ML18058B749
| ML18058B749 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/30/1993 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CAL, NUDOCS 9304130004 | |
| Download: ML18058B749 (6) | |
Text
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consumers Power POWERINli NllCHlliAN'S PROliRESS
. Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert'. Ml 49043 March 30, 1993.
Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 GB Slade General Manager DOCKEr 50-255 - LICENSE DPR PALISADES PLANT - CONFIGURATION CONTROL PROJECT STATUS UPDATE.
This letter provides an update of the status of the Palisades Plant Configuration Control Project (CCP).
Since the last CCP update letter, dated February 21, 1992, the NRC has conducted one inspection (IR 92026, dated December 15, 1992); the inspection resulted in one violati.on related to controlling changes to protedures.
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.
Since that initial meeting, the schedule has been amended and the project status has been updated by Consumers Power Company via letters dated July 29, 1988, December 13, 1988, January 23, 1990, and February 21, 1992.
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
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satisfies the design basis~functional requirements for that system; and (3) verification and correctiQ~ 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.
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2 DESIGN BASIS RECONSTITUTION This element of the CCP principally involves the development of approximately forty Design Basis Documents {DBDs} for the plant systems considered important to safe plant operation. Originally thirteen 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.
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.
The original scope for Phase II DBD development (five mechanical, six nuclear steam supply system (NSSS), and all electrical DBDs) has been completed. This completes our commitment to the NRC.
A CCP Phase III has been approved by plant management for DBD development.
The scope includes an additional ten system DBDs and six new design topical reports.
The systems selected for Phase III DBDs were based on the safety and operational significance of the systems not covered by the original CCP scope.
Several of the Phase III topical activities have already been completed.
Auxiliary Building HVAC, Containment Air Coolers, and Hazardous Environment DBDs are planned for completion in 1993.
DBD development for the other Phase III systems is scheduled through 1996.
The attachment to this letter lists the status of the currently identified DBDs and topical reports.
SYSTEM DESIGN CONFIRMATION 3
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.
The SSDC is conducted using a multi-discipline team of design experienced contractors working with Consumers Power Company personnel. Representatjon 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 span, two weeks of which are located at the Palisades Plant.
A total of seventeen SSDCs are currently planned covering the Phase II and Phase III system DBDs.
SSDCs are not presently planned for four DBDs addressing non-safety systems, or topical issues which are not system oriented.
Eleven SSDCs have been completed.
The schedule for the conduct of the remaining SSDCs depends on the completion of the appropriate Design Basis Documents.
The original committed number of Safety System Design Confirmations are progressing on schedule and are expected to be completed by December 1993.
Five additional SSDCs to validate the Phase III DBDs are scheduled to be completed in 1996.
DESIGN DOCUMENTATION VERIFICATION AND CORRECTION
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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-Classiffcation" of previously unclassified components has been completed.
The remaining portions of this element are expected to be complete in 1993.
4 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, the schedule for production of some of the original scope work products has been extended.
~?~4 Gerald B Sladet?v General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment
PALISADES NUCLEAR PLANT DESIGN BASIS DOCUMENTS AND TOPICAL REPORTS STATUS I.
COMPLETED DBD's MECHANICAL DESIGN BASIS DOCUMENTS COMPONENT COOLING WATER SYSTEM (CCW)
SERVICE WATER SYSTEM (SWS)
AUXILIARY FEEDWATER SYSTEM (AFW)
CHEMICAL VOLUME CONTROL SYSTEM (CVC)
CONTROL ROOM HVAC NUCLEAR DESIGN BASIS DOCUMENTS LOW PRESSURE SAFETY INJECTION (LPSI)
HIGH PRESSURE SAFETY INJECTION (HPSI)
CONTAINMENT SPRAY SYSTEM (CSS)
PRIMARY COOLANT SYSTEM (PCS)
REACTOR PROTECTION SYSTEM (RPS)
~ONTROL ROD DRIVE SYSTEM (CRD)
PLANT INTERNAL ELECTRICAL DISTRIBUTION EXTERNAL POWER SUPPLY TRANSFORMER INSTRUMENT AC SYSTEM 4160V SYSTEM 2400V SYSTEM 480V SYSTEM CRD POWER SUPPLY SYSTEM PRESSURIZER HEATER EMERGENCY POWER EMERGENCY LIGHTING SYSTEM DC & PREFERRED AC CIRCUITS STATION BATTERIES 125V DC SYSTEM (SAFETY-RELATED)
PREFERRED AC SYSTEM UNINTERRUPTIBLE POWER SUPPLY DIESEL GENERATOR DESIGN BASIS DOCUMENT
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DIESEL ENGINE ANO....AUXILIARY SYSTEMS GENERATOR AND GENERATOR PROTECTIVE SYSTEMS EMERGENCY DIESEL GENERATOR PERFORMANCE CRITERIA LOAD SHED CIRCUITS OBA AND SHUTDOWN SEQUENCER EMERGENCY GENERATOR AND AUXILIARY CONTROL AND MONITORING SYSTEMS ICDBDTOC.LM
_J OFFSITE POWER DESIGN BASIS DOCUMENT 345 kV SWITCHYARD TOPICAL REPORTS ELECTRICAL I&C ISOLATION INSTRUMENTATION ANP CONTROLS SEPARATION GRID INTERFACE CALCULATION CONTROL II.
DBD's CURRENTLY UNDER DEVELOPMENT MECHANICAL DESIGN BASIS DOCUMENTS AUXILIARY BUILDING HVAC NUCLEAR DESIGN BASIS DOCUMENTS
.CONTAINMENT AIR COOLERS (CAC)
TOPICAL REPORTS
. ELECTRICAL EQUIPMENT QUALIFICATION ELECTRICAL EQUIPMENT QUALIFICATION MASTER LIST FSAR CHAPTER 14 CALCULATION CONTROL III.
DBD's TO BE DEVELOPED MECHANICAL DESIGN BASIS DOCUMENTS SERVICE WATER INTAKE STRUCTURE INSTRUMENT AIR SYSTEM (CAS)
LIQUID *RADWASTE SOLID RADWASTE GASEOUS RADWASTE BIOLOGICAL SHIELD COOLING SYSTEM CONDENSOR/MAIN STEAM/FEEDWATER FIRE PROTECTION SYSTEM NUCLEAR DESIGN BASIS DOCUMENTS SPENT FUEL POOL COOLING TOPICAL REPORTS..
HELBA ELECTRICAL PENETRATIONS FLOODING AND DRAINS FREEZE PROTECTION AND HEAT TRACING ICDBDTOC.LM r