ML18043A415

Responds to NRC Ltr Re Violations Noted in IE Insp Rept 50-255/78-25.Corrective Actions:Personnel Instructed Not to Block Safety Injection Actuation Signal & Departmental Procedures Revised to Address Issue of Technical Audits

ML18043A415
Person / Time
Site:	Palisades
Issue date:	12/27/1978
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7901180284
Download: ML18043A415 (4)

Text

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consumers

• Power tompany General Offices: 212 West Michigan Aven:.ie, .Jackson, Michigan 49201

• Area Code 517 788-0550 December 27, l978 Mr Jam.es G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - IE INSPECTION REPORT 78-25 Conswners Power Company's response to the alleged items of noncompliance delinel:!-ted in IE Inspection Report 78-25 is -as follows:

ITEM 1 - Infraction Technical Specification 6.8.l requires implementation of procedures contained in Appendix A to Regulatory Guide 1.33 which includes reactor shutdown, recovery from reactor trip and response to abnormal or alarm conditions.

According to Procedures A5.9, Plant Cooldown From Hot Standby, and SOP-1, Step 6 .1. 6, Cooldown of Primary System From Hot Standby, boration to the cold shut-down boron concentration is to be accomplished before blocking the safety in-jection signal. Procedure D4.l, Reactor Trip, does not address blocking the safety injection signal.

Contrary to the above, following a reactor trip and associated system pressure transient and receipt of the "Block Permissive" light, the licensee blocked the safety injection signal for approximately seven minutes on October l7, 1978 without first establishing cold shutdown boron concentration.

RESPONSE

Discussion Plant Procedures SOP 1, Section 6.1.6, and A5.9 do require that PCS boron be at the cold shutdown concentration prior to cooldown of the plant from hot standby to cold shutdown. As indicated in the report, a transient which re-sulted in an unplanned plant cooldown was in progress and the Safety Injection Activation Signal was blocked.

790118023'(

JAN 2 1979 Q

2 A review or this incident and the procedures and Technical Specifications re-lated thereto has been conducted. This review has revealed the following:

The two procedures which were cited as examples apply to a planned cooldown from hot standby to cold shutdown. Inasmuch as the procedure for recovery from a reactor trip does not prohibit blocking of Safety Injection, and because the requirements of Technical Specification 3.3 regarding Safety Injection System operability and the shutdown margin requirements of Technical Specification 3.10 were satisfied during the transient, no noncompliance with plant proce-dures or the Technical Specifications occurred.

It is also noted that if safety injection actuation is allowed to occur under these conditions, the resulting loss of cooling water to the containment building will require stopping the primary coolant pumps. The result is that boration of the PCS without PCS flow will occur, contradictory to the requirements of Technical Specification 3.1. Analyses conducted by Consumers Power Company indicate that adequate mixing of the boric acid will occur under these condi-tions, and a letter of clarification to permit boration without forced PCS flow has been submitted to NRR.

Corrective Action Taken Shift operating personnel have been instructed not to block a safety injection actuation signal wh,ich might occur as a result of an unplanned plant transient.

It is our conclusion- that this action will preve~ re*currence and no further correctiv*e action is conkidered necessary.

ITEM 2 - Infraction Technical Specification 6.5.2.8.a requires an annual comprehensive technical auditing program which the licensee has defined in Quality Assurance Program Procedure (QAPP) 18-51 to include health physics and reactor physics audits.

Contrary to the above, the licensee failed to perform technical audits of health physics and reactor physics during 1977.

RESPONSE

Corrective Action Taken and Results Achieved Technical audits of health physics and reactor physics were performed in 1978.

Corrective Action Taken to Prevent Recurrence Departmental procedures have been revised to specifically address the issue of technical audits including the responsibility for same. Departmental training on these procedures will be completed by February 1, 1979. These procedures should prevent recurrence of this type of incident .

3 Date When Full Compliance Will Be Achieved

• rhe 1978 audits have already been completed. Training on the new departmental procedures will be completed by February 1, 1979, at which ti~e, full compliance will have *been achiev~d.

ITEM 3 - Deficiency Technical Specification 4.1, by reference to Table 4.1.3, requires a shiftwise comparison check of secondary rod position indication against primary rod position indication.

Contrary to the above, the licensee removed the secondary rod position typer from service and failed to perform shiftwise comparison checks on October 19-20, 1978.

RJ:;SPONSE Corrective Action Taken and Results Achieved A review of this occurrence revealed that the Technical Specification require-ment to perform the shiftwise comparison could have been performed by either of the two fpl~owing methods:

• 1.

2.

Use the operable typer in both the primary and* secondary data loggers (by "swapping" it between the two units"). , '

Obtain the secondary rod position indication by voltage measurements.

Corrective Action Taken to Prevent Recurrence

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Shift operating personnel will be instructed that the above-described options exist and should be used under similar circumstances.

Date When Full Compliance Will Be Achieved The training described above will be performed during regularly scheduled "fifth-shift" training in early 1979.

ITEi~ 4 - Deficiency Criterion VII of Appendix B to 10 CFR 50 requires measures be established to assure purchased material and equipment conform to purchase documents, and that documentary evidence of such conformance be available at the plant site.

Contrary to the above, the licensee has accepted certain items under Purchase Order 93282 (primary coolant pump parts) without documented test results re-quired by the purchase order .

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RESPONSE

Discussion The purchase order in question specifie~ that dimensional test results be in-cluded with the documentation accompanying the order. Inste13:d, the ve.ndor supplied a certificate of conformance which stated that the items in question were manufactured and tested to the specifications and drawings referred to in the purchase order. As a result, a nonconforming material report (NMR) was issued. The NMR was used to change the requirements of the purchase order to make the certificate of conformance acceptable evidence of having received a satisfactory part. This was performed in accordance with approved plant pro-cedures.

Corrective Action Taken and Results Achieved The underlying cause of this problem was overspecification in the purchase order. The parts list has been changed to reflect that a certificate of conformance is acceptable documentation for parts from the vendor in question.

This action is expected to prevent recurrence; accordingly, no further corrective action is considered necessary.

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David P Hoffman Assistant Nuclear Licensing Administrator CC: Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement