IR 05000255/1988012
| ML18054A463 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/22/1988 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18054A464 | List: |
| References | |
| EA-88-140, NUDOCS 8812300181 | |
| Download: ML18054A463 (4) | |
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Docket No. 50-255 License No. DPR-20 EA 88-140 Consumers Power Company ATTN:
David P. Hoffman, Vice President Nuclear Operations 212 West Michigan Avenue Jackson, Michigan 49201 Gentlemen:
DEC 2 2 1989 SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NO. 50-255/88012[DRS])
This refers to the NRC inspection conducted on May 9-13, 18, 31, June 14, 29, and 30, 1988, at Palisades Nuclear Plant, Covert, Michigan and at NRC Headquarters Office, of activities authorized by NRC License No. DPR-2 Violations of NRC requirements were identified by the NRC as a result of this inspectio The Inspection Report was sent to you by letter dated August 8, 198 The inspection was conducted to review the status of fire protection activities including Unresolved Items identified during the previous fire protection inspection (Inspection Report No. 50-255/86022[DRS])
which was sent to you by letter dated November 14, 198 On September 2, 1988, an enforcement conference was conducted with you and ~embers of your staff and myself and members of the NRC staff to discuss the violations, root causes and corrective action The violations described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involve: (1) the failure to satisfy fire protection requirements set forth in 10 CFR Part 50, Appendix R, and (2) the fail'ure of your management to take aggressive and timely corrective actio Of particular concern to the NRC is that the specific items referenced in Violation I were brought to your attention and addressed in the 1986 inspection report, yet the 1988 followup inspection found that adequate corrective action had not been implemente This failure demonstrates the importance of adequate management involvement in the implementation of your corrective action progra Violation I described a failure to protect the Volume Control Tank (VCT)
outlet valve (M0-2087) to prevent spurious opening of the valve which could cause a loss of reactor coolant makeup capability required to ensure safe shutdown in the event of a fir NRC* Inspection Report No. 50-255/86022[DRS]
specifically noted that a spurious signal analysis for this valve had not been CERTIFIED MAIL RETURN RECEIPT REQUESTED j ti
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Consumers Power Company
DEC 2 2 1988 performe In response to that inspection the procedural guidance to manually
~lose M0-2087 should it spuriously tipen was inadequate in that it failed to direct the operator to first open the power circui Spurious reopening of the valve after manual closure due to a hot short is not precluded with the power circuit close During the May 1988 inspection two power control cables were identified by NRC inspector~ that could hot short and reopen M0-2087 when its power circuit is close Violation II.A involves the failures to have a completed breaker coordination study and adequately analyze the letdown flow path as require In assessing the severity level for this violation, the NRC took into consideration your presentation at the September 2, 1988 enforcement conferenc You presented information which indicated that although an analysis was not available at the time of inspection, no instances were identified in which the loss of safe shutdown capability could have occurred with regard to the breaker coordination issu With respect to the second example of Violation II.A, you discussed an Emergency Operating Procedure, in place at the time, which you believe provided sufficient guidance for oper~tors to isolate the DC power and effectively isolate the letdown high/low pressure interface, if necessar We have reviewed the information you provided and agree with your conclusion Therefore, Violation II.A is considered to be a Severity Level IV violatio Violation II.B involves inadequate actions to correct emergency lighting deficiencies in a timely manner and is also considered a Severity Level IV violatio To emphasize the importance of taking timely and effective corrective action in response to safety concerns and proper implementation of your fire protection program to maintain safe shutdown equipment free of damage in the event of a fire, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Seventy-Five Thousand Dollars ($75,000) for Violation I described in the enclosed Notic In accordance with the 11General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR, Part 2, Appendix C (1988) (Enforcement Policy), this violation has been categorized at a Severity Level III. The base value of a civil penalty for a Severity Level III violation is $50,00 The escalation and mitigation factors in the Enforcement Policy were considered, and the base civil penalty amount has been increased by 50 percent because of the duration of the violatio Specifically, the issue of spurious interactions for valve M0-2087 was brought to your attention in 1986 and the 1988 inspection found that adequate corrective action still had not been take *
You are required to respond to this letter-and should follow the instructions specified in the enclosed Notice when preparing your respons In your response, you should document the specific actions taken and any additional actions you
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Consumers Power ~ompany
DEC 2 2 1988 plan to prevent recurrenc After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC 1 s 11 Rules of Practice, 11 Part 2, Title 10, Code of Fed~ral Regulations, a copy of this Jetter and its enclosures will be placed in the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, Pub. L., No. 96-51, SC1/r~
Enclosures: Notice of Violation and Proposed Imposition of Civil Penalty
~ Regional Administrator f
A. Bert Davis
. Inspection Reports No. 50-255/86022(DRS);
No. 50-255/88012(DRS);
cc w/enclosures:
Mr. Kenneth W. Berry, Director Nuclear Licensing Gerald B. Slade, General Manager DCD/DCB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Michigan De~artment of Pub 1 i c Health T. V. Wambach, Licensing Project Manager, NRR Ronald Callen, Michigan Public Service Commission Michigan Department of Publi:_:~alt.:
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Consumers Power Company Distribution SECY CA OGPA DCD/DCB (RIDS)
J. M. Taylor, DEDRO J. Lieberman, OE L. Chandler, OGC T. Murley, NRR RAO: RIII PAO: RIII SLO: RIII *
. M. Stahulak, RIII Enforcement Coordinators RI, RI!, RIV, and RV
4, DEC 2*2 198S