ML18065A201

Forwards LER 95-008-01,suppl Rept,Describing Final Results of Evaluation Performed to Determine Safety Significance of Disabled Containment High Pressure Trip Function

ML18065A201
Person / Time
Site:	Palisades
Issue date:	10/20/1995
From:	Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18065A203	List: ML18065A201 ML18065A205
References
NUDOCS 9510300213
Download: ML18065A201 (3)

Text

October 20. 1995 U S Nuclear Regulatory Commission Document Control Desk Washington. DC 20555 DOCKET 50-255

• LICENSE DPR-20

• PALISADES PLANT LICENSEE EVENT REPORT 95-008 BYPASSED CONTAINMENT HIGH PRESSURE TRIPS ON REACTOR PROTECTION SYSTEM - SUPPLEMENTAL REPORT Licensee Event Report (LER) 95-008-01. Supplemental Report. is attached. This supplemental report describes the final results of the evaluation that was performed to determine the safety significance of the disabled containment high pressure trip function. This event was originally reported to the NRC per 10CFR50.73(a)(2)(v)(A). as a condition that alone could have prevented the fulfillment of *the safety function of a system that is needed to shutdown the reactor and maintain it in a safe shutdown condition.

SUMMARY

.OF COMMITMENTS This LER Supplemental Report revises several existing commitments from the

• initial LER ~ated August 28. 1995. The revisions are editorial in nature and resulted from the final processing of the Palisades corrective action document.

1. Provide enhancements to the Design Control Program by implementing the following changes:

a. Revise Admi ni strati ve Procedures (AP) 9. 44. "Design Document Control." AP 9.45. "Vendor Manual Control." and AP 10.44.

"Engineering Records Center Distribution and Control of Design Documents" to indicate vendor manuals and vendor drawings have not been maintained as living documents. Also. add a requirement to AP 10.44 to attach a notice of that condition to any second generation print issued by ERC which contains information obtained from a vendor document. manual or drawing.

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b. Revise Project Management Construction and Testing procedure 1-3.

"Project Team Organization and Responsibilities" to better describe roles. responsibilities. and requirements for team meetings.

c. Revise AP 9.03. "Facility Change." to add the requirement-to initiate condition reports when potentially generic or significant issues are discovered during Facility Change Project work and to eliminate the option of using an inexperienced Prime Design Reviewer. *

d. Revise AP 9.04. "Specification Changes." to add the requ1rement to initiate condition reports when potentially generic or significant issues are discovered during Specification Change Project work.

e. Provide quarterly continuing training to Engineering Support personnel using a case study methodology to include as a minimum:

testing program improvements. management expectations for testing and consultant/vendor scrutiny. and Industry Experience Report evaluations. *

2. Provide enhancements to the Test Contro1 Program by implementing the.

following changes:

a. Assign responsibility for review of all modification testing to Systems Engineering who will act as the testing authority.

Surveillance tests assigned to Systems Engineering shall meet the stanoards established by the testing authority.

b. Revise applicable Administrative Procedures to emphasize functional testing requirements and accountability for test adequacy and completeness. Ensure procedures include the

• expectation of 100% functional testing of anything changed or affected directly or indirectly by the work done for a project.

Include a description of overlapping when relying on multiple tests to meet requirements. *

3. Provide enhancements to the Industry Experience Program by implementing the following changes:

a. Re-evaluate the documented responses to similar Industry Experience Reports (IN) pertaining to inadequate circuit modifications and testing, IN-88-83. IN-92-65. and IN-93-38.

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b. Develop a plan to implement reviews to comply with NRC intended actions for the new (currently in draft) Generic Letter No. 95-XX "Testing of Safety-Related Logic Circuits" published on May 22.

1995 in the Federal Register.

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c. Implement a second level critical review and approval of Industry Experience evaluations by Systems Engineering. Re-emphasize the importance of management expectations for industry experience reviews.

Richard W. Smedley Licensing Manager CC Administrator. Region III. USNRC Palisades Project Manager. USNRC NRC Resident Inspector - Palisades Attachment