ML18052A634

Ack Receipt of 860717 Response to Violation Noted in Insp Rept 50-255/86-14.Surveillance Testing Program Inadequate to Ensure That Auxiliary Feedwater Sys Will Perform as Described in FSAR

ML18052A634
Person / Time
Site:	Palisades
Issue date:	08/05/1986
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8608070195
Download: ML18052A634 (2)

See also: IR 05000255/1986014

Text

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Docket No. 50-255

Consumers Power Company

ATTN:

Dr. F. W. Buckman

Vice President

Nuclear Operations

212 West Michigan Avenue

Jackson, MI

49201

Gentlemen:

AUS o 5 1986

This refers to your response dated July 17, 1986 to the violation identified

in IE Inspection Report 86014.

In your response you stat~d that ANSI N 18.7

does not require that each test assure that the acceptance limits contained in

applicable design documents are satisfied. Further you indicated that the

current operational surveillance program, in conjunction with the testing

performed during the preoperational phase and subsequent to maintenance,

modification and procedural changes, address as an overall test program, the

requirements of ANSI N 18.7-1976.

The requirements of the ASME B&PV Code,

Section XI, and the Palisades Technical Specifications are used as a basis for

monitoring pump degradation.

We agree that the elements you outlined are necessary for a testing and

surveillance program which meet the requirements of ANSI 18.7-1976, the B&PV

Code,Section XI and the Palisades Technical Specifications. However, with

respect to Section XI requirements associated with surveillance testing of the

Auxiliary Feedwater System (AFW), your program was not adequate to assure the

AFW system will perform as described in the FSAR.

Specifically, the

parameters contained in your surveillance test (i.e., DP, NPSH, vibration,

discharge pressure, etc.) could have degraded to the point where the minimum

flow required from each AFW pump during accidents requiring AFW flow would not

be met.

These same degraded parameters measured against the Section XI

requirements would be within the band of acceptable pump operation.

Our

concern relative to this problem was the basis for our violation.

Further review of other safety related system surveillance tests by the

Resident Inspectors identified the absence of verification of recorded

parameters with design document flow requirements.

While we recognize that

the Section XI pump performance parameters may be adequate to assure

acceptable performance of safety related pumps, your program as currently

implemented did not provide assurance that the minimum flow requirements

stated in design documents would be met.

Based on this review, you were

requested to determine if the problem identified with the Section XI

surveillance testing might apply generically to other safety system surveillance

tests.

Your response addressed the generic question and refers to enhancements to the

surveillance testing program to positively demonstrate that each of the

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F. W. Buckman

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auxiliary feedwater pumps meets the FSAR Accident Analysis flow requirements.

This course of action appears adequate and no further response to this letter

is required.

Should you wish to further discuss this matter, please feel free to contact

Mr. B. L. Burgess of my staff.

cc:

Mr. Kenneth W. Berry, Director

Nuclear Licensing

J. F. Firlit, General Manager

DCS/ RSB (RIDS)

Licensing Fee Management Branch

Resident Inspector, RIII

Ronald Callen, Michigan

Public Service Commission

Nuclear Facilities and

Environmental Monitoring

Section

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18/04/86

RIII

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I ould~mond

Sincerely,

Charles E. Norelius, Director

Division of Reactor Projects

RIII

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