ML18054A825
| ML18054A825 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/28/1989 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A824 | List: |
| References | |
| 50-255-89-07, 50-255-89-7, NUDOCS 8907050310 | |
| Download: ML18054A825 (4) | |
Text
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NOTICE OF VIOLATION Consumers Power Company Palisades Nuclear Generating Plant Docket No. 50-255 License No. DPR-20 As a result of the inspection conducted on April 3 through May 5, 1989, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedures for NRC Enforcement Actions (1988), the following violations were identified:
- 1.
10 CFR 50, Appendix 8, Criteria~ III, as implemented by the Palisades Operations Quality Assurance Program requires, in part, that the design bases be correctly translated into specifications, drawings, procedures, and instructions;*that the design control measures provide for verifying or checking the adequacy of the design; and that design control measures be applied to the delineation of acceptance criteria for inspections and tests.
Contrary to the above, the following instances of inadequate design control were identified:
Failure to correctly translate the design bases into drawings, procedures and instructions.
- a.
Engineering Analysis No. EA-FC-789-07 contained multiple dimensional differences between the analysis model and the installation drawings.
- b.
Engineering Analysis No. EA-FC-789-07 contained multiple analytical errors including the wrong*center of gravity location for the new bypass valves, incorrect location of masses associated with existing flow elements and valves, and incorrect size and schedule of a portion of the existing pipe.
- c.
For Drawing No. MlOl, Sheet 5113, the size of the fillet 'welds was not specified and.the calculation performed by the welder was not documented or checked.
- d.
Engineering Analysis No. EA-T-FC722-501-0l used an incorrect value for the volume of gas in the Backup Nttrogen bottles. This caused a nonconservative pressure drop to be calculated.
- e.
Input into the ADLPIPE, Inc. (AOL) piping stress analy~is, contained in Facility Change No. FC-756, contained multiple dimensional differences from the as-built dimensions.
- f.
The as-built sketch used in the analysis for Facility Change No. FC-756 contained a nine inch dimensional error.
- g.
Pipe support drawings in Piping Support Calculation No. 03378 of Facility Change No. FC-756 did not adequately describe the required weld sizes.
8907050310 PDR ADOCK Q '
890628 05000255 PDC
Failure to adequately verify and check design.
- h.
The seismic stress calculation for Fadlity Change No. f:c*-731 assumed an incorrect center of gravity which was not identified during the checking process:
- i.
The calculation for bending stress in Facility Change No. FC-731 was incorrect.
This was not identified during the checking process.
- j.
Facility Change No. FC-567 did not address the impact of the increased load on the inverters, bypass regulators or the battery chargers.
- k.
Facility Change No. FC-760-02 contained an unverified assumption in that the assumption that the emergency lighting fixtures were rigid was never proven.
- 1.
Specification Change No.87-090 changed the Service Water (SW) leak detection setpoint from 75 gpm to 300 gpm without verifying what size of SW piping break in the containment air coolers would result in a 300 gpm delta-flow al.arm.
- m.
Specification Change No.87-163 added a series voltage regulating zener diode to the feed water flow transmitter instrument loop for transmitters No. FT 0701 and FT 0703 without specifying the required zener diode desig~ parameters.
- n.
Specification Change No.88-069 added a series voltage regulating zener diode to the Safety Injection Tank pressure transmitter instrument loops for transmitters No. PT 0363, 0367, 0369, and 0371 without specifying the required zener diode design param~ters.
- o.
Specification Change No.88-069 did not consider the effect of instrument loop loading on the power supply; as a result, the load adjustment resistor setting which matches impedance for maximum power transfer was.not specified or adjusted.
- p.
Specification Change No.88-102 installed a different model containment pressure transmitter for transmitter No. PT 1812 without performing a seismic analysis to determine the acceptability of installing the new transmitter on the old mounting.
Failure to adequately delineate acceptance criteria.
- q.
The acceptance criteria in test Procedure No. T-FC-722-501, Backup Nitrogen Supply test, did not account for the accuracy of the pressure gauge.
- r.
Specification Change No.87-163 added a series voltage regulating zener diode to the FW flow transmitter loop for transmitters No. FT
0701 and FT 0703 without specifying the measurement of the power supply, zener, and transmitter voltage as acceptance criteria to determine if the transmitter loop was operating within its design 1 imits.
- s.
Specification Change No.88-069 added a series voltage regulating.
zener diode to the Safety Injection Tank pressure transmitter loops for transmitters No. PT 0363, 0367, 0379, and 0371 without specifying the measurement of the power supply, zener, and the transmitter vo 1 tage as acceptance criteria to determine if the tr-ansmi tter 1 oop was operating within its design limits; and also did not specify acceptance criteria for determining the acceptability of changing the load adjustment resistor in the power supply.
This is a Severity Level IV violation (Supplement 1).
- 2.
10 CFR 50, Appendix B, Criterion X as implemented by the Palisades Operations Quality Assuranc~ Program requires, in part, that a program for inspection of activities affecting quality be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity and that examinations, measurements, or tests of materials or products processed be performed for each work operation where necessary to assure quality.
Contrary to the above:
- a.
For FC-789, the socket fillet welds were not verified to be in conformance with the size requirement given in Welding Specification Procedure No WPS-11.21, Revision 2.
- b.
For SC-89-72, the socket fillet welds were not verified to be in conformance with the size requirements given in Welding Specification WPS No. GT-8-8, Revision 5.
This is a Severity Level IV violation (Supplement 1).
- 3.
Technical Specification (TS) No. 3.1.8.1.a requires a Low Temperature Overpressure (LTOP) power operated relief valve (PORV) lift setting of <
310 psi a for T < 300°F and TS 3.1. 8.1. b requires a LTOP PORV 1 ift setfing of < 575 psia for T < 430°F.
c Contrary to the above, between August 9, 1988 and February 27, 1989, the PORV as-left setting exceeded the TS requirement on 17 occasions.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of 'the date of this Notice a written statement or explanation in reply, including for each violation:
(1) corrective.action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
Dated
,.LJ_J I<<~
Hubert J. Miller, Director ~
Division of Reactor Safety