ML18058A161
| ML18058A161 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/05/1992 |
| From: | Jeffrey Jacobson, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18058A159 | List: |
| References | |
| 50-255-91-26, NUDOCS 9202110222 | |
| Download: ML18058A161 (6) | |
See also: IR 05000255/1991026
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/91026(DRS)
Docket No. 50-255
License No. DPR-20
Licensee:
Consumers Power Company
1945 West Parnall Road
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant*
Inspection At:
Covert, MI
(November 20, 1991)
Meeting at Region III Office (January 16, 1992)
Inspection Conducted:
November 20, 1991 and January 16, 1992
Inspector: 7!11Ufftff:i f 6) J. J&cob.so~
J.
. Jacobs
Also participating in this inspection:
Approved
B. E. Holian, LPM, NRR
R. Devitto, or, RIII
By:~
M.:RiilglChief
Engineering Branch
Inspection Summary
-~/.;h~
Date
Inspection on November 20, 1991 and January 16, 1992 (Report No.
50-255/91026CDRS))
Areas Inspected:
Special unannounced inspection regarding the
completeness and accuracy of information provided to the NRC as
required by 10 CFR 50.9.
Samples of previous submittals and
current information provided to the NRC were reviewed.
Results:
Three historical samples of inaccurate information are
provided as background information and two current examples are
cited as a Severity Level IV violation of 10 CFR 50.9
requirements.
9202110222 920205
~DR ADOCK 05000255
DETAILS
1.
Persons Contacted
Consumers Power Company CCPCol
- P .* Donnelly, Safety and Licensing Director
- J. Kuemin, Licensing Administrator
K. Marbaugh, Performance Trending and Analysis Supervisor
G. Davis, Lead Engineer, Steam Generator Replacement
Project
R. Jenkins, Section Head, Civil, Structural Engineering
Bechtel Corporation (Bechtel)
G. Brown, Project Engineer
R. Parekj, Chief, Plant Design Engineer
Nuclear Regulatory Commission CNRCl
- J. Gavula, Reactor Inspector
- M. Ring, Chief, Engineering Branch
- E. Schweibinz, Senior Project Engineer
- Denotes those participating in the exit meeting conducted
on January 16, 1992.
2.
Review of Information Submitted to the Nuclear Regulatory
Commission
a.
Background
Two historic written responses regarding NRC
violations, and one letter to the Office of Nuclear
Reactor Regulation (NRR) regarding the use of an
alternative inspection technique, were reviewed for
accuracy of information as follows:
(1)
The licensee's response to violation 255/89024-01
(Example A.2) is discussed in Paragraph 2.d. of
NRC Inspection Report No. 50-255/90014.
As
discussed in this report, the licensee's response
dated April 12, 1990, stated on Page 8 of
Attachment 1 that the subject stress calculations
were currently in final review and would be
completed by April 30, 1990.
On May 2, 1990, the
licensee informed the NRC resident inspector that
the package was not complete and in fact, was not
in final review.
During the exit interview for
NRC Inspection Report No. 50-255/90014, the
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(2)
potential consequences of providing false
information was discussed.
Violation 255/89007-ld, written as an example of
inadequate design control, pertained to the
calculation of post modification test acceptance
criteria for several nitrogen backup systems.
The
acceptance criteria were used to verify the design
assumptions pertaining to system leakage and
volumetric usage for certain air operated valves.
In calculating the allowable test pressure drop in
the tank, an incorrect volume of the nitrogen tank
was used.
Instead of using the actual volume of
228 standard cubic feet (scf), a smaller "usable"
volume of 209 scf was used.
While the smaller
value is conservative in determining the number of
tanks required, it is nonconservative if used to
determine the allowable pressure drop for the post
modification test.
Since the initial volume
appears in the denominator of the pressure drop
equation, it is relatively simple to deduce that
the use of the smaller tank volume resulted in a
higher allowable drop in the test pressure.
In the licensee's August 10, 1989 response to the
NRC, CPCo gave three reasons why they did not
consider this as an example of a design control
violation.
They strongly maintained that the
pressure drop calculation was appropriate and
conservative.
The NRC reviewed the response and
concluded that the reasons given did not have any
technical merit and that the licensee had again
failed to recognize that they had disregarded
basic engineering principles regarding pressure
drops.
During a subsequent discussion with the NRC on
November 2, 1989, the licensee acknowledged that
the calculation was, in fact, incorrect and
nonconservative.
It was apparent that the
licensee's initial response was inadequate and
that efforts toward assuring the accuracy of the
information provided to the NRC were insufficient.
As a result of this discussion, the licensee
submitted an additional response with corrective
actions for the design control violation.
(3)
The NRC conducted an inspection (50-255/89026)
regarding the use of an alternative inspection
technique used in lieu of ASME Code required
hydrostatic pressure testing.
The details of this
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alternative inspection technique were specified in
the H.A.F.A. International, Inc., Topical Report
HAFA 135(P) (A).
This topical report was approved
by the NRC for licensing reference on November 7,
1985.
Contained within this topical report was a
requirement to perform an evaluation of the system
prior to application of the alternative technique.
A letter from CPCo to the NRC dated August 10,
1988, notified the NRC of CPCo's intent to utilize
the alternative technique on several plant
systems.
This letter further stated that the
appropriate evaluations, as required by Section IV
of the topical report, had been completed and were
available at the Palisades site.
During an inspection (50-255/89026), the NRC
inspector requested that the evaluations be made
available for review.
Further discussions
revealed that the evaluations were not available
at the site and in fact, had not been performed.
The licensee was cautioned that information
supplied to the NRC must be accurate and complete.
b.
Review of Current Submittals
(1)
During December 1990, while performing an NRC
inspection (50-255/90025) of the Steam Generator
Replacement Project (SGRP), an inspector
identified the application of inappropriate
seismic response spectra to the piping analysis.
On February 8, 1991, the licensee presented their
position during a meeting at NRC Headquarters and
concluded that the piping seismic analysis met the
FSAR criteria.
NRC inspection of the SGRP also identified several
examples of design control deficiencies which
ultimately led to additional inspection effort
(50-255/91202) and escalated enforcement action.
During the October 15, 1991 Enforcement Conference
held at the Region III office, the licensee again
presented their position on the NRC finding
concerning piping seismic analysis.
At this time,
information was presented which led the NRC to
believe that the licensee recognized early in the
project that the seismic calculation basis
described in the FSAR could not be met.
The apparent conflict of information prompted the
NRC to visit the site and conduct interviews of
individuals involved in this issue.
Due to the
3
potential of this information being considered a
material false statement, the NRC Office of
Investigations was asked to assist with the
interviews.
As a result of the interviews and reviews of
supporting documentation, the NRC inspectors
concluded that the apparent conflicting
information presented to the NRC was due to a CPCo
individual misinterpreting information provided by
Bechtel as indicating that early in the SGRP,
Bechtel had stated that the seismic calculation
basis described in the FSAR could not be met.
The inaccurate information presented to the NRC
regarding FSAR compliance for seismic analysis of
piping is considered an example of a violation of
10 CFR 50.9 (255/91026-0lA).
(2)
As a result of NRC Inspection Report No. 50-
255/91017, the licensee was issued violations for
operating the plant without containment spray pump
and high pressure safety injection pump
availability.
This inspection report documents
that on June 27, 1991, the NRC inspector was told
by shift supervision that when equipment is
returned to an operable status after breakers have
been racked out, the components are always start
tested.
The licensee replied to the NRC's Notice of
Violation in a letter dated December 9, 1991.
This reply stated that the racking out and in of
breakers and the removal and replacement of
closing coil and control power fuses was
considered routine and did not require start
testing of the components upon return to service.
This apparent conflict of information was brought
to the licensee's attention and resulted in a
revised reply dated December 13, 1991.
This reply
stated that the test starting of components
following the racking in of breakers or
replacement of fuses was not required by
procedures; however, instructions to test energize
equipment after racking in of breakers was posted
on the 2400v cubicle doors.
The inaccurate information presented to the NRC
regarding the licensee's practice of test starting
equipment upon racking in of breakers is
considered an example of a violation of 10 CFR
4
.
,
50.9 (255/91026-0lB).
Both of the examples cited above related to information
which was involved in escalated enforcement action and
as such, are considered to be of more than minor
significance.
3.
Exit Interview
The NRC inspectors met with the licensee representatives
(denoted in Paragraph 1) at the conclusion of the inspection
on January 16, 1992, as well as periodically during the
course of the inspection.
The inspectors summarized the
purpose and findings of the inspection.
The licensee
representatives acknowledged this information.
The
inspectors also discussed the likely informational content
of the inspection report with regard to documents or
processes reviewed during the inspection.
The licensee
representatives did not identify any such
documents/processes as proprietary .
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