ML18053A392

Responds to NRC 880422 Ltr Re Violations Noted in Insp Rept 50-255/88-08.Corrective Actions:Interpretation of Facility Tech Specs Written That Identified Opening of Containment Valve During Power Operations to Be Consistent W/Ce STS

ML18053A392
Person / Time
Site:	Palisades
Issue date:	05/23/1988
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TASK-06-04, TASK-6-4, TASK-RR NUDOCS 8805310032
Download: ML18053A392 (5)

Text

consumers

• Power PllWERINli ll/llCHl&AN'S PROliRESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 Kenneth W Berry Director Nuclear Licensing May 23, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

RESPONSE TO INSPECTION REPORT 88-008 NRG Inspection Report 88-008 dated April 22, 1988 transmitted two Notices of Violation and requested a written response.

The violation identified as Item 1 pertains to containment penetration 33 and failure to identify its current classification and usage as an unreviewed safety question. Item 2 is in regard to the failure to comply with Technical Specification 6.8.1.c during performance of Technical Specification Surveillance Procedure MI-39.

Consumers Power Company's responses to these violations are as follows:

ITEM 1 Violation (50-255/88008-01 (DPR))

10 CFR 50.59 requires that a safety evaluation be performed for changes made in the facility as described in the FSAR and that the bases be documented for the determination that the change does not involve an unreviewed safety question (URSQ). Otherwise, prior Commission approval is required.

Contrary to the above, iri 1982 the licensee identified a discrepancy between the FSAR description of containment penetration 33 and the existing method of satisfying a Technical Specification (TS) Surveillance requirement and did not identify the issue as an URSQ. Subsequent intentions to modify the penet-ration or submit a TS change request were dropped without proper review.

Corrective Action Taken and Results Achieved The final evaluation of SEP Topic VI-4, NRC letter dated February 8, 1982, specified that these valves were classified as C3 and noted that the valve arrangements differed from the requirements of GDC 56 in that one valve should be located inside containment. A Request for Modification to install a 2" automatic isolation valve for containment penetration 33 was initially OC0588-0017A-NL02 8805310032 880523 PDR ADOCK 05000255 Q DCD

Pali'sades Plant 2 Reponse to Inspection Report 88-008 May 23, 1988

• prepared on January 6, 1982. The request identified that an automatic valve was required by the FSAR since the valves needed to be opened during power operation for flushing and sampling. The original FSAR specified that Class C3 penetrations, "are never opened during power operation." Instal-lation of an automatic valve would have changed the classification of penet-ration 33 from Class C3 to Class C2. The FSAR permits opening of Class C2 penetrations during power operations. Completion of the modification would have eliminated the unreviewed safety question associated with the opening of a C3 penetration during power operation and, therefore, would have been consistent with the FSAR requirements.

Concurrent with the proposed modification, an interpretation of the Palisades Technical Specifications was written that identified the opening of a contain-ment valve during power operations to be consistent with the CE Standard Technical Specifications (STS). The STS permit the opening of containment isolation valves on "an intermittent basis under administrative control." The administrative controls were specified in a letter to the NRC dated June 2, 1982. The letter also committed Consumers Power Company to submit a change to the Palisades Technical Specifications that would specifically resolve the issue. This change request was never submitted to the NRC. Completion of the Technical Specification Change Request (TSCR) would have required a safety evaluation to be performed. The safety evaluation would have been required to address the necessity to open a manual Class C3 penetration during power operation in order to justify the TSCR. Submittal of the TSCR, therefore, would have eliminated a failure to determine whether or not an unreviewed safety question existed.

Although the inspection report identifies this issue to be an URSQ, the internal 10CFR50.59 review, i.e., Safety Evaluation (SE) which was written to address the opening of certain manual isolation valves during power operation, concludes this issue not to be an URSQ. This conclusion is reached because first, the system in question is not coupled directly to the primary coolant system, second, the SE requires that administrative controls are in place to assure that the operator remains at the valve during the flushing and sampling process until the isolation valve is returned to its closed position and third, the valve only effects Safety Injection Tank Level and low level of this tank has been previously reviewed during issuance of a one-hour LCO in the Palisades Technical Specifications.

Corrective Actions To Be Taken To Avoid Further Non-Compliance A TSCR has subsequently been determined as the preferred corrective action.

In order for the TSCR to receive prompt reviews and NRC acceptance, the TSCR will address and resolve applicable STS requirements. This includes the incorporation of a Containment Isolation Valve Specification in the Palisades TS. An isolation valve table will be included in either the Palisades TS or by reference to the FSAR. Changes to FSAR, Section 5.1.6.9, will also be accom-plished.

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Palisades Plant 3 Reponse to Inspection Report 88-008 May 23, 1988 Failure to track Consumers Power Company's commitment to the NRC (ie, failure to submit a TSCR following the June 2, 1982 submittal) was the root cause of this event. Commitments at that time were normally tracked by the General Office Nuclear Licensing Department (NLD) via an Action Item Record (AIR) as no formal commitment tracking system existed. However, an AIR was not initiated and therefore, the commitment was not tracked.

Presently, commitments are tracked by NLD via the Correspondence Logging &

Commitment Tracking System (CLCTS). Commitments made in letters to the NRC are identified by NLD and summarized on a Record Summary Sheet. An indepen-dent review of the submittal is then performed to assure all commitments are identified and logged into the CLCTS. The existing commitment tracking system provides assurance that NRC commitments are no longer lost or forgotten.

Date When Full Compliance Will Be Achieved A TSCR that addresses the Limiting Condition for Operations, Applicability, Action Statement and Surveillance Requirements of Section 3/4.6.4 of the CE-STS will be prepared and submitted by September 1988.

Changes to the Palisades' FSAR, Section 5.1.6.9 will be incorporated in the next Palisades FSAR update following the TSCR submittal.

ITEM 2 Violation (50-255/88001-02 (DPR))

Technical Specification 6.8.1.c requires that surveillance and test activities of safety-related equipment be implemented and maintained. Surveillance Procedure MI-39 tests the auxiliary feedwater actuation system (AFAS) logic in accordance with Technical Specification 4.1.3.16.

Contrary to the above, I&C technicians performing Technical Specification Surveillance MI-39 on April 4, 1988 did not implement the procedure when they did not obtain the required logic channel trip indications due to incorrect test performance and yet they signed the data sheet believing they had properly completed the surve~llance test.

Corrective Actions Taken And Results Achieved The failure by the I&C technicians to verify the required AFAS logic channel trip indications were obtained has been attributed to several contributing factors as identified below:

1. The guidance provided in TS Surveillance Procedure MI-39 and existing component labeling on auxiliary feedwater actuation panel, EC-187 are not wholly congruent to assure consistent satisfactory test performance.

2. The I&C on-the-job training program does not specifically address MI-39.

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Palisades Plant 4 Reponse to Inspection Report 88-008 May 23, 1988

• 3. A lack of attention to detail by the technicians performing the test was a factor. Adequate attention.to indication light response would have revealed that an improper test button was depressed.

During the performance of the surveillance test, the I&C technicians signed-off portions of MI-39 in good faith, believing indications received were those required. Only after the NRC Senior Resident Inspector inquired as to the validity of the received indications, did the I&C technicians question the response. The technicians then called an I&C engineer to the AFAS panel who clarified existing confusion by identifying the correct test circuitry.

The auxiliary feedwater actuation panel has been relabeled to provide enhanced continuity with MI-39. Until further corrective measures can be taken to eliminate confusion associated with performance of MI-39, appropriate I&C supervision or direct second party overview will be required.

In order to assure training provided to I&C technicians will result in profi-cient TS surveillance performance, a QA Surveillance and Human Performance Evaluation of the I&C TS surveillances training program was initiated. The QA surveillance completed on May 6, 1988 did not indicate that major changes are warranted at this time. However, the surveillance did recommend the use of post-training (ie, approximately two months) evaluations to further verify training effectiveness. To date the Human Performance Evaluation has not been completed. Recommendations from both independent reviews will be evaluated by Plant management and appropriate actions taken.

Corrective Actions To Be Taken To Avoid Further Non-Compliance As stated above, the AFAS panel has been relabeled. TS Surveillance Procedure MI-39 is currently in the final stages of revision and is expected to be issued by June 15, 1988. The combination of both these efforts should eliminate a large portion of existing technician confusion during MI-39 performance.

Surveillance Procedure Ml-39 is being included within existing I&C Department surveillance test training. By inputting MI-39 into the training program, specific emphasis will be placed on procedural steps and necessary procedure limitations and responses. Recommendations derived from both the QA Sur-veillance and Human Performance Evaluation will be evaluated by Plant management and appropriate actions taken. Any generic issues identified will be evaluated for implementation in regard to other TS Surveillance Procedures.

Date When Full Compliance Will Be Achieved The revision of MI-39 will be completed by June 15, 1988. The Human Perfor-mance Evaluation of the I&C surveillance test training program will be completed by July 1, 1988.

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- Palisades Plant 5 Reponse to Inspection Report 88-008 May 23, 1988 A date will be established later for implementation of recommendations derived from the independent reviews in progress. Timely action will be taken for those measures deemed appropriate by Plant management.

Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades OC0588-0017A-NL02