ML18054B083
| ML18054B083 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/03/1989 |
| From: | Masciantonio A Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| IEB-79-14, NUDOCS 8911090343 | |
| Download: ML18054B083 (12) | |
Text
November 3, 19
- t'ocket No. 50-255 LICENSEE:
Consumers Power Company FACILITY:
Palisades Plant
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NRC & LOCAL PDRs PD31 GRAY FILE JTHOMA AMASCIANTONIO ADEAGAZIO OGC EJORDAN NRC PARTICIPANTS ACRS(lO)
JC LIFFORD
SUBJECT:
SUMMARY
OF MEETING TO DISCUSS AS-BUilT DISCREPANCIES (TAC NO. 75155)
On October 30, 1989, representatives of Consumers Power Co (CPCo) met with NRC staff members to respond to certain findi~gs made by regional.inspectors during NRC Inspection 89024.
Attendees are shown on Enclosure 1.
During the inspection conducted at the Palisades Plant in August, September and October 1989, Region III inspectors identified a number of significant concerns relative to the adequacy of the licensee's response to IE Bulletin 79-14, "Seismic Analysis for As-Built Safety-Related Piping Systems" and the adequacy of the supporting engineering analysis.
The inspectors detailed numerous fundamental deficiencies and errors in the engineering analysis both in the assumptions made and subsequent calculations.
Numerous discrepancies were also discovered in the as-built configuration of pipe supports and hangers versus the documentation used in the analysis.
The inspectors reviewed packages for three systems and similar deficiencies were evident in all three systems.
In response to the inspection findings, Consumers Power Company provided its plan of action to correct the deficiencies.
The licensee repr~sentatives stated that they were aware that deficiencies exist but there are no operability issues.
The utility contends that they have uncovered the same problems which the NRC inspectors found and proposed a number of actions to be completed both prior to plant restart and post plant restart.
These were presented at the meeting and in a letter to the NRC Document Control Desk dated October 26, 1989.
(Enclosure 2)
The staff agreed to review and consider the limited proposal and inform the 1 i censee as to the adequacy and acceptability of the proposed actions.
PE/PD31: DRSP ~
AMASCIANTONIO 11/.3 /89 Armand S. Masciantonio, Project Engineer Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation
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Docket No. 50-255 LICENSEE:
FACILITY:
SUBJECT:
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 November 3, 19d9 Consumers Power Company Palisades Plant
SUMMARY
OF MEETING TO DISCUSS AS-BUILT DISCREPANCIES (TAC NO. 75155)
On October 30, 1989, representatives of Consumers Power Co (CPCo) met with NRC staff members to respond to c~rtain findings made by regional inspectors during NRC Inspection 89024.
Attendees are shown on Enclosure 1.
During the inspection conducted at the Palisades Plant in August, September and October 1989, Region III inspectors identified a number of significant concerns relative to the adequacy of the licensee's response to IE Bulletin 79-14, 11 Seismic Analysis for As-Built Safety-Related Piping Systems 11 and the adequacy of the supporting engineering analysis.
The inspectors detailed numerous fundamental deficiencies and errors in the engineering analysis both in the assumptions made and subsequent calculations.
Numerous discrepancies were also discovered in the as-built configuration of pipe supports and hangers versus the documentation used in the analysis.
The inspectors reviewed packages for three systems and similar deficiencies were evident in all three systems.
In response to the inspection findings, Consumers Power Company provided its plan of action to correct the deficiencies.
The licensee representatives stated that they were aware that deficiencies exist but there are no operability issues.
The utility contends t"hat they have uncovered the same problems which the NRC inspectors found and proposed a number of actions to be completed both prior to plant restart and post plant restart.
These were presented at the meeting and in a letter to the NRC Document Control Desk dated October 26, 1989.
(Enclosure 2)
The staff agreed to review and consider the limited proposal and inform the licensee as to the adequacy and acceptability of the proposed actions.
Armand S. Masciantonio, Project Engineer Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation
Mr. Kenneth W. Berry Consumers Power Company cc:
M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Conunission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Mr. Gerald B. Slade Plant General Manager Palisades Plant 27780 Blue Star Memorial Hwy.
Covert, Michigan 49043 Resident Inspector c/o U.S. Nuclear Regulatory Conmission Palisades Plant 27782 Blue Star Memorial Hwy.
Covert, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health P.O. Box 30035 Lansing, Michigan 48909
e £ n~los vrt. 1 MEETING ATTENDANCE DATE:
October 30, 1989 PLACE:
Rockville, Maryland UTILITY AND DOCKET NO:
Consumers Power Co. (Palisades Plant)
Docket No. 50-255
SUBJECT:
Discrepancies and corrective actions related to IE Bulletin 79-14 concerns.
NAME Ge!(.A<-i> SlA-O r
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Genetal Offi1;e~ 1945 West Parnell Ro.cl, Jackson. Ml 49201 * (617) 788-1636 October 26, 1989 Nuclear Regulatory Commission DocU111ent Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
~ALISADES PLANT !R 89024 - CORRECTIVE ACTIONS BEING TAKEN IN RESPONSE TO NRC INSPECTOR CONCERNS RELATIVE TO IE BULLETIN 79-14 Kenneth W Berry Di7tt1or f'iu"nr Lknlllftl NRC Inspection 89024, conducted at the Palisades Nuclear Plant during the periods of August 14-18, 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 ~ystemR 11 and to the adequacy of engineering analyses being ~ompleted by Consumers Pcnter Company in response to inspector concerns.
During the inspection, Consumers Power Company evaluated th* identif 1ed concerns and developed a list of actions deemed necessary to provide both near and lons term assurance that as-bui1t 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. 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 allowahles.
The analysis performed to represent structural loads on the main steam line yielded results which exceeded FSAll allovables by approximately 14 percent.
Alternate analyses performed using industry accepted coda cases yielded results which demnnRtrate the support system was within allowable FSAR loads.
However. a modification is being completed to re~tore margin to the Palisade~ FSAR requirements.
OC1089-0212-NL04
N~~1car R*5u1a~ory Comm£*e£_,.
. Palisades Nuclear Plant Response to Bulletin 79-14
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 vill 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.
Kenneth W Berry (Signed)
Kenneth W Berry Director, Nuclear Licensing CC Adminietrator, Region III, USNllC NRC Resident Inspector - Palisades Attachment OC1089-0212-NL04
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OC1089-0212-Nl04 ATTACHMENT Consumers Power Company Palisade& Plant Docket 50-255 Actions To Be Co=pleted In Response To Issues Identified By NRC Inepection 89024 October 26. 1989 2 Pages
- Com:mit1J1ents Made
- l.
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:
KAToner - Prior to plant startup
- a.
Main steam line supports (EB1-H32(S6Q) and EBl-H29(S30)
- b. Auxiliary feedwater line supports (EB10-R227.l) and EB10-R227,C)
- c.
LPSI hanger (HC3-R133,1)
- d. Auxiliary feedwater steam trap drain line (RB-41-l)
- 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.
KAToner - Prior to plant startup
- 3.
The services of an independent technical reviewer will be retained.
Thia reviewer will provide third-level technical oversight of all Consumers.
PO\\Ter Company initiated structural design-related analyses (including those completed in support of Item l) until such time that detailed structural analytical specifications are developed.
These epecifications will be designed to provide accurate, thorough and consistent analytical preparations and technical reviews within Consumers Power Company.
KAToner - Prior to plant startup
- 4.
A notice that IE Bulletin 79*14 records are not to be solely relied upon as design basis for structural analyses will be issued to Consumers Power Co~pany engineering personnel and placed within 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.
KAToner - Prior to plant startup 5,
Consumers Power Company will develop and seek NRC approval of an interim operating c~!terion similar to those approved at Prairie Island.
These criteria will be used to assure equipment operability, if cases where structural loads exceed FSAR code allowablee are identified during IE Bulletin 79-14 reverification.
KAToner - No date
- 6.
A reverification of IE Bulletin 79-14 records to assess overall program ac:cura.c:y and completeness within "stress packages" analyses and dra.w1ng 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 mitigatins the ef f ecte of design basis accidents for protecting the health and safety of the public, and to ALARA considerations during ch~ reverification process,
- 6.
(Contd)
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 ~~~rla r?ne~Am 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 baaed on the safety significance and the number of. findings resulting from the sample program, KAToner - See above dates
. 7, Detailed specifications for the conduct of design structural analyses and their technical review will be developed.
Spec1f1cat1one will be designed to assure analyses accuracy, thoroughness and consistency.
KAToner -
Response to Inspection Report 89-007 dated 8/10/89 Due Date 7/90.
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 etrUctural loads are potentially in excess of code allowableR.
As a minimum, re-analysis will be completed for:
a, Main steam line supports (EB1-H32(S6Q) and EB1-H29(S3Q)
- b. Audllary feedwater line supports (EB10-R227.1) And EB10-R227., C)
- c.
LPSI hanger (HC3-Rl33.l)
- 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 Rpecificatione 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 not to be solely relied upon as design basis for structural analyses will be issued to ConsU111ers Power Company engineering personnel and placed within IE Bulletin 79-14 records, This notice will further direct the analyst to conduct appropriate as-built walkdowne and re-analyses to confirm record accuracy.
Actions To Be Completed Post 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 overa11 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 vill be baaed on the role a particular ~ystam plays in mitigating the effects of design basis accidents for protecting the health and safety of the public, and to ALARA cone1deratione during the rev~r1f1cat1on process.
OC1089-0212-NL04
- 60'39~d 1~101 ** e
- e.
Preliminary reviews indicate an appropriate sample program would include:
a) high pressure safety injection, b) preasurizer power operated relief valves and c) auxiliary faed~ater. These systems assure that primary coolant system (PCS) inventory 1s maintained, PCS inventory can be borated to shutdovn 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 defin1~~ of the sample program content will be completed by December 1.
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 tha 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 analyaes and their technical review will be developed.
Specifications will be designed to assure analyses accuracy, thoroughness and consistency.
OC1089-0212-NL04