ML20058A233
| ML20058A233 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/15/1990 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010250349 | |
| Download: ML20058A233 (3) | |
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i Consumers POW 8T o e si General Mannter nl6DilGAWS MEDGotE55 Peheodos Nucleet Plant 27700 Blue Star Memoral Hashwsy. Covert MI 49043 October 15, 1990 a
Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 l
DOCKET 50-255 - LICENSE OPR PALISADES PLANT -
1 RESPONSE TO INSPECTION REPORT 90018; NOTICE OF VIOLATION Nuclear Regulatory Commission (NRC) Inspection Report 90018,. dated September 3
14,'1990, documented the results of a routine safety inspection and resulted
'in issuance of a violation for failing to submit a Technical Specifications
. change request as a result of a modification made to the containment high pressure 1(CHP) circuits to include steam generator feedwater isolation'per-Facility Change-(FC) 906. The-following is Consumers Power Company's response m
to this violation.
Violation 50-255/90018-04 (DRP)
'10CFR50, Appendix B, Criterion V, as implemented by Palisades ' Operations-
. Quality-Assurance Program, requires' that activities affecting quality shall; be
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l accomplished in accordance with prescribed procedures.
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Contrary to the above, as required by Paragraph 5.2.5.d to Palisades.
Administrative -Procedure 3.07, " Safety _ Evaluations", a Technical. Specification-0 Change Request was not initiated when a modification was made to the.
l, containment high pressure circuits to include steam generators' feedwater j
T isolation per FC-906.
' Reason For Violation ntd For a number of_ years Palisades' design included an automatic closure of the n
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'881-feedwater regulati'ig and the associated bypass valves on steam generator-(S/G)-
_ low pressure.
In early 1990 it was found that this valve' closure was not oo always early_ enough in a Main Steam Line Break (MSLB) event to prevent exceeding'containnent. design pressure.
FC-906 was completed to add ;a L, go w containment high pressure closure signal to these valves to obtain earlier -
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closure for smaller steam line break sizes.
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The safety evaluation for the modification concluded that no Technical Specifications change would be reqcired because the new configuration would not conflict in any way with the existing Technical Specifications. While Technical Specifications Tables 3.16.1 and 3.17.3 address related functions, they do not address feedwater isolation at all, even though the valves already close on S/G low pressure. The setpoints for S/G low pressure and CHP are specified in the Technical Specifications and would not change for this modification.
Plant Administrative Procedure 3.07, " Safety Evaluations", addresses the Technical Specifications question broadly.
In determining whether a-safety evaluation is necessary, a safety review is conducted. As part of the safety.
review a question is posed, "Does the item require a change to the Technical Specifications?" Section 5.2.5.d of Administrative. Procedure 3.07 states that, " Proposed activities which result in direct or indirect conflicts (emphasis added) with Technical Specifications requirements shall be answered
'YES' on the safety review. A 'YES' answer will also be appropriate if Technical Specifications changes are desired (or required) to add new material which is not already present."
It.is clear that this. safety review question
' requires consideration of potential new Technical Specifications.
No additional guidance is given to specify when something should'or should not be added. This is left up to the judgement of the safety evaluation preparer and reviewer.
Discussion with the originator of the safety evaluation for which the violation was written revealed that Technical Specifications Tables 3.16.1 and 3.17.3 were explicitly considered during the preparation of the design and the safety evaluation.
It was concluded that no changes were needed for two reasons:- a) the valves already had a similar automatic closure which was not -
addressed by Technical Specifications, and b) the only valve closures
' addressed-in. detail were for containment isolation valves and.these feedwater valves were not containment isolation valves.
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'In conjunction with the evaluation of this violation, a number of' experienced
. individuals were surveyed with several related questions. The survey showed' that there.was a good understanding that Administrative Procedure.3.07 intends that desirable as well as required Technical Specifications changes be -
identified. However, there was not a consistent' understanding of what. factors
- need to'be considered when evaluating the need for new Technical Specificatitons.
Plant modification procedures were also reviewed as part of this evaluation.
The various procedures were-found to contain not only references to; Administrative Procedure 3.07 for safety evaluations but, also.contain prompts.
for designers and analysts to consider the impact on Technical Specifications-during the design or analysis process. They did not, however, emphasize the need to consider the addition of new Technical Specifications.
Corrective Actions Taken And Results Achieved TheLsafety evaluation for FC-906 was revised to int cate that a Technical Specifications change request should be initiated A Technical Specifications
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change request will be prepared to add operability and surveillance I
requirements for main feedwater isolation on S/G low pressure and containment high pressure.
This violation has been discussed with all Plant Safety and Licensing (PS&L) safety. evaluation reviewers. They have been sensitized to this issue and are now giving greater emphasis to the Technical Specifications questions as the safety evaluator. The Palisades Plant Administrative Procedure 3.07 requires
.j that as a normal' process a certified PS&L reviewer review all safety H
evaluations. A more stringent PS&L review should identify potential Technical Specifications changes during the interim period while better guidance is being developed for initiators of safety evaluations.:
.l Corrective Actions Taken To Avoid Future Non-Comoliance Guidance will be added to Administrative Procedure 3.07 and if necessary. 3.0C I
" Technical Specification-Changes" to better define that the intent is t' ~
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identify desirable Technical Specifications changes as well as required
. Technical-Specifications changes.
The prompts in Administrative Procedure 9.03, "Facilty Change" and 0.11
" Engineering Analysis" will be enhanced to highlight the need to identify new Technical Specifications during design and analysis,. or we will consider
-developing an engineering guideline which accomplishes the same intent.
Date When Full Como11ance Will-Be Achieved The Technical Specification-Change Request will be submitted to the NRC by J
November 15, 1990. Administrative Procedure 3 07 and if necessary, 3.06 revisions will be completed by December 1,1990.
Revisions to-Administrative Procedures 9.03 and-9.ll or the' issuance of the engineering guideline will-be completed as appropriate by April:1, 1991.
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(GeraldBSlade
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General Manager 1
CC: Administrator,l Region III, USNRC Palisades Resident Inspector
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