ML18053A478
| ML18053A478 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/29/1988 |
| From: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 8808120063 | |
| Download: ML18053A478 (3) | |
See also: IR 05000255/1988008
Text
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Docket No. 50-255
- Consumers Power Company
ATTN:
David P. Hoffman
Vice President
Nuclear Operations
212 West Michigan Avenue
Jackson, MI
49201
Gentlemen:
JUL 2 9 1988
NRC Inspection Report No.88-008 dated April 22, 1988 transmitted two Notices
of Violation and requested a written response.
Consumers Power Company
responded to these violations by letter dated May 23, 1988.
Violation l
pertains to containment penetration 33 and the failure to identify the conflict
between the FSAR classification and actual use as an unreviewed safety question
(URSQ).
V1olation 2 regards the performance of a surveillance test that was
improperly executed.
Several concerns and inadequacies with your response and corrective actions
were identified during the review of your response.
Our primary concern is
the appearance of the inability to conduct an adequate 10 CFR 50.59 evaluation.
These issues are enumerated in the attachment to this letter and it is requested
pursuant to 10 CFR 2.201 that you respond in writing within 30 days of the
date of this letter.
Sincerely,
63 960729
asoa1200
05000255
ADOC~
PNU
( Y!Odwf-G~irector
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Division of Reactor Project
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Attachment: Comments and
Questions on Violations 1 & 2
cc w/attachment:
Mr. Kenneth W. Berry, Director
Nuclear Licensing
Gerald B. Slade, General Manager
DCD/DCB (RIDS)
Licensing Fee Managemen~ Branch
Resident Inspector, RIII
Ronald Callen, Michigan
Public Service Commission
Michigan Department of
Public Health
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Violation 1
1.
In the section titled
11 Corrective Actions Taken and Results Achieved
11 of
you~ response to Inspection Report No. 88008 dated May 23, 1988, no
explanation is given relating to:
1) the cause for dropping, without
proper review, the proposed modification of January 6, 1982, which had
been initiated to resolve the conflict between FSAR commitments and
operational requirements; 2) why both the Safety Evaluation (SE) completed
at the time of the proposed modification and the revised SE completed on
March 13, 1988, failed to identify the issue as an Unresolved Safety
Question (URSQ).
2.
In the same section of your response, the reasoning used to determine that
an URSQ does not exist are both faulty and inaccurate.
rirst, the system
in question, though not directly connected to the primary coolant system
(PCS) as pointed out in your response, does not preclude the application
of 10 CFR 50, Appendix A design criteria to the penetration.
The level of
commitment to containment design criteria is not evident and further, it
is not clear given the leakage history of certain check valves, that this
line should be considered not connected to the PCS.* Second, administrative
controls are not
11 in place
11 that would require an operator to "remain at
the valve during flushing and sampling.
11
Third, the approval of only a
one hour LCO for a Safety Injection Tank operability indicated the high
significance placed on its safety function and does not indicate that the
NRC had reviewed the containment isolation aspect.
3.
Other concerns have also resulted from a critique of your 10 CFR 50.59
review and associated safety evaluation completed on the same date as the
response in question and which concluded that an URSQ does not exist.
a.
In the discussion of the first possible scenario (Item 2 of the SE)
where the operability of the Safety Injection Tank (SIT) system is
evaluated for consequences of an accident, the conclusion appears to
be based on subjective reasoning instead of quantitative analysis or
calculations.
b.
Several questions ne~d to be addressed relating to the discussion of
the second possible accident scenario (Item 2 of the SE) and in the
evaluation of the operability of the containment system.
(1) It is argued that postulating the failure of the presumably
unprotected drain line is not probable and no mention is made as
to how this event would relate to the design criteria to which
Palisades is committed.
(2)
In lieu of an evaluation on the impact on 10 CFR 100 limits, a
PRA analysis (which has neither been reviewed nor approved by
the NRC) is u~ed to argue that since containment is postulated
to fail early in the PRA analysis, the failure of this
penetration would have no effect on offsite dose, when in
reality, a two inch hole in containment provides a leakage
pathway far in excess of that allowed by the Palisades FSAR to
meet the 10 CFR 100 offsite dose limits.
1
- ;I
. '
(3)
. ..
The NRC has not and would likely not approve the continued use
of an operator not -located in ready access to the isolation
valves and dedicated to the purpose of valve closure.
(4) Standard Technical Specifications (TS) make provisions for
opening certain manual isolation valves under administrative
control, but only after review and approval by the NRC.
Although
approval after review may seem likely, it is inappropriate for
an SE to presume approval or acceptability of an unreviewed
safety question and render a conclusion that the issue is not
an URSQ.
(5)
The second and third paragraphs of Item 2 have conflicting
statements with respect to the size of the penetration (one inch
flow restriction, two inch hole).
c.
Item 4 of the SE pertaining to the consequences of a malfunction of
equipment addressed only the operability of the Safety Injection Tank,
but not the consequences of the failure of the containment isolation
valves to isolate containment.
d.
Item 6 again presumes the acceptability of manual operation.of the
isolation v~lves. It is not clear whether the operability of the
containment system was considered.
e.
Item 7 discusses the margin of safety as reduced, but not
significant.
The logic of Item 2 does not adequately explain how it
can be considered insignificant.
The SE further states that the
basis for the.TS is affected (requires a change), yet does not
identify the issue as an URSQ.
Violation 2
1.
Corrective actions include training on MI-39 but no commitment was made
as to who will be included nor was a completion date established.
2.
Pleise advise us as to the status and completion dates of actions on the
QA and HPE recommendations.
2