ML18057B148
| ML18057B148 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/09/1991 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9107160339 | |
| Download: ML18057B148 (3) | |
Text
~tmsmners Power POW ERi Nii MICHlliAN'S PROliRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0453 July 9, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 David P Hoffman Vice President Nuclear Operations DOCKET 50-255 - LICENSE DPR PALISADES PLANT - MODIFICATION ENGINEERING INSPECTION FOLLOW UP ACTIONS An NRC Special Assessment Branch engineering team inspection was conducted at the Palisades Plant from June 10, 1991 through June 21, 1991.
During their inspection, the team reviewed various aspects of the plant's modification and engineering programs including the Steam Generator Replacement Project.
The team reviewed their inspection findings at an exit meeting held on Friday, June 21, 1991.
After reviewing the team's observations, we are proposing the following actions to improve the performance in the areas of modification engineering and engineering practices in general.
I.
FSAR REVISION The FSAR, sections 5.7 and 5.10, will be revised to clarify p1p1ng and pipe support design criteria and reduce ambiguity.
This revision will address design criteria such as faulted and test allowables.
It is expected that a draft FSAR revision will be available on or before July 19, 1991.
At that time we will transmit the draft revision for NRC Staff review. We have scheduled a working meeting with NRR for August 7, 1991, for discussions on the revision.
II.
SPECIFICATIONS C-173 AND M-195 UPGRADES Specifications C-173, "Technical requirements for the Analysis and Design of Safety Related Pipe Supports" and M-195, "Requirements for the Design and Analysis of Palisades Plant Safety Related Piping and Instrument Tubing," will be upgraded to reflect the FSAR revised criteria discussed in Item I, above.
A CIVlS ENERGY COMPANY 1/-oOI
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It is expected that rev1s1ons to C-173 and M-195 will be drafted by July 19, 1991 and implemented following review with the NRC.
III.
UMBRELLA DOCUMENT An umbrella document will be written and issued to tie specification and procedural requirements together. This document will be in commentary format and each individual within the Nuclear Engineering and Construction Organization (NECO) who performs piping and pipe support analyses will receive training to its content. Training will be completed by December 1, 1991.
IV.
ASSESSMENT OF PIPE AND PIPE SUPPORT ENGINEERING An assessment of pipe and pipe support engineering by a contractor commenced on June 3, 1991.
The purpose of this assessment is to:
- Identify design engineering strengths and weaknesses.
- Identify root causes of engineering design weaknesses.
- Suggest improvements to people, processes and equipment to address root causes of identified weaknesses.
Currently, the assessment is scheduled to be complete by July 31, 1991.
Upon receipt of the final report, an action plan and schedule will be developed for implementation of the assessment recommendations.
V.
CURRENT MODIFICATIONS Until such time as items I and II are completed, no safety related modifications involving piping and pipe support analyses will be implemented. Upon completion of the FSAR revision and revision to specifications C-173 and M-195, a third party review of all NECO initiated piping and pipe support analyses will be performed.
Analyses performed by contractors will receive an in-depth review by NECO engineering prior to implementation.
The third party review of NECO analyses will continue until the results of the contractor assessment are received and an action plan is developed and implemented.
Based on the action plan and schedule, a milestone will be established for termination of the third party review of NECO initiated pipe and pipe support analyses.
Exact timing of termination of third party review will be discussed with NRC staff at a later date.
VI.
MAIN STEAM LINE ANALYSIS As discussed during the NRC Special Assessment Branch engineering team inspection exit, the main steam line design will be reanalyzed after the FSAR and design specifications are revised.
Consumers Power will align with NRC staff on the details of the reanalysis during the August 7, 1991, meeting and expect to be able to complete the work by the end of November.
We will discuss all of the above mentioned proposed actions at our working meeting scheduled for August 7, 1991 with NRR.
t David P Ho fman Vice President Nuclear Operations CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades