IR 05000255/1994007
| ML18059A914 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/24/1994 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18059A915 | List: |
| References | |
| EA-94-041, EA-94-41, NUDOCS 9404040098 | |
| Download: ML18059A914 (16) | |
Text
'i Docket No. 50-255 License DPR-20 EA 94-041 Consumers Power Company ATTN:
Mr.,
Acting General Manager March 24; 1994 Palisades Nuclear Generating Plant 27780 Blue Star Memorial High~ay Covert, MI 49043-9530
Dear Mr. Palmisano:
SUBJECT:
PALI SADES ENFORCEMENT CONFERENCE REPORT NUMBER 50-255/94007 (DRS) *
This* refers to an Enforcement Conference conducted by Mr. John B. Marttn and other members of the Region Ill staff on March 11, *1994, regarding activities
- at your Pa 1 i sades Nuc.l ear Generating Pl ant authorized by your NRC License No..
DPR-20, and to the discussion of our findings.with you and your staff.
We have enclosed a report summarizing the discussion.*.
You will be notified by separate correspondence of our decision regarding the Enforcement Actio~ based on the information presented and discussed at the Enforcement Conference.
No response is required until you are notified of the proposed' Enforcement Action.
- As discussed at the conference, the Service Water System Operation~l Performance Inspection (SWSOPI) identified five examples where prompt corrective actions were not taken to previously identified concerns.. One significant example identified a single failure -vulnerability that could lead to the-loss of all engineered safeguards system pumps.
The significance and the number of design issues 'identified during this.inspection also led th~_
team to conclude that the sy~tem desig~ was-not clearly und~~siriod ~nd.no clear understanding e~isted between system and design engineering as to which was responsible for system design.
- In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
- this letter and the enclosed inspection report will be pliced in the NRC Public Document Room.
9404040098 940324 PDR ADOCK 05000255
Consumers Power Company
March 24, 1994 We will gladly discuss any questions you have concerning this Enforcement
. Conference.
Enclosure:
Enforcement Conference
- Report No. 50-255/94007
REGION lI I Report No. 50-255/94007 (DRS).
Docket No.
50-255 Licen~e No. DPR-20 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:.
Palisades Nuclear Generating Plant Meeting Conducted:
March 11, 1994 J
Meeting At:
Region III Office, Lisle, Illinois Type of Meeting:
Enforcement Conference Inspection Conducted:
Onsit~ at Palisades Nuclear Plant January 10 through February 11, 1994 Inspectors:
S. Burgess
- ,J. Guzman Approved By:
J. Lennartz*
R. Lerch Meeting Summary EA 94-041 Enforcement Conference on March 11. -1994. (Report No. 50-255/94007)
Areas Discussed~* A review -0f the five examples of the apparent* violation identified during inspection 50-255/94007(DRS), their safety significance, and correcti.ve actions taken or planned by.the licensee.* The inspection identified five* examples where prompt cprrective actions were not taken*tri previously identified concerns.
One significant example identified a single failure vulnerability that could lead to the loss *of all engineered safeguards system pumps and loss of the required safety injection function.
Three examples related to system performance analysis and testing issues, and one example was relative to the seismicity of instrument tubing.
. 9404040100 940324 PDR ADOCK 05000255 G
PDR (
Details 1.
Persons Present at Conference I
D. W. Joos, Sr. Vice President, Nuclear R. A. Fenech, Vice President Nuclear D. W. Rogers, Plant Safety and Licensing Director R. D. Orosz, Nuclear Engineering and Construction Manager R. M. Rice, Director, Nuclear Performance Assessment Department (NPAD)
J. Kuemin, Licensing Administrator S. Wawro, Operations Support Superintendent R. Brzezinski, Engineering Team Leader/ NRAD K. Osborne, System Engineering Manager D. Vandewalle, Mechanical/Civil/Structural Engineering Manager R. J. Gerling, Reactor and Safety Analysis Manager T. Duffy, Safety Analysis Supervisor P. J. Gire, Systems Engineering G. H. Groff, Control Operator U. S. Nuclear Regulatory Commission, Region III*
J. B. Martin, Regional Administrator, Riii G. E. Grant*, Dire*ctor,. Division of Reactor Safety, Riii G.- C. Wright, Chief, Engineering Branch, Riii.
L. F. Miller, Chief, Reactor Projects Branch 2, Riii R.
W~ DeFayettei Director EICS, Rlli P~.R. Pelke, Enforcement Specialist, Riii A. H. Hsia, Project Manager, NRR S. B. Burgess, Team Leader, Riii B.. A. Berson, Regional Cdunsel, Riii R. M. Lerch, Reactor Inspector J. A. Lennartz, Reactor Engineer, Rill C. N. Orsini, Reactor Engineer, Rill J. G. Guzman, Reactor Inspector, Rill
- 2.
Enforcement Conference An Enforcement Conferen~e was held in the NRC Region III office on March 11, 1994.
This conference was conducted as a result of the preliminary.
findings of the inspections conducted between January 10 and February 11, 1994, in which an apparent violfttion of NRC regulations and license conditions were identified.
The violation identified five examples where prompt corrective actions were not taken to previously identified concerns.
The inspection findings were documented in Inspection Report No. 50-255/94007(DRS), transmitted to the licensee by letter dated March 4' 1994.
The purposes of this conference were to (1) di$cuss the apparent violations, their causes, and the licensee's corrective actions; *(2)
determine if there were any escalating or mitigating circumstances; and
(3) obtain any information which would help determine the appropriate enforcement action.
The licensee's representatives described the Service and Component Cooling Water systems and discussed the five examples of inadequate corrective action.
Included in the discussion were (1) the technical issues, (2) the process that led to the lack of corrective action, (3)
remedial actions taken, (4) actions to prevent recurrence, and (5) the safety significance. A summary of the licensee's corrective actions is included in the attached handout that the licensee provided at the conference (Attachment 2).
The licensee did not contest any of the apparenLviolations and was in agreement with the NRC's understanding of the violation.
- At the conclusion of the meeting, the licensee was informed it would be notified in the near future of the final enforcement action. A copy of the licensee's and NRC's presentations are attached to this report.
- Attachments:
1.
NRC Presentation Handout 2.
Licensee Presentation Handout
U.S.. NRC. REGION Ill-PALISADES ENFORCEMENT CONFERENCE March 11, 1994 10:00 A.M. (CST).
EA 94-041 *
REPORT NUMBER 50-255/94002
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. REGION Ill OFFICE 801 WARRENVILLE ROAD LISLE, ILLINOIS
PALISADES ENFORCEMENT CONFERENCE Agenda INTRODUCTION ANo*-*oPENING REMARKS:
Geoffrey E. Grant, Director, Division of Reactor Safety NRC OVERVIEW:
Geoffrey C. V\\/right, Chief, Engineering Branch*
SUMMARY OF APPARENT VIOLATIONS:
Sonia D. Burgess, Team Leader, Division of Reactor Safety
- .
LICENSEE PRESENTATION AND DISCUSSION:
Consumers Power Company NRC FOLLOWUP QUESTIONS*
CLOSIN.G REMARKS:
John B. Martin, Region Ill Admi11istrator
APPARENT VIOLATION 10 CFR Part 50, Appendix B, Criterion XVI states that measures shall be established to assure that conditions adverse to quality, such as _
failures, malfunctions, deficiencies, deviations, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
CONTRARY TO THE ABOVE a. Prompt corrective actions were not taken to ~ddress that backup cooling to the ESS pumps from the service water system (SWS)
- could not be accomplished during a LOOP/LOCA because non-safety instrument air was* requ_ired for valve actuation.. This was previously identified on May 25, 1989, in the Component Cooling Water (CCW) Safety System Design Confirmation (SSDC) report.
b. Prompt corre_ctive actions were not taken to incorporate the non-critical header isolation valve, CV-1359, into a leakage test-program as previously identified on May 17, 1990, in the SWS SSDC report.
c. Prompt corrective actions were not taken until January 27, 1994, to address the seismicity of bent instrument tubing and unistrut supports located in front of the CCW heat exchangers.
1 The condition was identified on January 4, 19_94.
d. Prompt corrective actions were not taken to couple the SW IST pump reference values and the SW flow balancing test as pr~viously identified on May 4, 1990, in the SW SSDC.
The apparent violations discussed in this enforcement conference are subject to further review and may be subject to change prior to any resulting enforcement action.
.
l
e. Inadequate corrective action was taken to address that-SWS test T-216, "Service Water Flow Verification," Revision -4, balanced flow to the CCW heat exchangers at or -v-ery near their required flow rates and did not allow for pump degradation. This was identified in the SW SSDC on May 4,- 1990.
The apparent violations discussed in this enforcement conference are subject to further review and may be subject to change prior to any resulting enforcement action.
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PALISADES NUCLEAR Pl.ANT
.**PALISADES ENFO*RCEMENT CONFERENCE MARCH 11-, 1 994
AGENDA NRC INTRODUCTION INTRODUCTION....... *........... *... ow Joos
'
SYSTEM DESCRIPTION.... *......... ST WAWRO FIVE EXAMPLES... *.......... :..... RD OROSZ EVENTS CAUSES CORRECTIVE ACTIONS SAFETY SIGNIFICANCE NPAD PERSPECTIVE... ~........ ~. *.... RM RICE PERFORMANCE IMPROVEMENT DWJoos.
AIR TO CLOSE
- sis OPENS CV-0<151 ccw PALISADES NUCLEAR PLANT ENGINEERING SAFEGUARDS SYSTEM PUMP COOLING CCW SURGE TANK EL.... * 653'
OTHER ccw LOADS 4 ESS PUMP COOLERS.
cv-0q47 EL..... 571'
AIR TO OPEN 3 ESS PUMP COOLERS CV-087<1 CV-0'H3 AIR TO CLOSE*
SIS OPENS AIR TO CLOSE ( CV-0880
~
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LOSS OF All ES~ PUMPS Technical Issues Process Single failure of CCW supply valve for ESS pumps cooling Original design basis - pumps did not require cooling water 1986 vendor information questioned original design basis 1989 safety system design confirmation - single failure identified *
Issue Identification
> I Evaluatlon I -~--- > Corrective Action
Process
../
Expectations
Knowl eqge/Capabil it i es
Performance 1986 Inadequat~ inve~tigation of pump cooling r~quiremerits ~ifh inadequate follow up 1989 Inadequate investigation of single failure*vulnerabilities Remedial Actions 1.
Immediate action to open CCW valves.
2.
Pump cooling requirements analysis (04/30/94).
-3.
Pump*cooling modifications if required*(95 refueling~utage).
Actions to Prevent Recurrence 1.
Reevaluate SSOC findings (S&l involvement for design knowledge). (08/01/94)
Safety Significance 1.
Valve fails to open position (fail-safe) - failure unlikely.
2.
Preliminary conclusion - HPSI Pumps qualified for service.
3.
Containment can be cooled with air co6lers only. -
SYSTEM PERFORMANCE ANALYSIS AND TESTING.ISSUES Technical Issues Process Pump IST program linkage to system performance verification System performance verification deficiencies Heat exchanger fouling Instrument uncertainties Pump degradation Boundary valve degradation CV-1359 leakage testing program Issue Identification
> Evaluation
> Corrective Action
Process
.I
Expectations
Knowledge/capabilities
Performance 1990 safety system design confirmation identified these issues I
Narrow focus on code compliance Accepted system performance verification weaknesses Testing capability weaknesses Management accepted inadequate respoose to issues Remedial Actions 1.
Service water system performance reverification. {05/08/94)
Actions to Prevent Recurrence 1.
Coordinate pump IST program with system performance verifications. (all future testing)
2.
Multi-disciplinary evaluation of analysis a~d.testing interf~ces and development of test methodologies.
(12/15/94)
3.
Reevaluate SSDC findings (S&L involvement for design knowledge). (08/01/94)
Safety Significance 1.
Preliminary analysis shows adequate SW flow below a S0°F lake temperature..
2.
Engineering's judgement is that SW flows are adequate for anticipated lake temperatures although some tuning of SW system may be required.
INSTRUMENT TUBING SEISMIC ADEQUACY
- Technical Issues Tubing supports are not in accordance with current span requirements Tube is bent; one support is bent, another very flexible
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Tubing_ meets *interim operability criteria; but may not meet FSAR requirements for allowablestress-**- ---
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Process I Work Order
> Operations Review
Process *
Expectations
Knowledge/capabilities
- Performance
- System engineering not adequately involved i~ work order process System engineering knowl~dge of potential operability issues could be improved Remedial Actions I.
Engineering analysis of tubing/supports to determine FSAR compliance {07/01/94).
,
2.
Evaluate imp~ct of not meeting current design_ retjuirements on other instrument -
t~bing configuration {09/01/94).
Action to Prevent Recurrence
- * T.
Enhance work order review process by ensuring process *and expectations include a timely review of all work orders by system engineer to assess operability
{06/01/94).
2.
Provide continuing training of system engineers on lessons learned regarding operability issues; examples are; instrument tubing span criteria and.hanger integrity criteria {07/01/94).
Safety Significance 1.
Tubing meets interim operability criteria.
2.
Judgement of engineering is that tubing will be shown to meet FSAR criteria.