ML18052A720
| ML18052A720 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/17/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8610090292 | |
| Download: ML18052A720 (6) | |
Text
consumers Power POW ERi Nii
/1/1.ICHlliAN'S PROliRESS General Offices:
1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 July 17, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO IE INSPECTION REPORT 86-014 Kenneth W Berry Director Nuclear Licensing One item of violation was identified in IE Inspection Report 86-014 dated June 17, 1986.
The following is our response to that item.
Item 1:
Violation (255/86014-05) 10 CFR 50, Appendix B, Criterion XI, as implemented by CPC-2A which commits to ANSI N18.7-1976, requires that a test program be established that assures that testing be performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable design documents.
Contrary to the above, the licensee's test program for the auxiliary feedwater system contains acceptance criteria based only upon ASME Code Section XI requirements; the test program does not incorporate acceptance criteria that assures the system will perform as described in the design documents (ie, FSAR accident analyses).
This condition has existed since 1978.
Response
Discussion While we agree that our testing program for the auxiliary feedwater pumps could be enhanced by periodic routine testing to positively demonstrate 8610090292 860717 PDR ADOCK 05000255 Q
PDR OC0786-0114-NL04 JUL 211986
'(o Fo/
d
J G Keppler, Administrator
-- Palisades Plant Response to IEIR 86-014 July 17, 1986 that the system performs as described in the FSAR Accident Analysis, we believe our existing program currently meets the requirements of ANSI Nl8.7-1976.
2 ANSI Nl8.7-1976 does indeed require that a test program be established that assures that testing be performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable design documents.
ANSI Nl8.7-1976 further requires that the program cover all types of required testing, which includes 1) tests during the preoperational phase, 2) tests during the initial operational phase, 3) surveillance tests during the operational phase, and 4) tests associated with the demonstration of satisfactory performance following maintenance, modifications or procedural changes.
ANSI Nl8.7-1976 does not require that each test assure that the acceptance limits contained in applicable design documents are satisfied.
Rather, the overall test program shall address this assurance.
At Palisades, testing to demonstrate that design requirements are satisfied is performed during both the preoperational phase, and following major pump maintenance or modification.
Routine surveillance testing is currently conducted to monitor for pump degradation in accordance with ASME B&PV Code,Section XI, and the Palisades Technical Specifications.
Corrective Action Taken and Results Achieved Auxiliary Feedwater System design requirements have been clarified through evaluation of the vendors original flow requirements and reevaluation of flow requirements for the limiting plant transient.
Corrective Action To Be Taken to Avoid Further Violation Enhancements will be implemented to the surveillance testing program to positively demonstrate that each of the auxiliary feedwater pumps meets the FSAR Accident Analysis flow requirements.
This verification will initially be performed prior to plant start-up from the current maintenance outage, and subsequently at 18 month intervals.
The Palisades FSAR will be revised to reflect the currently assumed requirements of the Auxiliary Feedwater System in the next annual update, scheduled for late 1986.
An evaluation will be completed by December 31, 1986 which will address the feasibility of generically extending similar test program enhancements to other safety related pump testing.
OC0786-0114-NL04
J G Keppler, Administrator
~ Palisades Plant Response to IEIR 86-014 July 17, 1986 Date When Full Compliance Will Be Achieved Enhancements of the auxiliary feedwater pump test program will be assured prior to the end of the current maintenance outage, approximately September 1, 1986.
- ~L 253~ 6tfL Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades OC0786-0114-NL04 3
Docket No. 50-255 Consumers Power Company ATTN:
Dr. F. W. Buckman Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:
MAY 0 1
( 1986 This refers to the routine safety inspection conducted by M. L. McCormick-Barger of this office on April 14-25, 1986, of activities at the Palisades Nuclear Generating Plant authorized by NRC Operating License No. DPR-20 and to the discussion of our findings with Mr. J. G. Lewis and others of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection.
Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
No violations of NRC requirements were identified during the course of this inspection.
In accordance with 10 CFR 2.790 of the Commission 1s regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
8605120199 860507 PDR ADOCK 05000255 G
Enclosure:
Inspection Report No. 50-255/86013(DRS)
See Attached Distribution RIII
~40qe McCormick-Barger/mab 05/07/86 RIII
~C-(p_,~
Ring Sincerely, Charles W. Hehl, Chief Operations Branch RIII
..:rfS Suermann,bap
,-11 (see RIII
/s/
Hehl
Consumers Power Company Distribution cc w/enclosure:
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 2
MAY 0 7 1986