ML20212B283

Requests Addl Info Based on Util 861201 Response to NRC 861120 Request Per 10CFR50.54(f) to Address Questions Re Adequacy of Test Program to Assure That Sys Function as Designed & Basis for Deferral of Mods Beyond Plant Restart

ML20212B283
Person / Time
Site:	Palisades
Issue date:	12/23/1986
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8612290212
Download: ML20212B283 (5)

Text

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'. Dm6 USHTED STATES

[gaa ns \ NUCLEAR REGULATORY COMMISSION f

5 h no- m 799 ROOSEVELT ROAD

)f .< . . u.v,..ita 0 . .. i n DEC 2 31986 Docket No. 50-255 Consumers Power Company ATTN: Dr. F. W. Buckman Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:

By letter dated November 20, 1986, the NRC requested, pursuant to

- 10 CFR 50.54(f) that Consumers Power Company submit information on the utility's activities during the current outage which began on May 19, 1986,

- and on changes completed, underway, or planned to improve regulatory and operational performance.

1 By letter dated December 1, 1986 your company responded to the NRC's I November 20 request for information. That letter and its various enclosures and attachments addressed in some detail each of the areas called out in our letter. Following receipt and review of this information, a meeting was held i

in Region III on December 9, 1986 between Consumers Power Company and the NRC

( to discuss the actions taken thus far and future actions to support restart l and subsequent operation of the Palisades plant.

It was evident from the information provided that Consumers Power Company has a number of activities underway and planned through various programs (Material Condition Task Force, Augmented Test Program, Safety Functional Evaluation,

' Operational Readiness Assessments, and Configuration Control Program) to assess plant conditions and assure improved plant operations. Yet, we

- continued to have questions as to the adequacy of the test program to assure

! that planned tests will demonstrate that systems function as designed, the l

basis for deferral of certain modifications and program implementation beyond l the plant restart, and the specific technical basis for some of the requested Technical Specification change requests. More specific comments to address these concerns are set forth below:

1. Provide a detailed description and implementation schedule for all corrective action programs to be implemented after restart. Also provide a listing of all items identified by the Material Condition Task Force (MCTF) and significant emergent issues whose resolution is currently scheduled to occur after restart. For each item or issue, provide the scheduled resolution date and the basis and supporting analysis for delaying resolution beyond restart.

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'o i Consumers Power Company 2. For System Functional Evaluations, provide the following:

a. For each system for which a System Functional Evaluation was perfonned to establish operability /functionability, provide specific reference to the source of the criteria against which system performance was evaluated--e.g., FSAR accident analysis, etc.

b. Provide justification for the use of other than current operating data to establish system operability /functionability. Supporting analnes should be provided.

c. Provide the technical basis for any system considered operable /

functional which does not meet the criteria referenced in 'a' above.

Supporting 10 CFR 50.59 evaluations and analysis should be included as part of the technical basis. Any reduction in perfonnance margin should be explicitly identified as well as the imposition of any operating restrictions. Overall plant margin reduction should be i addressed.

3. With regard to plant testing:

a. For each of the systems which was the subject of the MCTF or a System Functional Evaluation, provide a summary description of any testing planned or performed above the component level, the objective of the testing, when performed, and the acceptance criteria as they relate to items 2.a and 2.c above. If no testing above the component level is planned for these systems, provide your justification for not doing such testing.

b. Provide a description of the program for test discrepancy resolution including the criteria to be used for either accepting less than fully satisfactory results without further action or deferring resolution beyond startup for those tests performed prior to startup, or beyond the specified test condition for those tests performed after startup,

c. Provide a description of any integrated plant testing /special monitoring planned during power ascension and any self imposed power ascension hold points for performance evaluation.

4. Provide responses to th'e questions contained in Enclosure 1 to this letter.

Recognizing that your programs, as well as the safety systems functional inspection, identified significant design problems, please provide us your plans for performing a detailed design review of systems important to safety.

Include your bases for systems selected or not selected, and schedule for such reviews. Also, please describe your planned approach to resolution of any future identified instances of plant system failure to meet design basis requirements.

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Consumers Power Company DEC 2 31986 The information requested should be submitted to Region III with a copy to the Office of Nuclear Reactor Regulation. As you are aware, a plant readiness inspection is currently underway at the Palisades Plant. The information requested in items I-3 above is necessary to support that inspection. The information requested in item 4 is necessary to support NRC review of the Technical Specification changes you have requested to support plant restart.

Your prompt attention to these requests will serve to facilitate a timely NRC decision on restart.

If you have any questions on these matters, please do not hesitate to contact me or Mr. W. G. Guldemond of my staff.

Sincerely,

@w.S vJames G. Ke p er Regional Administrator

Enclosure:

NRR Information Request relating to Technical Specification changes needed for Palisades restart cc w/ enclosure:

V. Stello, Jr., EDO H. Denton, NRR J. Taylor IE F. Miraglia, NRR A. Thadani, NRR J. Partlow, IE Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager DCS/RSB.(RIDS) O Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Nuclear Facilities and Environmental Monitoring Section i

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REQUEST FOR ADDITIONAL INFORMATION i

1. Describe the methodology for determining the service water flow and required inlet temperature to the post-DBA service water system heat loads. Provide examples of methodology used.

2. For conditions with one service water pump operating, either alone or with one or two diesel fire pumps, what is the operating point (flow and head) of each pump? If any of these points are beyond the design flow rating of the pump, what is the effect on pump operation and the

j. justification for continued operation for the duration of the event?

3. What manual actions are needed between a Safety Injection Signal (SIS) and Recirculation Actuation Signal (RAS)? How long do the actions take 3

and what other manual actions are also taking place? Verify that existing operating procedures direct the control room operator to promptly determine that systems are aligned correctly. What information is available to the control room operator to determine the need for i alignment of additional service water?

4. What is the flow distribution to each load in the CCW system with the i existing restrictions on CCW flow and as assumed in the FSAR for the following plant conditions:

a) power operation b) post-DBA c) shutdown cooling d) refueling

. 5. The CCW system has been balanced for power operating and post-DBA 4

conditions. Are valve realignments needed for shutdown cooling or j refueling? What is proposed for surveillance or controls on the system

valves? e.g., are there indications on valve stems that will be i monitored periodically or valve locks? For the service water system, what surveillances are planned to ensure critical service water flows

can be provided?

! 6. What is the margin between FSAR values and the present temperature and flow restrictions for the service water system?

7. What is the rate-of-rise of temperatures in critical control room cabinets when service water flow to control room coolers (VC 10/11)

is 0 gpm (Refer to Cases 3 and 4, special test T-216)? ,

8. If diesel generator 1-2 fails during the recirculation phase of the i post-LOCA response, describe the corrective actions required and the time j restraints involved to prevent elevated temperatures in the Engineered Safeguards Rooms from damaging essential equipment.

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9. l Can (e.g.,the heat up or sprinklers of deluge rooms containing) systems cause automatic actuation fire of suppression the fire systems j suppression system? If so, does this cause a sigr.ificant diversion of service water from critical components? j

10. In Special Test T-216, some of the results of tests 3 and 4 appear inconsistent in that (1) the pressures and differential across parallel components vary from 0-17 psi, and (2) the flow through the CAC changes 1222 pgm when instrument air is lost, however, this change is only approximately 300 gpm in tests 1, 2, 5 and 6.

11. What are the specific long term plans and schedules with milestone dates for modification to the Service Water System and Component Cooling Water System.

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