ML18058B290
| ML18058B290 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/15/1992 |
| From: | Burgess B, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18058B285 | List: |
| References | |
| 50-255-92-26, NUDOCS 9212220040 | |
| Download: ML18058B290 (8) | |
See also: IR 05000255/1992026
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No.
50-255/92026(DRS)
Docket No.
50-255
Licensee:
Consumers Power Company
1945 West Parnall Road
Jackson, MI 49201
License No. DPR-20
Facility Name: *palisades Nuclear Generating Plant
Inspection At:
Palisades site, covert, MI 49043
Inspection Conducted:
November
.ft_fk--
23-24, 1992
Inspector:
/Isa Yi.!1/.
I
Approved By:
Bruce L.-Burgess Chief
Operational Programs Section
Inspection Summary
Inspection on November 23-24. 1992 (Report No. 50-255/92026CDRS))
Areas Inspected:
Routine, announced inspection of licensee
configuration control project (CCP) implementation, stat~s, and
- corrective actions.
Results:
The CCP was implemented in accordance with the
licensee's schedule.
The Writer's Guide for the Design Basis
Document incorporated all of the past concerns raised by the
inspector.
The inspection identified that some of the
significant, safety-related CCP findings were not evaluated in
a timely manner.
One violation was issued regarding a lack of
measures to ensure that changes to procedures are controlled and
of good quality (Paragraph 6.b).
9212220040 921215 -
ADDCK 05000255
G
1.
2.
3.
DETAILS
Persons Contacted
Consumers Power Company CCPl
R. D. Orosz, Nuclear Engineering and Construction Manager
T. J. Palmisano, Operations Manager
T. A. Buczwinski, Engineering Program Manager
P. M. Donnelly, Plant Safety and Licensing Director
J. Kuemin, Licensing Administrator
B. L. Harshe, Supervisory Engineer
R. A. Vincent, Plant Safety Engineering Administrator
J. Blewett, Project Engineer
V. A. Meineke, Staff Engineer
u. s. Nuclear Regulatory Commission
J. Heller, Senior Eesident Inspector
Introduction
This was the third inspection of CP's Configuration Control
Project (CCP).
The CCP which consisted of a Design Basis
Documentation (DBD) program and a Safety system Design
Confirmation (SSDC) program.
The first inspection was
conducted in March through May 1990, and the findings were
documented in Inspection Report (IR) 50-255/90010.
The
second inspection was conducted in April and May 1991, and
reported in IR 50-255/91010.
The purpose of these
inspections was to followup on the results of Consumer Power
Company's CCP program that resulted from the issuance of
CAL-RIII-86-002 on May 21, 1986.
The scope of this
inspection included a review of CCP completion status,
assessment of the program, and followup of the licensee's
corrective measures for the safety issues identified by the
CCP process.
CCP Scope and Implementation
Phase I
In 1986 the licensee responded to NRC concerns
raised during a safety system functional inspection
conducted on the high pressure safety injection system;
by
conducting an operational readiness review for the auxiliary
f eedwater system.
Evaluation and testing were extended to
other plant systems.
These activities were documented in a
Phase I Preliminary Assessment Report, dated August 12,
1987 *
2
Phase II
The scope was developed in 1987, and the work was scheduled
for completion before the end of 1992.
The status of the
DBDs and SSDCs was as follows:
~-~<,:i~- 111'.
Mechanical Systems
Component cooling water, service water and control room
HVAC were completed, and containment spray was
scheduled for completion in December, 1992.
Nuclear Steam Supply Systems
All CE supplied systems including the reactor coolant,
reactor protection, high pressure safety injection, low
pressure safety injection, control rod drive, and
chemical and volume control were completed.
Electrical Systems
All systems with Emergency Diesel Generator and DC
power supplies were completed.
With the exception of
emergency lighting and pressurizer heater emergency
power, all systems with AC power supplies were
completed.
The licensee also completed the 345 KV
The remaining AC power and a grid
stability study will be completed in December 1992.
Except for containment spray and control room HVAC,
scheduled for 1993, all SSDCs for Phase II work were
completed.
No SSDCs were planned for the 345 KV switchyard,
grid stability, and emergency lighting.
The SSDC for
pressurizer heater power was included in the ~400.V design
confirmation study.
The inspector concluded that the scope of the licensee's
review was extensive, and would meet the corporate
completion schedule discussed previously with the NRC
(second quarter of 1993).
Phase III
Phase III DBD development and SSDC reviews
included containment heat removal, electric and I&C
separation and isolation, auxiliary building HVAC, main
steam, feedwater, condensate, fire protection, radwaste, and
spent fuel cooling.
The work was scheduled and funded for
1993 to 1996.
3
4.
DBD Writer's Guide
During this inspection, the inspector reviewed the revised
procedure, "Writer's Guide for Preparation of system Design
Basis Documents," Revision 4, dated September 1992, and
determined that the licensee had appropriately addressed
previous NRC comments.
5.
Resolution of CCP Findings
a.
Significance of Finding
The licensee classified each CCP identified discrepancy
into three categories:
Category I for minor problems,
Category II for issues where additional information was
needed to determine significance, and Category III for
major problems.
Category III discrepancies were
addressed through the formal corrective action system.
In accordance with the licensee program, all
discrepancies were evaluated for operability concerns
prior to assigning a Category.
During the April 1990 NRC inspection, the inspector
observed a large number of Category !Is, and questioned
the licensee's timeliness for determining safety
significance.
During May 1991 inspection, the number
of Category !Is were significantly reduced.
During the
present inspection, the inspector identified 155 open
category !Is issued since June 1989.
The licensee
stated that they had developed and implemented an
evaluation system in February 1991.
This system was
based largely on engineering judgement to assess the
importance of all the category !Is as follows:
Priority I -
A design document that supported or
defined technical specification (TS) safety
limits, LCOs, limiting system setpoints or
surveillance requirements.
These documents
demonstrated that T.S. addressed system, structure
or component (SSC) performed their safety
function.~
Priority II - A design document that defined the
controlling parameters or provided support for
demonstrating the functionality of a SSC not
addressed in TS, but supports a system addressed
in TS, such as heating ventilation and air
conditioning (HVAC).
4
Priority III, IV, and V - Design documents for
SSC's with less importance.
The licensee records showed the following Priority I's,
and II's still open.
System Review and Revision
Rev. 1
eves
Rev. o
Rev. 0
Emergency Power Systems
DBD Rev. 0
Emergency Power Systems
Rev. 1
Station Power Systems
DBD Rev. 0
station Power systems
Rev. 1
2400 V AC
SSDC
Rev. 0
No. of Open Priority
I's and II's
3 !I's since April 1991
2 II's since October
1991
2 I's, and 1 II since
Sept. 1992
1 I since Feb. 1992,
and 4 !Is
since Oct. 1991
8 II's since July 1992
2 !I's since December
1990
1 II since May 1991
4 !I's since February
1991
A total of 28 I's and II's
The inspector again expressed a concern about the
timeliness of resolving potentially important safety
related CCP findings.
The licensee stated that their
present program allowed one year to address Priority Is
and !Is *. However, after-reviewing the data compiled by
the inspector, the licensee agreed that the s*i tuation
was unacceptable.
The licensee committed to revise
Administration Procedure 13.01 to require the
engineering staff, assigned to the CCP, to initiate
resolution for Priority Is and IIs shortly after
identification.
This measure would ensure that
Category II items could be re-classified to Category I
or III within a four to six month period.
b.
Licensee Closeout of Category III Discrepancies
There were 28 Category III discrepancies identified in
the CCP reviews.
Deviation Reports (DRs) were written
for all these findings and were forwarded to various
5
- P
licensee departments for resolution.
The inspector
observed that ten DRs remained open.
All ten open DRs
had multiple issues or parts, and were partially
resolved.
The inspector considered licensee control of
these DRs to be acceptable.
6.
Review of Licensee DR Closeouts
The inspector reviewed the following completed DRs issued as
a result of CCW DBD reviews and document compilation.
Each
DR was closed after engineering evaluation and corrective
action:
a.
D-PAL-91-084
The DR documented that component cooling water to high
pressure safety injection, low pressure safety
injection and containment spray pump seal cooling inlet
and discharge solenoid valve safety injection signal
(SIS) relays did not have proper physical separation
inside the main control room panels.
The issue was
identified in April 1991, and_ closed in May 1991.
The inspector reviewed the engineering evaluation to
accept the as found condition, and had no adverse
comments.
b.
D-PAL-89-032
The inspector's review of this DR identified that the
licensee's administrative procedures were not
sufficient to control facility changes based on DBD
results.
Chronology of Events:
l}
1970:
Licensee identified that the procured
component cooling water heat exchangers were
significantly under-sized.
2)
September 10. 1979:
TS amendment 51 section
3.3.2.d stated "One shutdown heat exchanger and
one component cooling water heat exchanger may be
inoperable for a period of no more -than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
3)
Pre-February 1989:
Standard Operating Procedure
(SOP} 16, for the component cooling water system
(CCW), allowed, during normal plant operation, one
CCW heat exchanger to be out of service for up to
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
6
4)
January 1989:
The DBD program confirmed that both
CCW heat exchangers were under-sized.
The DBD
concluded -
(1) both CCWHXs were needed during
power operations for primary system heat load
removal and (2) at system flow rates greater than
8000 gpm tube damage would occur due to flow
induced vibration (see IR 50-255/90010,
paragraph 4.c).
5)
January 1989:
DR issued on the subject
recommending that SOP-16 and Technical
Specifications be revised to require both CCWHSs
be inservice when reactor coolant is greater than
3250 F.
6)
January 1989:
SOP-16, revision 6 issued requiring
both CCWHSs to be in service with reactor coolant
temperature above 3250F.
7)
No Technical specification change was ever
proposed.
8)
November 1992:
SOP-16, revision 8 issued to
delete the requirement for both CCWHXs to be in
service above 3250F *
The licensee explained that the deletion of the
requirement in SOP-16 resulted from a Training
Department discovery in November 1991 that it
conflicted with TS 3.3.2.d.
The operations department,
after receiving the deviation report, discussed the
matter with the licensing department, but failed to
perform a detailed review of the CCW DBD and
communicate with the appropriate DBD engineer.
The
lack of technical information, and the fact that a
10 CFR 50.59 safety evaluation was not required for the
1989 SOP-16 revision contributed to the decision by the
licensee to delete the requirement.
The deletion of the CCWHX requirement from SOP-16
allowed the plant to be operated in accordance with the
Technical Specifications.
Operation of CCW per the
requirements of the Technical Specifications would
allow removal of one CCWHX for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
With
one CCWHX inservice at full power, the ccw system would
be configured in such a way that serious degradation or
damage would occur to the heat exchanger potentially
rendering ccw inoperable.
Based on review of this
event, it was evident that the licensee had not
established sufficient administrative measures to
control changes to procedures to maintain procedural
quality, including the results of DBD reviews.
7
10 CFR 50, Appendix B, Criterion VI, requires that
measures be established to control the issuance of
documents, such as instructions, procedures and
drawings, including changes, which prescribe all
actions affecting quality.
The failure of the licensee
to establish sufficient administrative controls to
ensure that changes to station operating procedures
(SOP-16) include the necessary actions to maintain
quality is considered a violation of 10 CFR 50,
Appendix B, Criterion VI.
7.
Exit Meeting
The inspector met with licensee representatives (denoted in
Paragraph 1) on November 24, 1992, at the site and
summarized the purpose, scope, and findings of the
inspection.
The inspector discussed likely informational
content of the inspection report with regard to documents or
processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents or
processes as proprietary .
8