IR 05000255/1992026
| ML18058B471 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/17/1993 |
| From: | Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 9302230106 | |
| Download: ML18058B471 (7) | |
Text
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Docket No~ 50-255 Licens~ No. DPR-~~
Consumers Power Company ATTN:
Gerald General Manager FEB 1 7 1993 Palisa~es Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI 49043
Dear Mr. Slade:
SUBJECT:
NOTICE OF VIOLATION (NRC INSI>ECTION REPORT NO.. 50-255/92026 (DRS)-)
This will acknowledge receipt of your letter dated January 29, 1993, in resporise to our l~tter dated December 15, 1992, transmitting a Notice of ~iolation assodiated with an inadequate administrative.control for change to a station operations procedure at the Palisades Nuclear Generating Plant.
We have reviewed your corrective actions and have no further question~ at this tim~.
These corrective actions will be examined.during future inspections.
220001 see Attached Distribution
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Burgess 02/ J7 /93 9302230106 930217 PDR ADOCK 05000255 G
PDR RIII
Sincerely,
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Original signed by Mirk A. Ring'
Mark A. Ring, Chief Operations Branch *
~sen 02_ 17 /93
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02/17/93
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Consumers Power Company Distribution cc w /enclosure:.
David P ~ Hoffman, Vi_ce 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
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Michigan Department of
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consumers Power
~-P' POWERINli
- NllCHlliAN"S PROliRESS Pali.sades Nuclear Plant:. 27780 Blue Star Memorial *Highway. Coven. Ml 49043 January 29, 1993 Nuclear Regulatory Commission Document.Control Desk Washington, DC 20555 GB Slade General Mana.~er DOCKET 50-255 - LICtNSE DPR~20 - PALISADES PLANT - REPLY TO NOTICE QF VIOLATION; NRC INSPECTION REPORT No. 92026 NRC Inspection Report No. 92026, dated D.ecember 15, 1992, for*warded the results of an NRC inspection of the Configuration Control Project (CCP);
The inspectiqn report identified an apparent viol*tion of NRC requireme~ts pertaining to the establishment of sufficient administrative measures to*
. control changes to procedutes.. Our reply to the Notice of Violation is.
provided in th~ Attachment to this letter.
In ~ telephone conversation between.JLKuemih of Consumers Power Co~pany and BLBurgess, Regio~ III Reactor Projects Section Chief, on January 4, 1993, Mr. Burgess granted an exten.sion for our reply to January 29; 1993.
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Gerald B'Slade General Manager CC Administrator, Region III, USNRC NRC Resident Insp~ctor - Palisades Attachment
Ii CONSUMERS POWER COMPANY Jo the best of my knowledge, informati-0n.and belief, th~ contents of this submittal are truthful and complete.
Sworn and subscribed to before me this 27th day of January 1993.
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_N o'rma *Jean J§)wler, Notary Public Van Buren County Michigan *
My commission expires 02/02/94
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ATTAGHMENT
. Consumers Power Company Palisades Plant Docke.t so.,2ss REPLY TO NOTICE -OF VIOLATJON
. NRC INSPECTION REPORT No. 92026 January 29, 1993 2 Pages
REPLY TO NOTICE OF VIOLATION
- .violatfon 10 CFR 50, Appendix 8, Criterion VI, "Document Control," requires that measures sh~ll be. e~tabliih~d to ~ontfol the issuance of documents, such as instructions, procedures,and drawings, including changes thereto, which prescribe all actions affe~ting quality. *
Contrary to th~ above, the licensee failed to establish sufficient administrative measures to control changes to statio_n operating procedure SOP-16, issued November 19, 1992, *to ensure that the necessary actions to maintain the quality of the* procedure were completed.
Reason for the Violation Durfng the biennial review process for syitem operating proced~re (SOP)-16,
"Compon~nt Cooling Water Syst~m," a step in the procedure.was evaluated because it contained requirements more restrictive than the component cooling
~ater (CCW) system's plant technical ~pecifications. The step required both CCW heat exchangers to be in service and operable at all times when the primary coolant system (PCS) temperature is greater than 325°F and if this condition could not be met, then Technical Specification 3.0.3 was applicable.
This step was more restrictive than Technical Specification 3.3.2d, which a 11 ows one CCW heat exchanger to be out of service for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. * The difference had been identified to the Operations Department by the Training Depart~ent via a procedure change request.
The step had been previously added*
to the procedure to resolve a design discrepancy discovered during the development of the design basis document (DBD) for the CCW system.
During the biennial review, the procedure reviewei reviewed the change request, as well as other applicable documentation, to determine the reason for invoking Te~hnfcal Specificati6n 3.0.3 if ~oth heat exchangers were not in service when
. the PCS temperature was greater than 325°F.
The *review concluded that no
reason existed to invoke Technical Specification 3.0.3 and that existing
. system oper~ting limitations effettively ensured that b6th ccw* heat exchangers were in service *when the PCS was above 325°F.
Therefore~ the statement invoking Techn~cal Specification 3.0.3 was removed from SOP-16.
During an inspection of the Configuration Control Project (CCP),the NRC inspector identified that the Technical_Specification 3.0.3 statement had been added to the. procedure as a result of corrective action in 1989. * The corrective action document was initiated by the DBD author based on an ana1ytica1 determination th~t the CCW heat exch~ngers would suffer tube
degradation due to excessive vibration if flow from two CCW pumps was directed to a single heat exchanger. This configuration would result when a safety injection signal (SIS) is received coincident with ope of the CCW heat exchangers being out of service in accordance with Technical Specification.
3.3.2d.
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The cause of this violation is that the plant tec~nical specifications, the final safety analysis rep6rt (FSAR}, and the design basis document (DBD) for the CCW system did not fully capture or explicitly document the desi~n limitations of the CCW system contained it1 the aforementioned analysis.
The inadequate documentation resulted in the procedure reviewer having inadeq~ate infbrmation to substantiate current CCW system design limitations.
Corrective Actions and Results Achieved The following corrective actioris are currently in progress to address the*
design limitation of the CCW system:
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A revision to SOP-16, "Compbnent Cabling Water System," has been pro~essed to include a statement that prohi~its operating the CCW *
system with one heat exchanger out of servic~ when the PCS is greater than 325°F.
An interpretation of the stat~ment added to SOP-16 (in 1 above) has been added to Standing Order 62, "Technical Specification Interpretation/Guidance."
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Corrective Action to Avoid Future Non-Compliance The following cor~ective action is proposed to p~~vent future non-compli~nce:
1.
Design basis document (DBD) 1.01, "CCW System," will be revised to more accurately describe system operation as discussed in the various
- analyses conducted as part of previous correctiv~ action and.recent analysis performed by the CPCo (NECO) Safety An~lysis group.
2.
FSAR Section 9.3, "CCW System," will be revised to better define CCW system design characteristics and operational limitations..
3.
The DBD Writers Guide will be revised to incorporate into the DBD.
format a section which explicitly discusses operating limitations.
4.
DBDs previously issued will be r~viewed and revised as necessary to comply with the new requirement (3 above) of the DBD Writers Guide; Date of Full Compliance Full compliance has be~n achieved.