ML18064A815
| ML18064A815 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/19/1995 |
| From: | Haas K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9506290076 | |
| Download: ML18064A815 (10) | |
Text
.,
- consumers Power KurtM. Haas Plant Safety and Licensing Director POWERING MICHIGAN-S PllOGIUSS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 June 19, 1995 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT REPLY TO NOTICE OF VIOLATION - FIRE PROTECTION AND DESIGN CONTROL PROGRAMS NRC Inspection Report No. 50-255/95004(DRP) contained a Notice of Violation concerning the Fire Protection and Design Control Programs.
The Fire Protection Violation was presented in two parts.
The first (255/95004-0la) concerned the storage of materials in a stairwell and the second (255/95004-0lb) concerned the maintenance of portable fire extinguishers.
The Design Control Violation (255/95004-02(DRS)) concerned the failure to adequately consider the design basis temperature associated with auxiliary feedwater. contains the Consumers Power response to the storage of materials in the stairway; Attachment 2 contains the response to the maintenance of portable fire extinguishers; and Attachment 3 contains the response to the design engineering violation.
SUMMARY
OF COMMITMENTS This letter contains five new commitments as follows:
I.
Revise FPIP-7, "Fire Prevention Activities," to clarify and strengthen the requirements that allow exceptions.
- 2.
Relocate the construction fire extinguishers so they will be part of plant's fire extinguishers. This will put them under the control of the plant's Fire Protection Program.
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- 3.
- 4.
- 5.
Develop and conduct training for managers and superintendents on lessons learned in the implementation of the self-assessment process.
Revise the condensate storage tank low level alarm set-point to provide more margin for maintaining the 100,000 gallon technical specification limit.
Develop and train on a case study of the design control error in Engineering Support Continuing Training.
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Kurt M. Haas.
Plant Safety and Licensing Director cc Administrator, Region III, USNRC Project Manager, NRR, USNRC Resident Inspector, Palisades, USNRC Attachments 2
ATTACHMENT 1.
CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION STORAGE OF MATERIALS IN A STAIRWELL 255/95004-04a(DRS)
I Page
NRC VIOLATION REPLY TO NOTICE OF VIOLATION STORAGE OF MATERIALS IN A STAIRWELL 255/95004-04a(DRS)
Administrative Procedure 9.48, "Fire Protection Plan," Section 11.1, which is contained in the Fire Protection Program Report as described in the Updated Safety Analysis Report, Section 9.6.1.2, implements the requirements of Fire Protection Implementing Procedure FPIP-7, "Fire Prevention Activities." FPIP-7, Section 5.1, requires in part that stainiays sha77 be kept clear of storage at a77 times.
Contrary to the above, from October 20, 1994 through March 8, 1995 the bottom of the stainie77 leading to the safeguards rooms was being used as a storage area for various maintenance activities.(255/95004-04a(DRS))
CONSUMERS POWER COMPANY RESPONSE Reason for the Violation Consumers Power Company agrees with the violation.
The root cause is personnel failure to follow the procedures.
The Fire Protection personnel performed an evaluation, made a conscious decision to allow the activity (as is permitted by the procedure), but did not document the decision.
At no time did the storage of the materials in the stairwell constitute a hazard to the egress of personnel via the stairway from the Safeguards Rooms nor did it prevent access to Safeguards by the Fire Brigade.
The staging of materials in the stairwell did not significantly change the fire loading of the area.
Corrective Steps Taken and Results Achieved All scaffolding material was removed from the stairwell at the time of the inspection. A review of other areas of the plant was performed looking for other possible areas where undocumented exceptions to the procedures might exist. This review also included assuring a fire loading analysis was performed.
No other undocumented exceptions were identified.
Corrective Actions to be Taken to Avoid Further Noncompliance To avoid further violations, procedural changes will be made to FPIP-7 to clarify and strengthen the requirements that relate to exceptions.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION MAINTENANCE OF PORTABLE FIRE EXTINGUISHERS 255/95004-04b(DRS) 2 Pages
NRC VIOLATION REPLY TO NOTICE OF VIOLATION MAINTENANCE OF PORTABLE FIRE EXTINGUISHERS 255/95004-04b(DRS)
The National Fire Protection Association Standard 10, Section 4-4.1, which is implemented by the response to the BTP APCSP 9.5-1 and contained in the Fire Protection Program Report as described in the Updated Safety Analysis Report, Section 9.6.1.2, requires, in part, that annual maintenance be performed on all portable fire extinguishers.
Contrary to the above, from February 1991 through march 1995, 89 portable fire extinguishers maintained by the Project Management & Modifications Group for use by fire watches during the performance of hot work had not had the required annual maintenance.
(255/95004-04b(DRS})
CONSUMERS POWER COMPANY RESPONSE Reason for the Violation We agree with the violation as written by the NRC.
The root cause is the lack of adequate controls of fire extinguishers by the Project Management &
Modifications Group (PM&M).
This was compounded by the existence of separate programs for the inspection of fire extinguishers used by the plant and PM&M.
In addition, self-assessment missed opportunities to identify the lack of controls.
Corrective Steps Taken and Results Achieved The required annual maintenance was subsequently performed on these portable fire extinguishers and resulted in the replacement of six cartridges and the hydrostatic testing of two extinguishers.
In addition, one extinguisher was found to be missing at the time of the maintenance and subsequently determined to have been turned over to the Palisades Fire Protection Department to be recharged.
PM&M will use these fire ext i ngui she rs until corrective action can be completed to place all fire extinguishers in the plant's program.
A review was performed of contractors onsite that have the need to use fire extinguishers during the outage.
No fire extinguishers were found to be outside their inspection qualification periods.
Corrective Steps Taken to Avoid Further Violations Consumers Power Company is taking the following steps to avoid further violations:
I.
Relocate the construction fire extinguishers so they will be part of plant's fire extinguisher program.
This will put them under the control of the plant Fire Protection Program.
- 2.
Develop and conduct training for managers and superintendents on lessons learned in the implementation of the self-assessment process.
Pate When Full Compliance Will Be Achieved Full compliance has been achieved.
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- ATTACHMENT 3 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-255/95004(DRP)
DESIGN CONTROL ISSUES 2 Pages
NRC VIOLATION REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-255/95004(DRP}
DESIGN CONTROL ISSUES 10 CFR 50, Appendix 8, Criterion III, Design Control, requires in part that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in paragraph 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Also, design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews.
Contrary to the above, ca 1cu1 at ions EA-FC-954-02, "Low Pressure Suction Trip on the Auxiliary Feedpump - Setpoint Change," and EA-C-PAL-95-00538-01, "Incorporation of a Higher Auxiliary Feedwater Pump Low Suction Pressure Trip Setpoint into the T-2/T-81 Inventory Calculations Using the RETRAN Program", did not adequately consider the design basis condition for temperature.
These calculations were part of Facility Change (FC},
FC-954, "Change P-88 Control From CV-0521 to CV-0522A", which had been reviewed and was approved for installation on March 14, 1995. (255/95004-02(DRS))
CONSUMERS POWER COMPANY RESPONSE REASON FOR VIOLATION Consumers Power Company ag~ees with the violation.
The root cause is design engineering personnel failure to recognize the temperature assumption that was used in the conversion factor for pressure to feet in elevation and failure to assure that this temperature basis was also acceptable for use in another calculation.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED
- 1.
The 100,000 gallon inventory calculation (EA-C-PAL-95-0538-01} was revised to incorporate proper low suction pressure trip (LPST} level based on a tank temperature of 130°F.
The revised T-2 Low Level Alarm setpoint was also included.
The revised calculation confirmed that the error did not result in a Technical Specification violation due to auxiliary feedwater inventory.
- 2.
A memo was written and a face-to-face discussion was held with site design engineering personnel highlighting the dangers and consequences of utilizing equations or intermediate results from one analysis in another analysis-without understanding the assumptions inherent therein.
CORRECTIVE ACTIONS TO BE TAKEN I.
Revise T-2 Low Level Alarm Setpoint to provide more margin for maintaining the 100,000 gallon technical specification limit.
- 2.
Develop and train on a case study of this error in Engineering Support Continuing Training.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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