ML18065B035
| ML18065B035 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/30/1996 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9611060230 | |
| Download: ML18065B035 (7) | |
Text
consumers Power *** **
POWERllWi MICHlliAll-S l'frtllillESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 October 30, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT Thomas C. Bordine Manager. Licensing REPLY TO NOTICE OF VIOLATION -.INADEQUATE DESIGN CONTROL FOR THE CONTROL ROOM HVAC SYSTEM NRC Inspection Report 50-255/96009 (DRS) contains a Notice of Violation for a Severity Level N violation. Attachment 1 contains our response to that Notice of Violation.
Consumers Power Company (CPCo) agrees with the violation as stated.
SUMMARY
OF COMMITMENTS This letter contains three n~w commitments and no revisions to existing commitments.
- 1.
Complete modification to automatically switch the Control Room Heating, Veritila~ior:i, Air Conditioning (HVAC) System to the.emergency mode..
A G<<S' ENERGY COMPANY
- 2.
Discuss the lessons learned with the Chemistry and Radiological Services Department and Administration Department by the end of November 1996.
- 3.
Before July 1, 1997, provide training for Engineering Support Personnel on the lessons learned from this event.
~cs;:~
Thomas C. Berdine Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment 2
CONSUMERS POWER COMPANY To the best of my knowledge, the contents of this letter, Reply to Notice of Violation -
Inadequate Design Control for the Control Room HVAC System, are truthful and complete.
By
-~,,..?___""'
Tho ~almiSanO Plant General Manager Sworn and subscribed to before me this V'O 11 day of ~
Alora M. Davis, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)
My commission expires August 26, 1999 1996.
ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 RESPONSE TO NOTICE OF VIOLATION -
INADEQUATE DESIGN CONTROL FOR THE CONTROL ROOM HVAC SYSTEM 3 Pages
REPLY TO NOTICE OF VIOLATION..
INADEQUATE DESIGN CONTROL FOR THE CONTROL ROOM HVAC SYSTEM NRC VIOLATION During an NRG inspection conducted from August 13, through September 12, 1996, a violation of NRG requirements was identified. In accordance with the "General
- Statement of Policy and Procedure for NRG Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR 50, Appendix B, Criterion 111, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory r~quirements 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, is 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.
Final Safety Analysis Report (FSAR) Section 9.8.1.4.c specifies that the centre!
room HVAC system is designed to limit the radiation exposure of control room personnel during any of the postulated design basis accidents within the guidelines of 10 CFR 50, Appendix A, General Design Criteria 19.
1 O CFR 50, Appendix A, General Design Criterion 19, states, in part, that adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation-exposure in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.
Contrary to the above, adequate design control was not provided for the control room HVAC system to ensure that the system's design basis was met.
Specifically, adequate radiation protection was not provided to permit access and occupancy of the control room under accident conditions to ensure that personnel radiation exposures would not exceed 5 rem whole body, or its equivalent.
This is a Severity Level IV violation (Supplement I).
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CONSUMERS POWERCOMPANY RESPONSE Consumers Power Company (CPCo) agrees the violation occurred as stated.
REASON FOR THE VIOLATION The reason for the violation was a failure to properly utilize the Palisades modification process. This failure led to our failure to properly select and calibrate the continuous air monitor (CAM) for the control room HVAC. The details of this occurrence have been previously provided in Licensee Event Report 96-011 dated August 29, 1996.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The Eberline Model AMS-3 CAM has been removed and replaced with an Eberline Model AMS-4 CAM, which was calibrated with an alarm setpoint which correlates to 1 E-5µCi/ml Xe-133. The AMS-4 has a sample head designed for noble gas detection.
Control Room personnel have been informed of the change and appropriate operator aids and the on-shift operator guidance document (Standing Order 62) have been revised. The NRC staff reviewed the placement of the AMS-4 CAM in Inspection Report 50-255/96009 and found it acceptable.
An evaluation was completed to determine the advisability of installing equipment to automatically switch the Control Room HVAC to the emergency mode. It determined.
that installing the modification to automatically switch to the emergency mode is desirable. We plan to complete the modification prior to the end of the 1998 refueling outage.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS A review of other Health Physics Portable Instruments was conducted to validate that there were no other instruments being utilized in a condition which is outside of their capabilities. This review confirmed there are no other instruments operating outside their capabilities.
We have also conducted a review of the current Temporary Modification Program controls to assess whether they would have prevented the improper installation of. the Model AMS-3 CAM. Our review determined that the current controls are adequate to prevent this type of event from occurring once the Temporary Modification program is invoked. In this regard, we have, by publicizing this event, again made the engineering staff aware of the importance of properly implementing the design control 2
pmcesses. Also, the lessons learned from this event were discussed with Managers of the Chemistry and Radiological Services Department and Administration Department, who are the non-engineering departments that can initiate plant modifications. In turn, they will have communicated these lessons learned and expectations to their staffs by the end of November 1996. We will also provide training to Engineering Support Personnel (ESP) on these lessons learned from this event during the second quarter of 1997.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED CPCo is now in full compliance.
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