ML18054B064

Informs of Corrective Actions Being Taken in Response to NRC Inspector Concerns Re IE Bulletin 79-14, Seismic Analysis for As-Built Safety-Related Piping Sys. Mod Being Completed to Restore Margin to Facility FSAR Requirements

ML18054B064
Person / Time
Site:	Palisades
Issue date:	10/26/1989
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-79-14, NUDOCS 8911030052
Download: ML18054B064 (5)

Text

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• consumers Power Kenneth W Berry Dinctor l'DWERINli Niu:kar licensing MICHlliAN'S -l'RDliRESS Gene_ral Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 October 26, 1989 J -

Nuclear Regulatory Commission Document Control Desk_

Washington, DC 20555 DOCKET 50-255' - LICENSE DPR~20 - PALISADES PLANT -

PALISADES PLANT IR 89024 - CORRECTIVE ACTIONS BEING TAKEN IN RESPONSE TO NRC INSPECTOR CONCERNS RELATIVE TO IE BULLETIN 79-14 NRC Inspection 89024, c_onducted at the Palisades Nuclear Plant during the periods of August 14-1$, 1989, September 5-8, 1989 and October 16-20, 1989, identified concerns relative to the adequacy of actions taken in response to IE Bulletin 79-14, "Seismic Analysis For As-Built Safety-Related Piping Systems" and to the adequacy of engineering analyses being completed by Consumers Power

_Company in response to inspector concerns. During the inspection, Consumers Power Company evaluated the identified concerns and developed a list of actions deemed necessary to provide both near and long - term assurance that as_-built Plant configurations provide adequate structural strength to satisfy FSAR requirements. A preliminary action plan was presented to the NRC prior to the inspection exit meeting on October 20, 1989. Attachment l to this letter provides the formalized action plan that Consumers Power Company intends to follow.

To date, all completed re-analyses with the exception of one, have verified structural loads are within FSAR allowables. The analysis performed to represent structural loads on the main steam line yielded results which exceeded FSAR allowables by approximately 14 percent. Alternate analyses performed using industry accepted code cases yielded results which demonstrate the support system was within allowable FSAR loads. However, a modification is being completed to restore margin to the Palisades FSAR requirements.

8911030052 891026 PDR ADOCK 05000255 Q PDC OC1089-0212-:t:-n,04

• t Nuclear Regulatory Commission Palisades Nuclear Plant Response t6 Bulletin 79~14

• 2 October 26, 1989 The attached actions and results of completed analyses will be presented by

.consumers Power Company to NRC staff on October 30, 1989 at the NRC *office at One White Flint North and will be an integral part of our response to the pending inspection report. Additionally, details concerning the basis for the adequacy of the presented corrective action will be presented in our response.

Kenne~h W*Berry.

Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC1089-0212-NL04

ATTACHMENT Consumers Power Company Palisades Plant Do.cket 50-255 Actions To Be Complete~ In Response To Issues Identified By NRC Inspection 89024 October 26, 1989 2 Pages OC1089-0212-NL04

Actions To Be Completed Prior To Plant Startup

1. NRC observations will be prioritized in terms of potential safety signifi-cance and re-analysis will be completed for any conditions where calculated structural loads are potentially in excess of code allowables. As a minimum, re~analysis will be completed for:

a. Main steam line supports (EB1-H32(S6Q) and EB1-H29(S3Q)

b. Auxiliary feedwater line supports (EB10-R227.1) and EB10-R227.C)

c. LPSI hanger (HC3-R133.1)

d. Auxiliary feedwater steam trap drain line (HB-41-1)

2. As-built Plant conditions shown by re-analysis to. represent structural loads in excess of FSAR code allowables will be modified. Additional modifications may be completed in order to gain margin if structural loads marginally meet FSAR code allowables.

3. The services of an independent technical reviewer will be retained. This reviewer will provide third-level technical oversight of all Consumers Power Company initiated structural design-related analyses (including those completed in support of Item 1) until such time that detailed structural analytical specifications are developed. These specifications will be designed to provide accurate, thorough and consistent analytical preparations and technical reviews within Consumers Power Company.

4. A notice that IE Bulletin 79-14 records are nbt to be solely relied upon as design basis for structural analyses will be issued to Consumers Power Company.engineering personnel and placed withiri IE Bulletin 79-14 records.

This notice will further direct the analyst to conduct appropriate as-built walkdowns and re-analyses to confirm record accuracy.

Actions To Be Completed Pas~ Plant Startup

1. Consumers Power Company will develop and seek NRC approval of an interim operating criterion similar to those approved at Prairie Island. These criteria will be used to assure equipment operability, if cases where structural loads 'exceed FSAR code allowables are identified during IE Bulletin 79-14 reverification.

2. A reverification of IE Bulletin 79-14 records to assess overall program accuracy and completeness within "stress packages" analyses and drawing documentation will be conducted. Assessment of program adequacy will be initiated through a three system sample program. System selection will be based on the role a particular system plays in mitigating the effects of design basis accidents for protecting the health and safety of the public, and to ALARA considerations during the reverification process.

OC1089-0212-NL04

• 2 Preliminary reviews indicate an appropriate sample program would include: a) high pressure safety injection, b) pressurizer power operated relief valves and c) auxiliary feedwater. These systems assure that primary coolant system (PCS) inventory is maintained, PCS inventory can be borated to shutdown concentrations and that redundant mechanisms exist to remove heat. Selection of the power operated relief valves will additionally provide reconfirmation of recent structural analyses completed by Consumers Power Company engineering personnel.

Final definition of the sample program content will be completed by December 1, 1990. A completion schedule for the sample program reverifi-cation will be submitted to the NRC by January 10, 1990. Continuing reverification of IE Bulletin 79-14 program adequacy, beyond the sample program, will be based on the safety significance and the number of findings resulting from the sample program.

3. Detailed specifications for the conduct of design structural analyses and their technical review will be developed. Specifications will be designed to assure analyses accuracy, thoroughness and consistency.

OC1089-0212-NL04