ML20137L603
| ML20137L603 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/18/1985 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8601280036 | |
| Download: ML20137L603 (6) | |
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M Consumers Power Company General Offices: 1945 West ParnaH Road. Jackson, M! 49201 + (5171788-0550 October 18, 1985 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO INSPECTION REPORT 85-018 Four items of noncompliance were identified in Inspection Report 50-255/85-018 dated September 13, 1985.
In addition, the cover letter to the inspection report identified noncompliance item 2 as a significant failure to implement a broad spectrum of design controls for a minor modification. This identification resulted in a NRC request in the cover letter to discuss the corrective actions taken to address the adequacy of modifications and to assure that other deficiencies in design control have not occurred.
Management review and comment resolution has resulted in a five day delay in the submittal of this response. Telephone conversations with NRC Region III personnel on October 14, 1985 resulted in the approval of this delay.
Consumers Power Company plant changes are performed under the categories of major and minor modifications. We have determined that the errors identified occurred in the design of a minor modification to a plant system. Since major modifications are handled by offsite groups and receive additional reviews and controls, we believe the lack of proper design control is limited to minor modifications. Therefore, our review for similar modification errors will be limited to minor modifications.
A review of a representative sample of safety significant minor modifications will be performed to determine that the proper design controls were applied.
Based on these reviews, adequate assurance will be achieved that inadequacies are not present in other plant design changes.
The following is our response to the four items of noncompliance:
9601200036 851018 PDR ADOCK 050 5
0 OCT 211985 OC1085-0310-NLO4 TEO/
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a-d J G Keppler, Administrator 2
Palisades Plant Response to IEIR 85-018 October 18, 1985 Noncompliance Item 1 10CFR50.59 states in part:
"The licensee shall maintain records of changes in the facility..." which"...shall include a written safety evaluation which provides the basis for the determination that the change...does not involve an unreviewed safety question."
Contrary to the above, the licensee removed roof hatches.for the East Safeguards Pump Room on July 17, 1985, an action which partially defeated the ventilation isolation capability of the room as described in the FSAR Section 7.4.5.2, without performing a safety evaluation.
Corrective Actions Taken And Results Achieved The East Safeguards Pump Room roof hatches were reinstalled. A review was performed to determine any restrictions applicabic to the removal of these hatches during power operation. The review determined that removal of the hatches is an acceptable evolution provided certain controls are instituted.
Corrective Action To Be Taken To Avoid Further Noncompliance Administrative controls will be provided for the removal and replacement of the Safeguards Room roof hatches. A Safety Evaluation per 10CFR50.59 will be performed prior to any further removal of the roof hatches.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by December 15, 1985.
Noncompliance Item 2 10CFR50, Appendix B Criterion III states: " Measures shall be established to assure that applicable regulatory requirements and the design basis...for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.
Measurea shall also be established for the selectica and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components." Also, "The design control measures shall provide for verifying or checking the adequacy of design..."
Consumers Power Company Quality Assurance Topical Report CPC-2A implements 10CFR50 Appendix B.
Section 3.1 of the Topical Report further states:
"...The (design] controls apply to preparation and review of design documents, including the correct translation of applicable regulatory OC1085-0310-NLO4
4 J
J G Keppler, Administrator 3
Palisades Plant Response to IEIR 85-018
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October 18, 1985 requirements and design bases into design, procurement and-design bases into design, procurement and procedural documents." Appendix A, Part 1 of c
the Topical Report entitled " Regulatory Guide and ANSI Standard Commitmet.ts" commit the plant to ANSI N45.2.11-1974.and N18.7-1976.
a.
ANSI N45.2.11-1974 requires consideration of redundancy, diversity, separation requirements and failure effects requirements of structures, systems and components including a definition of those events and accidents which they must be designed to withstand (Section 3.2).
Section 6.1 of this standard also requires verification of the adequacy of the design.
b.
ANSI N18.7-1976 requires that purchased materials and components
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associated with safety-related structures or systems are purchased to meet the required specifications and codes.
IEEE 323-1974 includes electrical equipment and systems essential for containment isolation
'in the definition of Class IE equipment.
Contrary to the above:
a.
Design considerations for redundancy, diversity, and separation were incorrectly applied for Facility Change (FC). 452-2 which installed a single pressure switch and relay in series with both trains of the containment isolation signal to the component cooling water (CCW) isolation valves. The' evaluator of the change incorr'ectly assumed that redundant pressure switches were-included in the design. Also, this change did not consider the impact of the operation of the non-seismic portion of the CCW system inside containment during an accident or event.
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b.
Purchase documents associated with FC-452-2 did not specify the appropriate requirements for Class 1E system components.
Discussion The deficiencies in design control identified by this violation were reviewed by the Palisades Plant Modifications Review Task Force. This group was formed to address recent INPO concerns and other issues identified by various levels of management with respect to the modifications process.
The Task Force determined that adequate administrative controls are available to ensure proper design control during modifications.
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The inadequacies of this modification were determined to have resulted from a lack of understanding of the' design requirements by the-cognizant engineers. Therefore, certain training activities will be undertaken to improve the knowledge of these requirements.
OC1085-0310-NLO4
3 J G Keppler, Administrator 4
Palisades Plant Response to IEIR 85-018 October 18, 1985 Corrective Action Taken And Results Achieved Extensive reviews were performed of the applicable design requirements in General Design Criteria, ANSI and IEEE Standards for the CCW system. The results were compared with the installed isolation signal modification.
The modification was determined to be sufficiently within the applicable requirements and was, therefore, allowed to remain as installed. The modification was found to be deficient with respect to design requirements in IEEE Standard 279 1971.
Since this deficiency did not affect operability, the modifications to remove the deficiency would take place at a later date. Special training has been given plant engineers to emphasize the proper use of design documents and governing standards.
Corrective Action To Be Taken To Avoid Further Noncompliance The CCW isolation signal will be modified to remove the inadequacies regarding lack of redundancy, diversity and separation for the pressure switch and relay installed in the original modification. Plsnt engineers will attend a seminar on the effective use of the IEEE critetia noted to be inadequate in the CCW isolation signal design.
Date When Full Compliance Will Be Achieved The training seminars will be completed by April 30, 1986.
The additional modification to the CCW isolation signal will be completed during the next appropriate plant outage and is expected no later than December 31, 1987.
Noncompliance Item 3:
10CFR50.59(a)(1) requires prior Commission approval of a change involving an unreviewed safety question. Paragraph (a)(2) in part defines an unreviewed safety question as a change where the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased.
Contrary to the above, the Safety Evaluation for FC-452-2 did not conclude that an unreviewed safety question existed whereas the probability of the occurrence of a malfunction of'the initiation circuit for containment isolation of the CCW system was increased by adding another relay in series with the Safety Injection signal.
(The Safety Evaluation that was performed also inaccurately described redundant pressure switches.) The NRC had been notified of the licensee's intent to make a-different modification to the isolation logic, i
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OC1085-0310-NLO4
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J G Keppler, Administrator 5
Palisades Plant Response to IEIR 85-018 October 18, 1985 Discussion This occurrence resulted from errors similar to those addressed in the response to Item 2 of the Notice of Violation. Proper control of the design change and adherence to the appropriate design requirements would have prevented any discrepancies between the final design and the statements provided in the Safety Evaluation. Corrective actions with respect to the errors in design control are provided in the response to Item 2.
Corrective Action Taken And Results Achieved Special' training was recently completed for all PRC and CARB members in the requirements of 10CFR50.59. In addition, these sessions were attended by many engineers from various plant departments. The training was given in response to IE Inspection Report 85-009.
Corrective Action To Be Taken To Avoid Further Noncompliance Additional actions are provided in the response to Item 2 of this Inspection Report.
Date When Full Compliance Will Be Achieved Full compliance will be achieved as indicated in the response to Item 2.
Noncompliance Item 4:
. Technical Specification 6.8.1.f requires the implementation of proce'dures covering the Site Fire Protection Program. Fire Protection Implementing Procedure No. 7, Section 9.2 sets forth requirements for training of fire vasches and their duties and responsibilities which include being present durtag hot work with a suitable fire extinguisher.
Contrary to the above on July 16, 1985, a welder was observed grinding, an activity for which he had obtained a " Hot Work Permit", without posting a fire watch or having a fire extinguisher present.
Corrective Action Taken And Results Achieved The work activity was secured following notification of this procedural violation. The welder and-the responsible supervisor were counseled on the fire watch requirements prior to continuation of the work activity.
Fire watch responsibilities are presented during the General Employee Training required for site access. The Hot Work Parmit is required for certain specific activities such as grinoing. ~Tue responsibility for ensuring all requirements are satisfied remains with -the job supervisor.
OC1085-0310-NLO4
,o J G Keppler, Administrator 6
Palisades Plant
' Response to IEIR 85-018 October 18, 1985 Corrective Action To Be Taken To Avoid Further Noncompliance All site Maintenance Supervisors will be counselled on their responsibility to properly implement the hot work requirements.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by December 15, 1965.
j Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director,-Office of Inspection and Enforcement NRC Resident Inspector - Palisades 4
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