ML18337A434
| ML18337A434 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/28/2018 |
| From: | O'Brien K NRC/RGN-III |
| To: | Arnone B Entergy Nuclear Operations |
| References | |
| EA-18-013 IR 2017007 | |
| Download: ML18337A434 (10) | |
See also: IR 05000255/2017001
Text
November 28, 2018
Mr. Charles Arnone
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: RESPONSE TO DISPUTED NON-CITED VIOLATION IN PALISADES
NUCLEAR PLANTNRC DESIGN BASES ASSURANCE INSPECTION
(TEAMS) INSPECTION REPORT 05000255/2017007WITHDRAWAL OF
NON-CITED VIOLATION
Dear Mr. Arnone:
On January 28, 2018, Palisades Nuclear Plant (PNP), provided a written response to the
U.S. Nuclear Regulatory Commission (NRC) Inspection Report 05000255/2017007 issued on
December 29, 2017, concerning a Design Bases Assurance Inspection completed at PNP. The
letter contested a Non Cited Violation 05000255/2017007-01 associated with the failure to test
the emergency diesel generators (EDGs) capacity to start and accelerate design basis
sequenced loads. Specifically, periodic testing and post-maintenance testing did not confirm
the Palisades EDG design requirement that the recovery time for the EDG voltage to return to
90 percent of rated voltage after each load step is less than 3 seconds. The letter explained
that the inspection report does not provide a rationale for contending that this testing is required
by the Institute of Electrical and Electronics Engineers Standard 308-1978 and does not explain
why PNP testing performed following maintenance activities that could adversely affect EDG
frequency and voltage response is inadequate.
The NRC reviewed PNPs reply and determined that the original enforcement decision to
disposition this issue as a violation of Title 10 of the Code of Federal Regulations, Part 50,
Appendix B, Criterion XI, Test Control, was not valid. Within the context of the Palisades
plant specific licensing basis, the high level/broad statement from Institute of Electrical and
Electronics Engineers Standard 308-1978 noted in the Non-Cited Violation could not reasonably
be construed as specifically requiring that licensee periodic EDG testing verify a necessary
minimum voltage is retained throughout the loading sequence. Further, the NRC inspection did
not include and the inspection report did not reflect a comprehensive look at the full extent of
Palisades post maintenance testing following EDG governor controller or voltage regulator work,
address/discuss a specific example thereof, nor provide a technical rationale that would
invalidate other testing performed as sufficient to meet regulatory requirements. The basis for
the NRC staff conclusion is enclosed.
C. Arnone -2-
This letter, its enclosure, PNPs January 29, 2018, response, and your response (if any) will be
made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html
and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal
Regulations, Part 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Kenneth G. OBrien
Director, Division of Reactor Safety
Docket No. 50-255
License No. DPR-20
Enclosure:
NRC Staff Assessment of Disputed
cc: Distribution via LISTSERV
C. Arnone -3-
Letter to Charles Arnone from Kenneth G. OBrien dated November 28, 2018.
SUBJECT: RESPONSE TO DISPUTED NON-CITED VIOLATION IN PALISADES
NUCLEAR PLANTNRC DESIGN BASES ASSURANCE INSPECTION
(TEAMS) INSPECTION REPORT 05000255/2017007WITHDRAWAL OF
NON-CITED VIOLATION
DISTRIBUTION:
RidsNrrPMPalisades Resource
RidsNrrDorlLpl3
RidsNrrDirsIrib Resource
DRPIII
DRSIII
ROPreports.Resource@nrc.gov
ADAMS Accession Number: ML18337A434
PACKAGE: ML18337A434
NCP-2018-004: ML18337A440
OFFICE RIII RIII RIII RIII RIII RIII
NAME JGilliam:cl JBenjamin KStoedter JCameron JCameron for KOBrien
Nonconcur MMarshfield
DATE 11/14/18 06/26/18 11/20/18 11/21/18 11/27/18 11/28/18
OFFICIAL RECORD COPY
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information provided in
Palisades Nuclear Plant (PNP) letter dated January 29, 2018, to determine whether Non-Cited
Violation (NCV) 05000255/2017007 was valid. This review was performed by an NRC staff
member having relevant regulatory knowledge and who did not participate in the inspection
documented in Inspection Report 05000255/2017007, which dispositioned the disputed
violation. The NRC staff referenced documents that are listed in the Reference Section of this
Enclosure and consulted with other NRC staff members that were independent from the original
enforcement decision, including members of the Office of Nuclear Reactor Regulation (NRR).
1. BACKGROUND
On December 29, 2017, the NRC issued Inspection Report 05000255/2017007
documenting the results of a Design Bases Assurance Inspection at PNP. The
report included an NCV of Title 10 of the Code of Federal Regulations (CFR), Part 50,
Appendix B, Criterion XI, Test Control, for the failure to periodically test the emergency
diesel generators (EDGs) capability to start and accelerate all of the sequenced loads
within the applicable design voltage and frequency transient and recovery limits. This
violation was dispositioned as NCV 05000255/2017007-01.
On January 29, 2018, PNP provided a written response to the NRC contesting the
enforcement decision associated with NCV 05000255/2017007-01. In the letter, PNP
stated that the NRC inspection report does not provide a rationale for contending that
periodic system testing to demonstrate that the EDGs could start and accelerate their
sequenced loads within the applicable voltage and frequency acceptance limits is
required by Institute of Electrical and Electronics Engineers (IEEE) Standard 308-1978
and does not explain why PNP testing performed following maintenance activities that
could adversely affect EDG frequency and voltage response is inadequate.
2. ORIGINAL ENFORCEMENT DECISION
Inspection Report 05000255/2017007described the violation as:
Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in
part, that a test program be established to assure that all testing required to
demonstrate that structures, systems, and components will perform satisfactorily
in service is identified and performed in accordance with written test procedures
which incorporate the requirements and acceptance limits contained in applicable
design documents. It also stated that test results shall be documented and
evaluated to assure that test requirements have been satisfied.
The Updated Final Safety Analysis Report [UFSAR], Section 8.1.1, Design
Basis, states, in part, that the engineered safeguards electrical system is
intended to meet all the other requirements identified in IEEE 308-1978. The
IEEE 308-1978, Section 7.4, Periodic Equipment Tests, states that, Tests shall
be performed at scheduled intervals to (1) Detect the deterioration of the system
towards an unacceptable condition. (2) Demonstrate that standby power
equipment and other components that are not exercised during normal
operation of station are operable.
Enclosure
Contrary to the above, as of November 15, 2017, the licensee failed to establish
a testing program to demonstrate that the EDGs could start and accelerate their
sequenced loads within the applicable voltage and frequency acceptance limits
periodically as required by IEEE 308-1978 and following maintenance activities
that could adversely affect EDG frequency and voltage response (e.g., governor
and voltage regulator maintenance activities). The licensee is still evaluating its
planned corrective actions, however, the team determined that the continued
non-compliance does not present an immediate safety concern because the
licensee reasonably determined the affected systems, structures, and
components remained operable.
Because this violation was of very-low safety significance and was entered
into the licensees Corrective Action Program as CR-PLP-2017-05265 and
CR-PLP-2017-05283, this violation is being treated as an NCV, consistent
with Section 2.3.2 of the NRC Enforcement Policy.
Licensee testing performed in accordance with Palisades Improved Technical
Specifications demonstrates starting and load sequencing of the EDGs to attain
steady state voltage and frequency, and in the required time (fully loaded condition).
The description section of the associated finding in the NRC inspection report noted
that the UFSAR Section 8.4.1.3, Design Basis states that the recovery time for the
EDG voltage to return to 90 percent of rated voltage after application of each load step
is less than 3 seconds. Hence, the focus of the enforcement action was that neither
periodic testing nor post maintenance testing verified that a necessary minimum voltage
is retained throughout the loading sequence, in particular verifying the UFSAR design
requirement that EDG voltage returns to 90 percent of rated voltage within 3 seconds
for each load step, instead providing a voltage verification only at the final fully loaded
condition within a prescribed time, and hence misses a testing opportunity that could
identify a deteriorating EDG.
3. LICENSEE POSITION
In a letter dated January 29, 2018, PNP concluded the inspection report does not
provide a rationale for contending that periodic testing to demonstrate that the EDGs
could start and accelerate their sequenced loads within the applicable voltage and
frequency acceptance limits is required by IEEE Standard 308-1978. In addition, the
NRC inspection does not explain why PNP testing performed following maintenance
activities that could adversely affect EDG frequency and voltage response is inadequate.
In summary, the bases for PNPs position is:
The IEEE Standard 308-1978, Section 7.1, Surveillance Methods, states that the
extent, selection, and application of the various surveillance methods, including periodic
testing, to indicate the operation status of Class 1E power systems will depend on
individual plant design requirements, and refers to the surveillance methods for
Class 1E equipment outlined in Table 3, Illustrative Surveillance Methods. Table 3
outlines the testing described in Section 7.4 of the IEEE standard, which is to detect the
deterioration of the equipment toward an unacceptable condition and to demonstrate
that standby power equipment and other components that are not exercised during
normal operation of the station are operable. The table does not specify that diesel
2
generator voltage and frequency recovery be monitored at periodic intervals. Instead
it specifies periodic monitoring of diesel generator dc auxiliary systems, starting
capability, loading capability, and breaker operation.
Additionally, PNP post-maintenance testing is performed in accordance with industry
guidance contained in various Electric Power Research Institute reports, and the reports
do not require that post maintenance EDG testing include voltage and frequency
recovery testing.
4. NRC STAFF REVIEW
The NRC staff reviewed the PNP position as it applied to the specific circumstances
surrounding NCV 05000255/2017007-01 as follows:
1. Palisades Final Safety Analysis Report
During this review, the NRC staff reviewed Palisades Final Safety Analysis Report
(FSAR) Chapter 8Electrical Systems. The relevant sections reviewed were:
- FSAR Section 8.1.1, Design Basis, states, in part, that the engineered
safeguards electrical system is intended to meet all the other requirements
identified in IEEE 308-1978.
- FSAR Section 8.4.1, Emergency Generators, describes the licensees design
parameters for its emergency generators. In the description and operation
Section (8.4.1.2) the licensee describes testing of the EDGs to be, Automatic
start and loading sequencing of the emergency generators are tested as part of
the safety injection testing. The emergency generators start-up may be
manually tested at any time to verify that the generator is ready for loading within
10 seconds and that it achieved acceptable steady state voltage and frequency.
Acceptable voltage is within the rating of the generator, and acceptable
frequency is such that flowrate through the safeguards pumps is within the
margins of the accident analysis. In addition, the section tells the reader to refer
to Technical Specifications for further details.
- FSAR Section 8.4.1.3, Design Analysis, states that, The generator is rated at
2,500 kW at 0.8 power factor with a two-hour overload rating of 2,750 kW. The
recovery time for voltage to return to 90% of the rated voltage after application of
each load step is less than three seconds.
As a result of the above review, the NRC staff concluded that the licensees use of
IEEE 308-1978 and the design basis for the EDG (voltage, frequency, rating, etc.) is
described in the FSAR.
3
2. IEEE Standard 308-1978
The NRC staff reviewed the testing requirements discussed in IEEE
Standard 308-1978. Section 7.4,Periodic Equipment Tests, states, Test
shall be performed at scheduled intervals to: (1) Detect as well as practicable,
the deterioration of the equipment toward an unacceptable condition and
(2) Demonstrate that standby power equipment and other components that are
not exercised during normal operation of the station are operable.
The staff noted that the IEEE standard has a table that lists the parameters of the
diesel generator and illustrative surveillance methods for each parameter. Per the
table, dc aux systems, starting capability, loading capability, and breaker operation
should be periodically tested. The table shows the following parameters illustrative
surveillance methods for continuous monitoring: voltage, frequency, amperes, watts,
vars, winding temperature, field amperes, field volts, ground, control voltage, and
breaker position. However, the standard does not provide EDG voltage and
frequency acceptance limits.
Conversations with NRR staff noted that the IEEE Standard 308-1978 tabulated
format of illustrative tests in Table 3 does not coherently specify or explain the
rationale on how the tests demonstrate conformance with requirements in licensing
basis and lacks clarity and definition for EDG testing. As a result of the above
review, the staff concluded that IEEE 308-1978 provides information on what
parameters of the diesel generator to test but does not give specifics on how to test
those parameters and how often.
3. Evaluation of the Original Enforcement Action
The licensee is required to adhere to IEEE 308-1978, including the Section 7.4
provision that applies to Class 1E power systems, and is the focal point of the NCV,
that Tests shall be performed at scheduled intervals to (1) Detect as well as
practicable the deterioration of the system towards an unacceptable condition.
(2) Demonstrate that standby power equipment and other components that are not
exercised during normal operation of station are operable.
The NRC staff reviewed previous regulatory initiatives that related to Palisades EDG
reliability and testing including NRC reviews done for the Systematic Evaluation
Program, Station Blackout Rule, Maintenance Rule, and transition to Palisades
Improved Technical Specifications. Within the context of the Palisades plant specific
licensing basis, that high level/broad statement from IEEE 308-1978 noted in the
NCV could not reasonably be construed as specifically requiring that licensee
periodic EDG testing verify a necessary minimum voltage is retained throughout the
loading sequence, in particular verifying the UFSAR design requirement that EDG
voltage returns to 90 percent of rated voltage within three seconds for each load
step. In fact, evidence would suggest that surveillance tests described in the
Palisades Technical Specifications were deemed sufficient to meet the testing
requirements with respect to starting and load sequencing of the EDGs.
Further, there is insufficient rationale to support the contention that 10 CFR 50,
Appendix B, Criterion XI, requires that post maintenance testing following EDG
governor controller and voltage regulator replacement include testing of the voltage
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recovery specification described in the USFAR, specifically a test to verify the
recovery time for the EDG voltage to return to 90 percent of rated voltage after
application of each load step is less than 3 seconds. In particular, the NRC
inspection did not include and the inspection report did not reflect a comprehensive
look at the full extent of Palisades post maintenance testing following EDG governor
controller or voltage regulator work, address/discuss a specific example thereof, nor
provide a technical rationale that would invalidate other testing performed as
sufficient to meet regulatory requirements.
As a result of the above review, the NRC staff determined that the original
enforcement action of NCV 05000255/2017007-01 was not valid.
5. CONCLUSION
Based on this review and after consideration of the information provided by PNP in letter
dated January 29, 2018, the NRC staff determined that the violation of 10 CFR Part 50,
Appendix B, Criterion XI, Test Control, did not occur as stated in NCV 05000255/2017007-01.
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6. REFERENCES
1. Letter to Charles Arnone from Mark Jeffers; Palisades Nuclear PlantNRC Design
Bases Assurance Inspection (Teams) Inspection Report 05000255/2017007;
December 29, 2017
2. Letter from Jeffery A. Hardy to the NRC Document Control Desk; Design Bases
Assurance Inspection (Teams) Inspection Report 05000255/2017007;
January 29, 2018
3. Palisades Nuclear Plant Final Safety Analysis Report; Revision 32
4. IEEE Standard 308-1978, IEEE Standard Criteria for Class IE Power Systems for
Nuclear Power Generating Stations
5. Regulatory Guide 1.9, Selection, Design, Qualification, and Testing of Diesel
Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power
Plants; Revisions 3 and 4
6. Safety Guide 9, Selection of Diesel Generator Set Capacity for Standby Power
Supplies; dated March 10, 1971
7. Regulatory Guide 1.108, Periodic Testing of Diesel Generator Units Used as Onsite
Electric Power Systems at Nuclear Power Plants; Revision 1
8. NUREG 1432 Standard Technical Specifications: Combustion Engineering (CE)
Plants; Revision 1
9. Letter from D.M. Crutchfield (NRC) to D.P. Hoffman (CPCo), SEP TOPIC VIII-2,
Diesel Generators (Palisades Plant); dated February 27, 1981
10. Letter from D.M. Crutchfield (NRC) to D.P. Hoffman (CPCo), SEP TOPIC VIII-Onsite
Emergency Power SystemsDiesel Generator, Safety Evaluation for Palisades;
dated October 29, 1981
11. NUREG 0820 Integrated Plant Safety Assessment Systematic Evaluation Program
(SEP)Palisades Plant Final Report; dated October 1982
12. Letter from T.V. Wambach (NRC) to D.J. VandeWalle (CPCo), Supplement to
the Integrated Plant Safety Assessment for the Palisades Plant; dated
November 7, 1983
13. NUREG 1424 SafetyEvaluation Report Related to the Full-term Operating License
for Palisades Nuclear Plant; dated November 1990
14. Letter from A. Masciantonio (NRC) to G.B. Slade (CPCo), Palisades PlantStation
Blackout Analysis Safety Evaluation (TAC NO. M68578); dated June 25, 1992
15. NUREG-0933 Resolution of Generic Safety Issues: Item B-56: Diesel Reliability;
Revision 2
6
16. NUREG-0933 Resolution of Generic Safety Issues: Item B-156: Systematic
Evaluation Program; Revision 8
17. NUREG/CR-0660 Enhancement of Onsite Emergency Diesel Generator
Reliability; dated February 1979
20. RT-8D; Palisades Nuclear Plant Technical Specifications Surveillance Procedure;
Revision 38
7