ML18064A424

Requests Addl Info Re Review of Plant IPE & Staff Det Rept on Plant

ML18064A424
Person / Time
Site:	Palisades
Issue date:	10/19/1994
From:	Gamberoni M Office of Nuclear Reactor Regulation
To:	Fenech R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 9410240102
Download: ML18064A424 (4)

Text

• t Mr. Robert A. Fenech Vice President, Nuclear Operations Consumers Power Company Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043 October 19, 1994

SUBJECT:

PALISADES PLANT - QUESTIONS ON ~ALISADES INDIVIDUAL PLANT EXAMINATION (IPE) SUBMITTAL

Dear Mr. Fenech:

Based on the on-going review of the Palisades IPE and the staff's diagnostic evaluation team (DET) report on the Palisades Nuclear Generating Facility, we require additional information and have prepared the attached list of supplemental questions.

The questions relate primarily to concerns identified by the DET as perceived inadequacies in your IPE.

Your August 11, 1994, submittal responding to the DET report indicated that you will resolve the !PE-related concer~s, presumably in the near future.

Please provide a response to the enclosed questions within 45 days of the date of this letter.

If you have any questions, please contact me at (301) 504-3024.

Sincerely, ORIGINAL SIGNED BY I

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Marsha Gamberoni, Project Manager Project Directorate 111-1 Division of Reactor Projects - Ill/IV Office of Nuclear Reactor Regulation

-Docket No. 50-255

Enclosure:

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Mr. Robert A. Fenech Consumers Power Company cc:

Mr. Thomas J. Palmisano Plant General Manager Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Mr. David W. Rogers Plant Safety and Licensing Director Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 U.S. Nuclear Regulatory Commission Resident Inspector Office Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3423 N. Logan Street P. 0. Box 30195 Lansing, Michigan 48909 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.

Washington DC 20037 Alora Davis Commitment Tracking System Coordinator Palisades Plant Consumers Power Company 27780 Blue Star Memorial Highway Covert, Michigan 49043-9530 April 1994

I.

2.

3.

4.

Supplemental Request for Additional Information Palisades Nuclear Power Plant Information Notice 89-54, "Potential Overpressurization of the CCW System," discussed a postulated accident scenario in which leakage of reactor coolant could occur into the CCW system via failure of the RCP heat exchanger. This scenario dominated the risk profile at another Combustion Engineering plant.

No mention of this accident scenario was made, however, in the Palisades IPE submittal. Please discuss the risk significance of this accident scenario and its disposition with respect to the Palisades plant.

NUREG-1424, "Safety Evaluation Report Related to the Full-Term Operating License for Palisades Nuclear Plant," dated November 1990, indicated that the results of Generic Letter 89-19, which relates to steam generator overfill, would be addressed in the Palisades IPE.

No mention of this issue, however, was made in the licensee's IPE submittal.

Please address the safety significance of the issues related to this Generic Letter, as discussed in NUREG-1424.

Section 2.3.2.3.3, Reduction of Reliance on Human Errors, of Rev. 1 of the IPE (July 22, 1994) (retitled, Determination of Important Recovery Actions, of Rev. 2 (October 6, 1994)) states that to reduce the reliance on operator actions following an initiating event, post-accident human errors that are performed outside the control room, and are either a backup to an automatic action or a bypass for a failed component, were not included in the preliminary quantification. These actions (backup to an automatic action or bypass for a failed component) are generally classified as recovery actions. It is not clear from the original IPE or Revision 1 to the IPE how non-recovery, proceduralized and non-procedural ized operator actions that are performed outside of the control room, and are needed for accident mitigation and safe shutdown of the plant, were identified and quantified. Please provide:

(1) A list of all credited operator actions (including proceduralized, non-proceduralized, and recovery) performed outside of the control room which are needed for accident mitigation and for safe shutdown of the plant, and; (2) A discussion on how these operator actions were identified and quantified.

Include sample task analyses for the more significant operator actions.

The original IPE submittal states that if a procedure offers precise and unambiguous guidance, then a basis exists for using a lower error probability. Further, the submittal states that actions that are emphasized in training are more likely to be successful, therefore, human error rates can be decreased. In contrast, however, poor procedures and training may result in increased human error rates.

In the request for additional information (April 14, 1994) the staff asked the licensee to indicate which operator actions were beneficially impacted by training and procedures, by what factor, and whether these factors were used globally or individually (HRA question 9). The licensee's response stated that no operator actions were affected and no factors were used.

However, a recent diagnostic evaluation team {OET) report identified "persistent problems with procedural adherence and poor quality procedures." Please discuss how the IPE/HRA reconciles itself with these later findings.

~.

5.

The IPE submittal does not provide enough detail to determine what diesel generator coping time is available, given the fuel in the day tank, in comparison with what is actually needed to mitigate severe accidents.

However, a recent staff report indicated that the day tank coping time is actually less than that originally estimated in the FSAR.

Discuss the impact on the IPE results of using the actual, as-built, diesel generator coping times instead of the FSAR-based values.

6.

As indicated in your response to Back-End (BE) Question 1 you indicated (July 22, 1994 transmittal) that a potential containment modification which would prevent core debris from entering into the containment sump appeared to be cost beneficial.

Please discuss your current implementation plans for this containment modification involving the blocking off of the drain lines between the containment cavity and the auxiliary building.