IR 05000255/1991017
| ML18155A278 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/14/1991 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18057B381 | List: |
| References | |
| EA-91-126, NUDOCS 9111210034 | |
| Download: ML18155A278 (4) | |
Text
Docket No. 50-255 License No. DPR-20 EA 91-126 Consumers Power Company ATTN:
Gerald November 14, 1991 Plant General Manager 27780 Blue Star Memorial Highway Covert, Michigan 49043
Dear Mr. Slade:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$50,000 (NRC INSPECTION REPORT NO. 50-255/91017)
This refers to the special safety inspection conducted September 10 through 20, 1991, at the Palisades Nuclear Generating Station to review the events
_surrounding the\\failure to have a containment spray pump operable When the reactor was made critical on March 10, 1991, and again_on March 26, 1991.
The report documenting this inspection was sent to you by letter dated October 1, 1991.
As a result of the inspection, significant violations of NRC requirements were identified.
An enforcement conference was held on October 9, 1991, in the Region III office to discuss the violations, their cause and your corrective actions.
A copy of the enforcement conference report was mailed to you on October 18, 1991.
On May 23, 1991, the Palisades Plant staff found containment spray pump P54C in an inoperab.le condition when it failed to start during a routine surveillance test.
The NRC inspection of this event concluded that the pump was removed from service on February 11, 1991, so the containment spray pumps would not inadvertently start while the plant was in an outage.. Thereafter, pump P54C was not properly returned to service before the plant was restarted on March 10, 1991.
As a consequence, the pump remained inoperable during routine plant operations from March 10, 1991, through May 23, 1991.
The root cause of this problem was that appropriate written procedures or instructions were not established and implemented to ensure that safety related components, including containment spray pump P54C, were verified operable prior to returning the reactor to service.
The violations, which are described in the enclosed Notice of Violation; include:
(a) failure to establish adequate written procedures or instructions to ensure that the containment spray pumps, and similarly the high pressure safety injection pumps,*were verified operable; and (b) operation of the reactor at po'wer while containment spray pump P54C was inoperable without complying with the CERTIFIED MAIL RETURN RECEIPT REQUESTED 9111210034 911114 PDR ADOCK 05000255 Q
- Consumers Power Company
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November 14, 1991 applicable technical specification. The consequence of these violations is that part of the containment cooling system~ which is designed to miti~ate a ser~ous safety event, was not able to perform its intended safety function.
Therefore, in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C (1991), the violations are classified in the aggregate as a Severity Level III problem.
Your corrective actions were discussed during the October 9, 1991, enforcement conference.
Those corrective actions consisted of operator training, revisions to the administrative testing program and the startup procedure, institution of a preventive maintenance program on breaker fuse block assemblies, and providing electrical indication for the closing coil power.
Those corrective actions appear acceptable to correct the immediate technical issue.
However~ the NRC is concerned that the Palisades Plant staff did not recognize that containment spray pump P54C was inoperable for a two month period because of the lack of procedures or instructions concerning the return to service of the Containment Cooling System.
We are also concerned with the effectiveness of your corrective action processes as they were applied to this matter.
Specifically, when the containment spray pump was found inoperable, you failed to question its previous operability history and you did not perform an aggressive review to identify ariy previous similar events.
We believe that, absent NRC involvement in the broader issues, your corrective actions may well have been less inclusive than those actually taken or proposed.
To emphasize the need to verify that systems designed to prevent or mitigate a serious safety event are available to perform their intended safety function, I have been authorized after consultation with the Director, Office of Enforcement, and the Deputj Executive Director for Nuclear Reactor Regulation, Regional Operations and Research to issue the enclosed Notice of Violation and Proposed
. Imposition of Civil Penalty (Notice) in the amount of $50,000 for the Severity Level III problem.
The base value of a civil penalty for a Severity Level III problem is $50,000.
The civil penalty adjustment factors in the Enforcement Policy were considered and no adjustments were made to the amount of the base civil penalty.
We recognize that your surveillance activities on May 23, 1991, identified.that pump P54C failed to start and you reported that event to the NRC in Licensee Event Report No.91-016.
While you took immediate corrective actions to restore pump P54C to service, your actions did not include an historic evaluation of pump operability and you did not perform an aggressive review to identify any previous similar problems with other plant equipment.
Further, the NRC identified the inadequacies of your start-up procedure in that the procedure did not require a demonstration of the operability of the Containment Spray System.
Therefore, on balance an adjustment to the amount of the civil penalty was not made for either the identification and reporting factor or the corrective action factor.
The NRC also considered both your past performance and the duration of the violation and deterwined that on balance, no adjustment to the base civil penalty is warranted.
The remaining factors in the enforcement policy were also considered, but not deemed appropriate for this case.
Consumers Power Company
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November 14, 1991 You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
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 requirements.
In actordance with 10 CFR 2.790 of the NRC's "Rules of Pra~tice, 11 a copy of this letter, its enclosure, and your responses will be placed in the NRC Public Document Room.
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.96-511.
- Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/enclosure:
David P. Hoffman, Vice President Nuclear Operations P. M. Donnelly, Safety and Licensing Director DCD/DCB (RIDS)
James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health Palisades, LPM, NRR SRI, Palisades SRI, Big Rock Point
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Pa~{ello 11/i'f/91 11 /p.191
- Concurren~e received during 11/8/91 telecon between W. Troskoski, OE, and p * R * Pe 1 k e, R II I CJ.:- (RY _,.l ~1 /1 /..
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- Consumers Power Company DISTRIBUTION SECY CA H. Thompson, DEDS J. Sniezek, DEDR.
J. Lieberman, OE L. Chandler, OGC J. Goldberg, OGC T. Murley, NRR -
J. Partlow, NRR Enforcement Coordinators RI, RI!, RfV, RV F. Ingram, GPA/PA D. Williams, OIG B. Hayes, OI E. Jordan, AEOD OE:ES OE:Chron OE:EA (2)
State of Michigan RAO: RI II SLO:RIII PAO:RI U IMS: RI! I
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November 14, 1991