ML18057B467
| ML18057B467 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/09/1992 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9201150082 | |
| Download: ML18057B467 (7) | |
Text
consumers Power Palisades Nuclear Plant:
27780 Blue* Star Memorial Highway, *covert, Ml 49043 January 9, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 GB Slade General Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT - REPLY TO A NOTICE OF VIOLATION; NRC INSPECTION REPORT No.91-018 NRC Inspection Report 91-018, dated Nove~ber 26, 1991, documented the results
- of a routine safety inspection and included a Notice of Violation pertaining to the rendering of PS-0918 inoperable, which in turn rendered Component Cooling Water Pump P-52C inoperable. There subsequently was a failure to comply with the action statements within the time limits specified in Technical Specification 3.4.2.
In a telephon~ conversation between JLKuemin of CPCo and BLJorgensen, Region III Reactor Projects Section Chief, on December 23, 1991, Mr. Jorgensen granted an extension for the reply to NOV 91018-01 until January 9, 1992.
The Attachment provides the response to the violation..
As discussed i~ the Attachment, we disagree with the proposed ~iolation as stated. However, we have concluded that a violation did occur and, therefore, do not contest this Notic~ of Violation.
~/~--
Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment A CIJIS EJ\\/El?GY COMPANY If\\
~
I.
CONSUMERS POWER.COMPANY To the-best of my knowledge, information and belief, the contents of this submittal ~re truthful and complete.
. By~p~-en-t--~
. Nuclear Operations.
Sworn and subscribed* to before me this 8th day of January 1992.
[SEAL]
LeAnn Morse Notary Public
-.Van Buren County, Mic.higan My commission expires June 6, 1994
ATTACHMENT Consumers Powe~ Company Palisades Plant Docket 50-255 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 91018 January 9, 1991 4 Pages
I.
I
- i.
VIOLATION REPLY TO NOTICE OF VIOLATION INSPECTION REPO_RT 91018
- Palisades Final Safety Analysis Report, Section 9.3.2.3.3, "Component CQoling System Emergency Operatio*ns,,,_ describes low pump c/ischarge pressure as ah interlock required to automatica17y start Component Cooling Water Pump P-52C during accident conditions if the other pumps have not started.
Pressure switch PS-0918 provides this function.
Palisades Technical Specification 3.4;1 requires, in part, Component Cooling Water Pump P-52C sha17 be operable~ as sha77 a17 associated heat exchangers, valves, piping and interlocks required to function during accident conditions.*
This includes pressure switch. PS..:0918.*
Technical Specification 3.4.2 a17ows one component specified in Technical Specification 3;4.1 to be inoperable, but.restricts the duration to 10.5 days unless the reactor is -in cold shutdown; Contrary to the above, Pressure Switch PS-0918 was made inoperable on August 27, 1991, when electrical links were opened as part of a ground fault isolation, and it remained inoperable until September 12, 1991, a period of sixteen days.
Reason for the Violation On August 27, 19.91 the Preferred AC Bus trouble al arm,was received due to a ground fault.. The grounded circuit was determined to be on the_pr~ssure.
switch PS-0918 control wiring.
As an immediate ~ction, links were opened to isolate the fault. A work order and ~ corrective action document were prepared.
Hand switches for Component Cooling Water {CCW) pump P-52A and p..:52c were caution tagged regarding the defeating of the stand-by start feature. It was decided that, since the PS-0918 was inoperable-and out of service *and the affected pump hand switches were caution tagged, a temporary
. modification {TM) was not required. This determination wa*s based on Administrative Procedure 9.31, 11Temporary Modifications, 11 Section 2.1, which states t~at "Temporary alterations performed on plant equipment while it is inoperable are NOT considered temporary modifications...
11 This statement was*
interpreted to m~an that work on PS-0918 did not require a TM however, the effect on CCW pump operability* was not fully evaluated and documented.
Per Administrative Procedure* 5.01, the work order process includes a
- determination, by the Shi ft Supervisor (SS), whether or not equipment can be
~eleased for repair and if the removal from service to perform repairs places the plant in a limiting condition of operation {LCO).
With PS-0918 inoperable, the work order was considered adequate control. Again, however, it was the operability of the CCW pumps, without the stand-by start feature, that should have been.considered.
Beca*use a TM was not initiated, a. proper evaluation of the operability of the CCW pumps was not made via a 10 CFR 50.59 ev~luation. We consider this as the significance of the situation and disagree with the violati~n as st*ted.
However, we agree that a violation has occurred in that a temporary
- modific~tion remained i~ place without a proper eval~ation of operability*
being ~ade.. Th~ subsequent 10 CFR 50.Sg evaluation determined that the CCW
- pumps, P-52A and P-52C; were* operable.
The basis for this conc.lusion is discussed below.
The validity of the proposed violation, as stated, is dependent upon whether TechDical Specification 3.4.1.c requires operability of PS~0918. It is required to be operable if it is " *.. required to function during accident conditions...," per the specification. The Palisades staff determined, based on the accident analysis, that PS-0918 would not be required since no credit is taken in the analysis for the automatic start of P-52C~ The automatic start feature of the other pump powered from the 1-1 Diesel Generator, P--52A, would suffice; On the other hand, the p~oposed violation indicates that if P-52C is required operable by the Technical Specifications and FSAR **
Section 9.3.2.3.. 3 describes its operation in emergency ope~ations, then, regardless of whether credit was taken for it in the accident analysis, its.
associated equip~ent {e.g. PS-0918) must also be operable.
2 To determine operability ~equirements, the NRC insp~ctor reviewed the FSAR
- Section 9.3.2.3.3 entitled "Emergency Opera'tions" and determined that the description of P-52C operation contained therein constituted a commitment for,
system design and operability.
FSAR Section 9.3.2.3.3 states in part "The third pump [P-52C] is sequenced later but only starts if a low pump discharge pressure is present, indicating that the other pump~ h~ve not started." This describes the start permissive function of PS-0918.
The FSAR contains two different types of information. Through its discussions of accident analysis, design criteria, acceptance limits, etc., the FSAR
- provides a partial compilation of liceristng bases and formal commitments for the plant. The FSAR als~ includes considerable description or general design arid operating features to provide understanding of overall plant and system operation.
Most of this material is not part of the licensing bases, in that it does not represent design capabilities or features which are relied upon to prevent b~ mitigate accidents and protect the health and safety.of the public.
We believe that the FSAR discussion of the third. CCW pump starting is an example of descriptive information about an installed operating feature and does not represeht a feature required to prevent or ~itigate accidents; This interpretation is further supported by the following:
- J; In the same FSAR paragraph in which the statement regarding the third pump sfarting on low discharge pressure first appears, the text further states, "In the event of a DBA, one component cooling pump and... are required." This statement is affirmed later in FSAR
- Section 9-.3.3.1.1 which states, "For post-OBA operation, one pump can furnish 100% of the required capability for cooling the containment spray and safety injection recirculation water." These FSAR sections.
do not identify any conditioh in which the start of the third pump is required to mitigate the accident.
- 2.
The typical approach for an~lyzing accident scenarios assumes an initiating eventand then compounds the problem by imposing the most limiting single active failure and, in many cases, a loss of offsite
power.
For tho~e accidents which require CCW at Palisades, the most limiting single failure is usually a loss of one diesel generator.
3 The single failure of a diesel generator.coupled with a loss of offsite power would render either one or t~o CCW pumps* unavailable (dep~nding on which diesel is assumed to fail), but would have no
- effect on the pump(s) on the other diesel. Assuming a failure of one '
diesel generato~ or ~ne CCW pump as th~ single failure would still leave at least one other ~ump available for automatic starting, regardless of the status of PS-0918. The only sequentes that might rely on the start permissive function of PS-0918 would require two or more earlier failu-res coincident with a loss of offsite power.
This*
conditiQn is* outside the licensing basis for the plant.
.To reiterate, the violation states that FSAR Section 9.3.2.3.3* " *.. describes low pump discharge pressure as an interlock required to automatically start P-52C dufing accident conditi~ns if the other pumps have:not started," and, Technical Specification 3.4.1 requires P-52C to be operable as well as its
. a~sociated interlocks including PS-0918.
We believe that the proper*
interpretation is that PS-0918 was not an interlock required to function*
during accident conditions, therefore, Technical Specification 3.4.1.c was not violated. Although the automatic start.of P-52C, after the loss of both P-52A and P-52B, was disabled, the pump was still available via manual start.
Sine~
no credit is taken for automatic starting and operation of P-52C in the accident analysis and more than one single failuie would have to occur to render the CCW system safety function in6perable, P-52C remained oper~ble-*nd capable of fulfilling its normal and accident fun~tions.
The condition described in the proposed violation provides a good example of the need for plant personnel to be.sensitive to the letter of FSAR language and anticipate the potential for misunderstanding.
It also exemplifies the need to document the bases for deci~ions in situations that ~r~*not clear cut and to do so ih a timely fashion.
We belteve that ih.cases where an operability*determination is required several documents must be considered. These fnclude not only 10 CFR, the Technical Specifications and the FSAR, but also, in certain cases, other,
d~cketed information and documehted accident analys~s. The basis for
. including the accident analyses in rendering an operability determination is that the.detailed *analyses maY be needed to interpret the intent of-the FSAR discussions.
The accident analyses go into far greater detail regarding component and system capabilities and system interaction with.respect to analyzed accidents than does the FSAR.
Failure to take credit for accident analyses in making.an operability determination and relying solely on the info~mation provided in the FSA~ could result in misinterpretation of FSAR.
summaries both in non-conservative and conservative directions.
- A criticism of Palisades' staff actions in this NOV is that the FSAR was not r~viewed in helping to interpret the TS requirement that interlocks required to function during accident conditions must be operable.
We had instead reviewed the Technical Specifications and the accident analysis.
Had we fully reviewed the FSAR we would have more than likely ~ade the same operability determination because the concluding interpretation lies in the accident analysis details as to what equipment is requi~ed to function during accident conditions.
4
.The underlying issue of d~~tinguishirig FSAR descrfptions about*~e~igh features from licensing*bases can be a difficult one for Palisades and presumably other plants of the same vintage as well. *Much.of the information in the FSAR is..
. descript_ive and does not represent the capability which iS relied upon to prevent or mitigate accidents.
We recognize that additional improvements in * *
. FSAR content and clarity are warranted.
Initiatives already underway, such as*
- the Design Basis.Reconstitution portion of the Configuration Control Program are already addressing tMs recognized weakness.
-Cone 1 us ion A proper determination of the operabjlity of the CCW pumps was not made via a 10 CFR 50.59 evaluation.
We consider this to be the significance of the situati.on and disagree with the Violation as stated. However, we agree that a violation has occurred fn that a temporary.modification remained inplace without a proper evaluation of operability being made~
It is also our conclusion that. PS-0918 is not required by the Technical Specifications since it is not equipment that is required to function during accident conditions as determined by our interpretation of the FSAR and the -
atcident analysi~ assumptiohs.
Componerit Cooling Water Pump P-52C remained operable by virtue of its ability to be manually started, if necessary, had P-52A and P-52B become inoperable.
Failure of both P-52A and P-52B is a
- condition outside the plant's licensing basis.*
With respect to the proposed violation, as.stated, we are concerned that it * *
~oul d cr~ate a_ ~recedent for ~reel udi ng us~ of ~na lyses and other sources of
- information to interpret comm1 tments and 11 cens mg bases.
We are al so concerned that creating such a precedent could imply that the letter of the
- FSAR should prevail regardless of actual intent.
Corrective Action Taken and-Results Achieved The length of time taken to make an operability determination for PS-0918 was unnecessarily lon~. Subsequently, training was provided to members of Palisades Corrective Action Review Board (PCARB) regarding timely determinations of operability. This training was originally initiated as a*
result of corrective action related to the operability of Containment Spray Pump P-54C in response to IR 90017-01.
Corrective Action to Av6id Future Non~Compliance We intend tci use thi~ situation as a case study for discussion with Operations and management personnel to document bases for decision$ in a timely manner in situations that require explanatio~.
Date When Full Compliance will be Achieved Full compliance has been achieved.
.. '