IR 05000255/1988011
| ML18053A406 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/31/1988 |
| From: | Phillips M, Sutphin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18053A405 | List: |
| References | |
| 50-255-88-11, NUDOCS 8806150346 | |
| Download: ML18053A406 (12) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/880ll(DRS)
Docket No. 50-255 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant License No. DPR-20 Inspection At:
Covert, Michigan and General Offices, Jackson Michigan Inspection and May 2-5, 1988 Inspector:
Approved By:~~Chief Operational Programs Section Inspection Summary sf "31/ e; Date Date Inspection on April 25-29 and May 2-5, 1988 (Report No. 50-255/880ll(DRS))
Areas Inspected:
Special, announced inspection of the progress and results of the licensee's Configuration Control Project and its impact on the implementation of design changes, modifications, and the verification of as-built information/records. *
Results:
No violations or deviations were identified as a result of this inspection.
8806150346 880531 PDR ADOCK 05000255 n Q
DETAILS
~ Persons Contacted Consumers Power Company (CPCo)
- G. B. Slade, Plant General Manager
- W. E. Garrity, Engineering Manager, ESS
- M. R. Wade, Project Manager, CCP
- J. G. Lewis, Technical Director
- R. M. Rice, Operations Manager
- D. W. Joos, Administrative and Planning Manager
- W. L. Beckman, Radiological Services Manager
- R. D. Orosz, Engineering and Maintenance Manager
- J. T. Pomaranski, Site Manager, ESS
- C. S. Kozup, Technical Engineer
- G. Y. Yetsley, Senior QA Engineer
- P. F. Bruce, QA Engineer
- D. T. Malone, Nuclear Licensing Analyst
- M. L. Morris, Assistant Project Manager, CCP
- D. C. Takach, Site Manager, CCP J. F. Fremeau, Director of Nuclear Safety K. W. Berry, Director of Nuclear Licensing U.S. Nuclear Regulatory Commission (USNRC)
- E. R. Swanson, Senior Resident Inspector Other members of the staff and contractors were also contacte *Denotes those present at the exit interview on May 5, 198.
Configuration Control Project (CCP) General Purpose and Scope The purpose of this inspection was to examine the various activities undertaken by Consumers Power Company (CPCo) to satisfy their commitments to the NRC in the area of Configuration Management at Palisade Configuration Management generally has four phases or objectives, known as the Identification Phase, the Accounting Phase, the Control Phase, and the Status Phas The purpose of the Identification Phase is the establishment of the design basis for the nuclear power plan The design basis is generally all the necessary technical data used by the design function to select and specify the physical and operating characteristics. of everything in the plan This data is generally identified as the static and dynamic design basis informatio The static information applies to the properties and characteristics of materials, equipment,
- components, structures, and systems as-designed and as-buil The dynamic information applies to the operating, functional, or perform~nce capabilities, and/or characteristics of the materials, equipment, components, structures, and system The purpose of the Accounting Phase is the establishment of the mechanism to document the design basis information to the detailed extent necessary to satisfy the needs of the designers and users of the informatio It also includes the classification of the information so that its value is recognized and controlled or used in an appropriate manne The information is generally classified as Critical (the most important), Major, and Other (the minor or least important).
Associated with this phase, is the numbering or accounting type approach to identification of the data, for control in the establishment of the data, storage, status, retrieval, and end us The purpose of the Control Phase is the establishment and use of the design basis information control This include both the means for the control of the design basis data, so that it is not changed without proper authority, and the application of, or assigned responsibility for use of, the data so that requirements and commitments are met, and maintaine The 11Critical 11 data has the highest level of controls applie The purpose of the Status Phase is the ability to determine the official correct static and dynamic design basis information for any material, equipment, component, structure, system, or the plant, at any point in time; and to retrieve and display that information in an appropriate manner so that their responsibilities, requirements, and commitments can be me This status information retrieval and display phase should have appropriate hard copy capability, appropriate to the circumstance The Consumers Power Company (CPCo) Configuration Control Project (CCP)
was established to address these configuration management concepts to determine the status of present information, and to plan or initiate action as appropriate to meet CPCo) commitments to the NR The NRC was also interested in the current impact of these activities on the CPCo design change and modification programs; the implementation of design, design change, and modifications; and the verification of as-built information/record Documents and References Reviewed (1)
Project Plan, Configuration Control Project (CCP),
Palisades Plant, Revision 1, February 25, 198 (2)
Palisades Phase 1 Report, Preliminary Assessment, Configuration Management, August 12, 198 *
(3)
Palisades Configuration Control Project, NRC Site Visit, Status Briefing, March 31, 198 (4)
NRC Confirmatory Action Letter, CAL-RIII-86-002, dated May 21, 198 (5)
Consumers Power Company (CPCo) Submittal of Commitments to NRC dated December 1, 1986, in response to the NRC 10 CFR 50.54(f) information request dated November 20, 198 (6)
NRC RIII; December 23, 1986 letter to CPCo requesting more specific comment (7)
CPCo January 28, 1987, submittal to the NRC in response to item (6) abov (8)
CPCo letter to NRC dated March 26, 1987, regarding restart authorization, and stating power escalation commitment (9)
NRC Confirmatory Action Letter dated March 26, 198 (10) CPCo letter to NRC dated June 1, 1987, regarding System Functional Evaluation (SFE) Pre-Startups Actions Summar (11) CPCo September 14, 1987 letter to the NRC regarding CAL-RIII-86-02 Commitment Clarification (12) CPCo Palisades Plant, Configuration Control Project, Technical Advisory Group (TAG) Meeting Minutes - February 17, 198 (13) CPCo Palisades Plant, Configuration Control Project, Technical Advisory Group (TAG) Meeting Minutes - April 14~ 1988; (14) CPCo April 25, 1988 Energy Supply Services, Configuration Control Section. Monthly Resume - Apri (15) CPCo QA Surveillance Report No. S-QP-88-24; Configuration Control Project, Field Activitie (16) CPCo Palisades Design Basis Document, Service Water System; SWS-DBD, Revision 0, April 4, 198 (17) CPCo Project Management and Control PMC:
Procedure 13-13, Revision 1; January 15, 1988, 11 Identification and Tracking of CCP Discrepancies.
(18) CPCo Organization Chart for Energy Supply Services (ESS)
Engineering Department dated April 1, 1988.
(19) CPCo Organization Chart for the ESS Configuration Co~trol Project (CCP).
(20) CPCo Equipment Data Base (EDB). Inspection Results (1) Status of the Configuration Control Project (CCP)
The Configuration Management concept that CPCo wanted to develop and implement had two basic characteristics:
(1) control all changes to the facility, and (2) integrate these changes into all aspects of plant operatio To do this, documented design bases for the involved plant systems must be establishe This would involve the evaluation and selection of systems to be included, the retrieval or development of the original design bases, and the review of all changes to equipment and processes, such as drawings, specifications, and procedures that reflect the current design base As-built walkdowns, and tests or verifications of function, would be done as necessary, to confirm the status and compliance of the plant to requirement The licensee approached this objective in two phase Phase I was the 11 Preliminary Assessment 11 phase, and Phase II was the 11System Assessment 11 phas (a)
Phase I, Preliminary Assessment Phase I was completed in August 1987 and was a comprehensive review of the plant systems by several functional and systems evaluation groups, the results of which were tabulated and assessed for the impact on configuration control objective The groups an_d activi~ies that were involved, or whose results were assessed for impact on the objectives, were:
Maintenance Order Task Force
Operational Readiness Assessment
Material Condition Task Force (MCTF)
Augmented Test Program
System Functional Evaluation (SFE)
NRC - Safety System Functional Inspection (SSFI)
Quality Assurance Audits
Valve Improvement Program The reviews examined Design Basis information, the FSAR, System Descriptions, Operating Procedures, Valve Lineups, Power Supplies, System Walkdowns, Open Maintenance Work Orders, and the results of the Material Condition Task Forc The results of activities of the SFE, the NRC -
SSFI, and Operational Readiness Assessment were also include **
The systems that were identified having the potential
_ for producing the earliest and most significant impact
~ on plant regulatory and functional performance were:
- * * * *
- * * * * * *
SWS - Service Water System CCW - Component Cooling Water CSS - Containment Spray System AFW Auxiliary Feedwater PCS - Primary Coolant System CVC - Chemical and Volume Control HPSI - High Pressure Safety Injection LPSI - Low Pressure Safety Injection EPS Emergency Power System SPS - Station Power System RPS - Reactor Protection System CRD - Control Rod Drive CAS - Compressed Air System/High Pressure Instrument Air System The overall result of the Phase I assessment was conducted primarily under the cognizance of the Nuclear Operations Departmen Phase I resulted in the development of the Configuration Control Project Pla This plan is the guidance document for Phase II, and for the overall conduct of future configuration control activities, and includes the assignment of responsibilitie (b)
Phase II, System Assessment Phase II, which had been initiated, was designed to provide verified and corrected design documents for
_ the_selected Palisades Plant Systems identified in
- Phase The SWS was selected as the initial pilot system to be reviewed for the CC Ten separate CCP Tasks make up Phase II 1s principal objectives. They are:
Task 2.1 Electrical Wiring Diagram Verification and Correctio Task 2.2 Electrical Circuit and Recovery Drawing Verification and Correction.
Task 2.3 Mechanical and Civil Drawing Verification and Correction.
Task 2.4 Spare Parts Progra Task 2.5 Safety System Design Confirmation and System Functional Testin The systems that were identified,having the potential for producing the earliest and m6st significant impact
~ on plant regulatory and functional performance were:
- * *
- *
- * * * * * * *
SWS - Service Water System CCW - Component Cooling Water CSS - Containment Spray System AFW - Auxiliary Feedwater PCS - Primary Coolant System CVC - Chemical and Volume Control HPSI - High Pressure Safety Injection LPSI - Low Pressure Safety Injection EPS - Emergency Power System SPS - Station Power System RPS - Reactor Protection System CRD - Control Rod Drive CAS - Compressed Air System/High Pressure Instrument Air System The overall result of the Phase I assessment was conducted primarily under the cognizance of the Nuclear Operations Departmen Phase I resulted in the development of the Configuration Control Project Plan. This plan is the guidance document for Phase II, and for the overall conduct of future configuration control activities, and includes the assignment of responsibilitie (b)
Phase II, System Assessment Phase II, which had been initiated, was designed to provide verified and corrected design documents for the selected Palisades Plant Systems identified in Phase The SWS was selected as the initial pilot system to be reviewed for the CC Ten separate CCP lasks make up Phase !I's principal objectives. They are:
Task 2.1 Electrical Wiring Diagram Verification and Correctio Task 2.2 Electrical Circuit and Recovery Drawing Verification and Correctio Task 2.3 Mechanical and Civil Drawing Verification and Correctio Task 2.4 Spare Parts Program.
Task 2.5 Safety System Design Confirmation and System Functional Testin *
t:-
Task 2.6 Q-List and Equipment Data Base Update and Validatio *
Task 2.7 Scope of Work for Remaining 34 Plant System *
Task 2.8 Mechanical and NSSS Design Bases Reconstitutio *
Task 2.9 Electrical Design Bases Reconstitution.
Task 2.10 Modification CPCo Commitments to the NRC that should also be addressed by the implementation of Phase II are:
One -
11Adequately describe the system design requirements which form the bases for the accident analysis.
Two - Determine 11that what exists physically in the plant satisfies the design bases, and that design documentation accurately reflects the physical plant.
11 -
Three - Provide 11the administrative controls necessary to ensure that changes to the design basis or operation are properly reviewed with regard to the design bases, and once implemented, that documentation is properly updated to reflect the change Each of the CCP Tasks results in the verification and correction, if required, of a selected set of Palisades Plant Design Document In addition, an enhanced design
- control process and the appropriate procedures will be developed for use after CCP is complete These are in line with the above NRC commitment Design Documents which were included are:
.
,,
.
Design and Vendor Drawings
Component Indexes, Schedules, and Lists
Design Basis Documents (DBD)
Equipment Database and Q-List
Analytical Models
CCP Discrepancy Reports The overall project was scheduled in the form of a Critical Path Method (CPM), with Target Schedules, to reflect the overall CCP target milestone The CCP is under the direction of the Manager of Engineering within the Energy Supply Services (ESS) Departmen The responsibility of Project Manager is being performed by the Section Head-Electrical, I&C, Confi_guration
Engineering; who reports to the ESS Manager of Engineerin _ Each of the ten tasks has a Task Project Engineer assigne ~ Significant progress had been made on the Pilot System, the SW Appropriate search and review had been made and a draft issue (Revision O) of the SWS Design Basis Document (DBD) was released April 4, 198 The inspector reviewed this DBD and made several comments on the contents for consideration by the license Several of the items had been previously recognized by the licensee as needing further attention and appropriate action was under consideratio All design control aspects of the CCP were being conducted using Quality Assurance (QA) approved plans and procedure The General Office (GO) Quality Assurance Support organization had prime responsibility, and the Palisades Plant QA provided QA overview for CCP activities conducted at the plan The resolution of problems was handled using CCP Discrepancy Reports, Deviation Reports (DRs),
and.Action Item Requests (AIRs) in accordance with appropriate CCP guidelines and established procedure Training had been established so that personnel performin~
CCP functions were adequately trained for performance of their assigned task It was done in accordance with the Project Management and Control Procedure for training, and included required reading, instruction by supervisors and project engineers, and appropriate on-the-job trainin Specific tasks included in the training were the Package Preparation Process, the Field Walkdown Process, and the Discrepancy Resolution Proces Overall progress on the CCP was on target for the initial objective The results of the SWS DBD activity were being reviewed for impact on the related Component Cooling Water (CCW) review A coordinated effort on the SWS and CCW was receiving appropriate emphasi This activity was in the Mechanical area of Task In the Electrical/I&C area, preparation of a DBD for the External Power Supply Transformer was substantially complete The drafting of a DBD for Instrument AC Systems was essentially completed and should be ready for release, for review and comments, in May 198 Work on the general concepts for DBDs on 4160 volt, 2400 volt, and 480 volt systems had been starte Work on the Diesel Generator Performance Criteria review will be initiated soo All electrical system requirements were being considered and reviewed, not just the safety-relate Substantial progress had been made on the walkdown and markup of electrical systems wiring diagrams, including
- ~ those associated with the plant control roo CCP Discrepancy Reports were generated and processed in the prescribed manner for each item or discrepancy between the installed as-built equipment and the wiring diagram A Technical Advisory Group had been established to provide general overview and guidance for the various tasks of the CC (2) Technical Advisory Group (TAG)
The TAG had been providing the technical oversight of the CCP and of any revisions to the scope of the CC Membership of the TAG consisted of ten senior personnel from both the Palisades Plant Staff and the General Office Staf Engineering, Operations, Maintenance, Radiological Services, Licensing, and planning groups were all represented on the TA The Normal TAG Functions and Responsibilities were as follows:
Concur on Priorities assigned to the list of vital safety and vital support system *
Provide guidance on extent of design basis reconstitution, safety system design verification, and safety system functional testin *
Review content and format of final design basis document *
Overview resolution of discrepancies between the FSAR and the reconstituted design bases, et *
Review criteria for adding more systems to the configuration control prqgra Provide concurrence on the addition/deletion of systems and/or activitie *
Provide concurrence on major modifications as recommended by the configuration control grou *
Review recommendations for enhancing existing design control measures to ensure proper configuration control in the futur *
Review and concur on all specific NRC commitments relative to configuration contro *
Document through meeting minutes the decisions and guidance agreed upon in TAG meeting The inspector determined, through the interview process and th~ review of minutes of the TAG meetings, that they were performing their required responsibilitie As a result of the review of the Project Plan for the CCP, discussions with the TAG members, and others associated with, or working on the CCP, the inspector identified the following items as being appropriate for a review, for future special consideration, as part of the configuration control project:
Separation of design basis data into two separate categories of information - static and dynamic, (Physical vs. Functional).
- Classification of Characteristics (or Data) into three levels of importance; such as Critical, Major, and Other (Minor).
- Establishment of a Configuration Control Board (CCB),
or Change Control Board, to maintain appropriate management level Control of Design Basis Data, in the long range future, if TAG is dissolved, as planne *
Determine the appropriate document level for the Design Basis Documents in the hierarchy of licensee documents, i.e. higher than the FSAR, equal to the FSAR, just below the FSAR, etc., or as appropriate in the Engineered Document Serie *
Review the Configuration Status Phase requirements of Configuration Management to make sure the retrieval and display of configuration information, and Design Basis Information, is accurate, specific, and user friendl The licensee indicated that they had, at various times in the past, considered these or similar items and would continue their evaluation of the (3) Conclusions The inspector's review of CCP activities to date indicated that CPCo had initiated their Configuration Control Project in a manner that was essentially consistent with their commitments to the NRC and the results were generally meeting the objectives expecte No violations or deviations were identifie * Exit Interview The inspecto~ met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on May 5, 1988, and summarized the purpose, scope, and findings of the inspectio The licensee stated that the information reviewed during the exit interview and which would be included in the inspectors report was not of a proprietary natur