IR 05000255/1991018
| ML18058A152 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/05/1992 |
| From: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 9202110012 | |
| Download: ML18058A152 (3) | |
Text
Docket No. 50-255 License No. DRP-20 Consumers Power Company ATTN:
G.erald General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI 49043
Dear Mr. Slade:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-255/91018(DRP))
This will acknowledge receipt of your letter dated January 9, 1992, in response to our letter dated November 26, 1991, transmitting a Notice of Violation associated with Inspection Report No. 50-255/91018(DRP).
Some of the issues raised in your letter necessitate further discussion and clarification.
First, your letter suggests we considered Component Cooling Water Pump P-52C inoperable as a consequence of the inoperability of pressure switch PS-0918.
We did not make such a determination.
We did determine PS-0918 was inoperable, and it was this component to which we applied Technical Specification 3.4.2 time limits.
The relative lack of safety significance of this component is reflected in the low severity level assigned to the violation.
Second, we disagree with your interpretation of the language of Technical Specification 3.4.1.c:
".*. required to function during accident conditions."
You consider only single-failure design basis accident conditions.
You infer that the design bases and the licensing bases coincide.
Actually, licensing bases must be equal to or better than design bases.
The licensing bases (and, thereby, technical specifications) may involve component
"performance requirements" (10 CFR 50.34(b)2) in excess of those needed to meet single failure.
In this case, PS-0918
"performance requirements" are stated in FSAR Section 9.3.2.3.3.
They include operation to start pump P-52C in the "accident conditions" involving failure of the other pumps.
Therefore, Technical Specification 3.4.1.c applies to PS-0918 and the violation is valid as written.
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Consumers Power company
We agree with your conclusion that a timely 50.59 evaluation was not made when PS-0918 was disabled.
This was the root cause of the problem, to which the Notice of Violation could have been addressed, and for which your stated corrective actions appear appropriate.
These corrective actions will be examined during future inspections.
Sincerely,
____ ;. _______.
c::::::.~ -
Edward G. Greenman, Director Division of Reactor Projects cc:
David P. Hoffman, Vice President Nuclear Operations P. M. Donnelly, Safety and Licensing Director DCD/DCB (RIDS)
OC/LFDCB Resident Inspector, RIII James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health Palisades, LPM, NRR SRI, Big Rock Point RIII
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Consumers Power Company
We agree with your conclusion that a timely 50.59 evaluation was not made when PS-0918 was disabled, This was the root cause of the problem, to which the Notice of Violation could have been addressed, and for which your stated corrective ~ctions appear appropriate.
These corrective actions will be examined durinq future inspections.
Sincerely, c:_~,~ :, *_ : -
Edward G. Greenman, Director Division of Reactor Projects cc; David P. Hoffman'- Vice President Nuclear Operations RIII P. M. Donnelly, Safety and Licensing Director DCD/DCB (RIDS)
OC/LFDCB Resident Inspector, RIII James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health Palisades, LPM, NRR SRI, Big Rock Point RIII RIII Jorgensen/dp Pederson Shafer
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