ML18054A823
| ML18054A823 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/28/1989 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18054A824 | List: |
| References | |
| NUDOCS 8907050304 | |
| Download: ML18054A823 (3) | |
See also: IR 05000255/1989007
Text
JUN 2 8 1989
Docket No. 50-255
Consumers Power Company
ATTN: 'David P. Hoffman
Vice President
Nuclear Operations
1945 West Parnall Road
Jackson, MI
49201
Gentlemen:
This refers to the special team inspection conducted by Mr. Rolf A. Westberg
and oth~rs of this office on April 3 through May 5, 1989, of activities relatjve
to the design basis reconstitution portion of the Configurati6n Control Project
(CCP), to the technical adequacy of design changes and to inservice testing
(IST) of pumps and valves at the Palisades Nuclear Generating Plant authorized
by NRC Operating License No. DPR-20.and to the discussion of our findings with
Mr. R. D. Orosz 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 .
The inspection of design changes and IST produced evidence of program strengths
such as good design procedures; improved performance in pump and valve testing;
and competent, knowledgeable ,personnel.
However, the results of this inspection
indicated weaknesses relative to design control. Several examples of problems
noted were as follows:
0
0
Review of ten specification changes and *nine facility changes resulted in
nineteen examples of inadequate design control.
One specific example
involved the addition of zener diodes in the Safety Injection Tank pressure
transmitter power supply without fully analyzing the potential failure
modes and without checking diode output voltage after installation. In this
case, vendor recommended input voltage to downstream pressure transmitters
was actually exceeded.
Review of the Backup Nitrogen Supply modification indicated that the design
engineer specified an inappropriate weld.
Field personnel did not reject
the design and implemented their own interpretation of-weld requirements
instead of referring the matte~ to engineering for resolution. This
constitutes an unauthorized design change .
Consumers Power Company
2
JUN 2 8 1989
0
0
The FSAR was changed to take advantage of the stress intensification
factor (SIF) allowed by a later edition of the ASME Code;
howe~er, this
same later edition also increasectthe SIF for so-cket welde*d fittings which
was not incorporated into the FSAR.
By selectively using the code of
convenience, the SIF employed became less than unity which had the
potential of introducing non-conservatism into analyses in which it was
used.
The Engineering Design Change (EDC) form used on site to revise facility
changes does not list the calculations affected by the EDC; therefore, it
is uncertain if the technical reviewers have considered the effects of
the EDC on the original analyses. This may constitute an undocumented
engineering judgement.
Taken individually, the safety significance of the above weaknesses and the
violations in the body of the report is small.
However, when taken as a whole,
we are concerned that the problems may be generic. Another concern that stems
from several of these examples is that modifications being made under the
Palisades Specification Change process are not consistently receiving an
adequate level of attention.
Because of the large number of implementation deficiencies relative to design
control,. consideration was given by Region III to taking escalated enforcement
action for the violations in Appendix A.
However, these violations were
categorized at Severity Level IV because the violations had minor safety
significance and did not result in deficient hardware or impact equipment
operability.
The program strengths stated previously and your effective post-
modification testing program were also considered in determining that these
violations do not represent a broad programmatic breakdown in design control
warranting a Severity Level III violation.
The inspection of the CCP indicated that electrical design basis documents
(DBDs) are well organized and useful; however, the only mechanical DBD completed
to date was considered poorly organized and difficult to use.
During this inspection, certain of your activities appeared to be in violation
of NRC requirements, as specified in the enclosed Notice.
A written response
is required; however~ any corrective action taken should include but not be
limited to the specific examples presented by this report.
We also request
that you address in your response the specific examples of program weaknesses
stated previously and the unresolved items in the repor,t relative to welding
issues concerning Auxiliary Feedwater and Reactor Coolant System Cold Leg drain
valve modifications.
This letter also confirms our plans as discussed on June 27, 1989, between
Mr. R. N. Gardner of our staff and Mr. R. D. Orosz of your staff to conduct a
meeting on August 2, 1989, at the Region III office in Glen Ellyn, Illinois .
The meeting is to discuss your corrective actions relative to the violations
and other program weaknesses described in this report.
Consumers Power Company
3
JUN 2 81989
We will gladly discuss any questions you have concerning this -inspection.
Enclosures:
1.
2.
Inspection Report
No. 50-255/89007(DRS)
3.
Attachments
cc w/enclosures:
Mr. Kenneth W. Berry, Director
Nuclear Licensing
Gerald B. Slade, General Manager
DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
Ronald Callen, Mi£higan
Public Service Commission
Michigan Department of
Public Health
.
~~
Burgess
4.{ 7...3 / s-~
Sincerely,
Original signed by R. W. Cooper, II, (for)
Hubert J. Miller, Director
Division of Reactor Safety
RIII A
., fl /J-"'
Rn
Gardner
G~L-j~'\\