ML18058A224
| ML18058A224 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/21/1992 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9202270377 | |
| Download: ML18058A224 (3) | |
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- MICHlliAN'S PRDliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 February 21, 1992 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
CONFIGURATION CONTROL PROJECT STATUS UPDATE GB Slade General Manager This letter provides an update of the status of the Palisades Plant Configuration Control Project (CCP).
During the two years since our last letter to you on this topic, the CCP has received two NRC inspections and has also been reviewed as part of the recent Electrical Distribution Safety Functional Inspection (EDSFI).
The CCP was initiated, in partial response to an NRC confirmatory action letter dated May 21, 1986, to address concerns with missing or inadequate Palisades Plant design information.
Consumers Power Company letters dated December 1, 1986 and January 28, 1987, provided a preliminary description of the project purpose, scope, and schedule. A detailed description of the project scope was provided to the NRC during an April 24, 1987 meeting.
The schedule has been amended by Consumers Power Company letters dated July 29, 1988, December 13, 1988, and January 23, 1990.
The CCP consists of three elements:
(1) reconstitution of the design bases for the plant systems considered, at that time, to be most important to plant safety; (2) validation or confirmation that each system, as designed, satisfies the design basis functional requirements for that system; and (3) verification and correction of certain plant design documentation.
Included as a part of each of the three elements is a discrepancy resolution process.
Each of these elements is discussed below.
DESIGN BASIS RECONSTITUTION This element of the CCP principally involves the development of approximately 33 "Design Basis Documents" (DBD) for the plant systems considered important to safe plant operation. Originally 13 systems were selected and, subsequently, the Control Room HVAC system was added.
Other design basis reconstruction has been scoped and implemented through the development of design guidelines which are topical in nature and not system oriented.
An example of a completed design guideline is Electrical Cable Separation and Routing.
9202270377 ___ 920221 PDR ADOCK 05000255
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PDR A CllllS ENERGY COMPANY
2 A DBD is a controlled document containing current configuration design basis information for a specific system, or portion of a system, which can assist the user in making changes to the design, maintenance or operation of the system without violating its design basis. A DBD is intended for use primarily by modification design engineers, plant system engineers and other personnel performing nuclear plant safety reviews.
The existence of the DBDs is expected to enhance the ability of these groups to establish accurate system design modification requirements and margins and to derive accurate conclusions when performing associated 10 CFR 50.59 safety evaluations.
As part of the design basis reconstitution process, historical design information and licensing information is reviewed to recover the design basis for the current system configuration. The system's design basis, as defined by Consumers Power Company, consists of system functional requirements, regulatory requirements, original design codes, and standards of record (unless clearly superseded by a regulatory commitment to a later code or standard).
During this reconstitution process, it is expected that certain design basis information will not be found due to the lack of documentation of the existing requirements at the time of original plant construction. It is the intent of the CCP to reconstitute missing critical "design bases" information as defined in 10 CFR 50.2. This includes, for example, information needed to establish the system functional requirements, or specific values of controlling parameters chosen as bounds for design.
It is not our intent, however, to reconstitute all "design" information (i.e., that information, such as calculations, used to establish that the chosen design configuration met the design basis). Missing design information (as opposed to design basis information) is only being reconstituted in special cases where it has been recognized that the design may be marginal and needs to be confirmed.
Otherwise, missing design information is being identified in the DBDs for future reconstitution if required to support design modifications.
As a result of completed work on the project, it has been determined that the design basis reconstitution element should be expanded to include additional DBDs for the Auxiliary Building Heating, Ventilation and Cooling Systems, and for Containment Isolation. Additional design guidelines, (such as for electrical and l&C isolation and for IEEE separation) have also been added to the scope.
The relative significance of these additional documents to the original scope documents has caused some adjustment of the priority of each DBD to assure the most important DBDs are being addressed first.
As of the date of this letter, 25 DBDs have been completed and six topical design guidelines have been issued. Completion of both the original scope and the additional scope is expected by December 1994.
SYSTEM DESIGN CONFIRMATION
' The second element of the CCP involves the confirmation of the system design basis for the thirteen plant systems.
The principal method for confirming the design basis is the Safety System Design Confirmation (SSDC) review.
The SSDC provides an independent evaluation of the selected system DBD(s) relative to design commitments, operating procedures, maintenance practices, and surveillance testing.
Interfaces between the selected system and other supporting and supported systems are reviewed, as well as selected plant practices which may affect system design.
3 The SSDC is conducted using a multi-discipline team of design experienced contractors working with Consumers Power Company personnel.
Representation from the plant staff is available as a resource to the SSDC Team from the System Engineering, Operations, and Maintenance organizations. The SSDC is performed as a combination of design and facility change documentation review, plant and procedure walkdowns, and interviews with plant and engineering personnel.
Emphasis of the SSDC is on the integration of functional design basis information into the operation and maintenance of the plant.
The SSDC is a four week review conducted over a five week s~an, two weeks of which are located at the Palisades Plant.
Fourteen SSDCs are currently planned covering the DBDs.
SSDCs are not presently planned for three DBDs addressing non-safety systems, or topical issues which are not system oriented. Eight SSDCs have been completed.
Conduct of the remaining SSDCs depends on the completion of the appropriate Design Basis Documents (DBDs).
Approximately three Safety System Design Confirmations will be completed during each of the remaining years.
The Safety System Design Confirmation element is progressing on schedule and is expected to be completed by December 1993.
DESIGN DOCUMENTATION VERIFICATION AND CORRECTION This element of CCP involves the verification and correction of selected design documentation including electrical wiring diagrams, circuit and raceway schedules, and selected engineering data fields in the plant equipment data base.
The scope of this element is essentially the same as that described in Consumers Power Company letter dated April 16, 1987, as well as the various meetings with NRC at which the Configuration Control Project scope and status were discussed.
The "Q-Classification" of previously unclassified components has been completed.
The remaining portions of this element are expected to be complete in 1992.
DISCREPANCY RESOLUTION Common throughout the CCP is the need to resolve the discrepancies identified by the three elements.
The resolution of these discrepancies includes a process to accumulate lists of the identified discrepancies and track them to technical resolution. Significant discrepancies are passed to the plant corrective action system to obtain the required operability and reportability reviews. This process has required more resources than originally anticipated and, as these resources have come from the CCP, production of some of the original scope work products has been extended.
~/1 Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment