ML20207L633
| ML20207L633 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/12/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8701120278 | |
| Download: ML20207L633 (4) | |
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M Nuclear Ikonsing SMM M General Offees. 1M6 West Pernell Road, Jochson, MI 49201 e (6t h 7881636 December 12, 1986 James G Keppler, Administrator Region III US Nucleat Regulatory Commission 799 Roosevelt Road Glen Ellyn IL 60137 j
DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO IE INSPECTION REPORT 86-028 IE Inspection Report 86-028 dated November 12, 1986, transmitted one violation which requires a response by December 12, 1986. The following is our response to that item.
Item 1:
Violation (255/86020-01) 10 CFR 50, Appendix B, Criterion III, as implemented by Consumers Power Company Quality Assurance Program Requirement 3.0, requires that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into srecifications, drawings, precedures and instruction. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from auch standards are controlled.
Contrary to the abover a.
The licensee fafled to correctly translate the design requirements of Schematic Diagram E-137, Sheet 1. Revision 15, onto the applicable connection diagrams. The resulted miswiring, which was identified in two unrelated breaker control circuits, prevented the automatic clonure of the diesel generator feed breaker under certain conditione.
8701120278 86121'2 PDR ADOCK 05000255 0
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4 Admini:tr:t:r, Regirn III 2
Palisades Plant Response to IEIR 86-028 December 12, 1986 b.
The licensee failed to ensure that the as-built configuration of the plant conformed to the latest design drawings.
For example, electrical conductors were found to be terminated on termination blocks and electrical devices; however, these terminations were not reflected on the applicable design drawings, and vice versa.
Field wiring of undervoltage protective relays did not conform to the applicable design drawing.
c.
The licensee failed to assure that applicable regulatory requirements were met by performing an adequate load analysis and cable sizing review when additional electrical loads were added to 2.4KV switchgears ID and IE.
Response
Corrective Actions Taken and Results Achievedt a) Subsequently, both of the wiring errors have been corrected. Contrary to the statement in the inspection report, testing performed to verify the correctness of connections in accordance with the connection diagram would not have detected the problem as the connection diagram was, itself, in error, and represented the cause of the wiring error.
As stated, however, the root cause of the occurrence was the failure to correctly translate information from the schematic diagram to the connection diagrams, and the failure of the review process to disclose this error, b) Appropriate drawing revisions were incorporated for each of the dis-crepancies between design drawings and the as-built condition which were noted in Example B of this Violation #255/86028-01.
c) To rectify the potential overloading condition, the ampacity of the feeder cables to the ID and IE switchgear subsequently have been upgraded through the installation of a solar shield on exposed conduit and the installation of a covered cable tray, respectively.
Corrective Actions To Be Tnken To Avoid Further Viointions a) No additional corrective actions are necessary.
Since the subject error occurred over six years ago during 1980, specific identification of the responsible individuals for potential counselling has not been undertaken. We believe the incident is an isolated occurrence and that adequate procedural controls are in place to prevent recurrence.
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Administrator, Region III 3
Palisades Plant Response to IEIR 86-028 December 12, 1986 b) An electrical drawing verification and update program is being devel-oped and will be implemented which will systematically identify and correct wiring or drawing discrepancies. The verification and update effort is included in the configuration management program described in our December 1, 1986, response to the November 20, 1986, NRC 50.54(f) letter.
c) The failure to perform an edequate load analysis was the result of an isolated personnel error watch occurred in 1983. We believe that controls are in place to provide adequate load analyses prior to the addition of loads. The subject example was, in fact, identified during such an evaluation which was being performed with regard to a planned loading addition.
In addition, Example C of Violation 255/86028-01 does not appear to represent a departure from compliance with NRC regulations or applica-ble license conditions. The failure to have performed a thorough load analysis ultimately resulted in no past equipment operability concerns or safety implications.
Furthermore, even if the stated example was conservatively construed as a departure fron regulatory requirements, the tests for self identifi-cation, severity level, reportability and appropriate corrective action which are stated in 10 CFR 2 Appendix C V.A. were completely satis-fled, precluding the necessity for the example to be included in a notice of violation.
Consequently, we request that Example C of the violation be withdrawn.
Date When Full Compliance Will Be Achieved:
a) Full compliance has been achieved.
b) Full compliance has been achieved with respect to the identified discrepancies. Further wiring / drawing revisions will be completed as necessary on an on-going basis, c) Full compliance has been achieved.
Clarification An incorrect statement regarding concern for drawing updates was included in the 1 Sat paragraph of Section 2 of the Inspection Report (page 14). The statement specified our "ph.tlosophy regarding identified field deficiencies is to make the equipment operable and not be concerned with update the drawing." The NRC inspector apparently misunderstood the content of the discussion.
Palisades philosophy and practice is to update drawinga to an OCl286-0198-NI,02
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Administrator, Region III 4
Palisades Plant Response to IEIR 86-028 December 12, 1986 as-built status following the discovery of deficiencies. The point we were explaining to the inspector was that we judge the seriousness of the drawing error based on its effect on equipment operability. We did not state that the drawing error should not be corrected.
jb 8 Kenneth W Berry Director Nuclear Licensing i
CC Director, Office of Nuclear Reactor Regulation i
Director, Office of Inspection and Enforcement i
NRC Resident Inspector - Palisades i
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