IR 05000255/1992011
| ML18058A476 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/02/1992 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18058A478 | List: |
| References | |
| EA-92-074, EA-92-74, NUDOCS 9206090021 | |
| Download: ML18058A476 (6) | |
Text
Doc~et No.
50~255 License No.
DPR-20 EA 92-074 Consumers Power Company June 2, 1992 ATTN:
Mr. David Vice President - Nuclear Operations 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Hoffman:
SUBJECT:
PALISADES NUCLEAR GENERATING PLANT NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$75,000 (NRC INSPECTION REPORT NO. 50-255/92011(DRS))
This refers to the special safety inspection conducted during the period of February 12-14, February 25-27, March 24-27, and April 16, 1992, at the Palisades Nuclear Generating Plant.
The inspection included a review of the circumstances surrounding the main steam isolation valves being inoperable in the event of a high energy line break, and your disposition of a contractor's review of the environmental qualification (EQ) equipment list.,
The report documenting this inspection was sent to you by letter dated April 27, 1992.
During this inspection a violation of NRC requirements was identified.
Your plan for enhancing the environmental qualification of electrical equipment was sent to the NRC by letter dated April 30, 1992, and an enforcement conference was held on May 1, 1992, to discuss the violation, its causes, and your corrective actions.
The report summarizing the conference was sent to you by letter dated May *6, 1992.
In response to previous EQ program problems, you commissioned a contractor to perform an independent review of the EQ equipment list.
The contractor's report, which identified a number of deficiencies in the EQ equipment list as well as in the plant's equipment data base, was received by your staff in December 1990.
Your initial screening review of the report, performed shortly after it was received, did not identify any immediate concerns CERTIFIED MAIL RETURN RECEIPT REQUESTED I\\\\
- -r.r-Ff
Consumers Power Company
June 2, 1992 with compliance with 10 CFR 50.49.
Based on other priorities a more detailed review of the report was deferred.
In March 1991, the plant was returned to service following a six month outage.
The detailed review of the contractor's report began in November 1991.
As a result of the review, you determined on February 5, 1992, that the main steam isolation valves could be rendered inoperable by a steam line break outside of containment.
Since the plant was operating at 100 percent power, a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> temporary waiver of compliance was requested.
However, on February 6, 1992, you determined that the deficiency could not be corrected in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and promptly shut down the plant.
At least six other significant EQ deficiencies were identified as a result of the detailed.review and were reported to the NRC.
We believe that your initiation of a special independent review of the EQ program in light of past problems in this area was a very positive action.
The contractor's report was briefly reviewed upon its receipt to assess the significance of the items raised and to determine what, if any, immediate corrective actions were necessary.
However, this review was not sufficiently comprehensive nor given sufficient management attention to assure that items having potential impact on operability were promptly addressed.
Notwithstanding indications in the report that certain equipment in harsh environments was not environmentally qualified, it was nearly a year before a detailed review of the report was undertaken.
The root cause of this problem appears to be either a lack of detailed knowledge about EQ requirements on the part of the reviewer or excessive workloads associated with the-steam generator replacement project which caused the initial review to be superficial.
An independent contractor review, such as the one performed, requires a thorough initial review by personnel having sufficient time and expertise to assure that immediate operability issues, if they exist, are identified and corrected.
Additionally, we are concerned that there was no formal tracking of the contractor's report to ensure both management's awareness of the report and a timely completion of the detailed review.
One violation is described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involving failure to establish measures to promptly identify and correct
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Consumers Power Company
June 2, 1992 significant EQ nonconformances.
This violation is a significant regulatory concern because it resulted in safety-related equipment, nonsafety-related -411quipme_nt -which affects safety-related equipment, and accident*monit9ring instruments not being environmentally qualified for an extended period of time.
Most *
notably, the violation resulted in the main steam isolation valve circuitry not being able to perform ~ts intended safety function under certain conditions.
Therefore,* in accordance with the
"General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C (1991),
- this violation.has been categorized at Severity Level III.
We acknowledge your corrective actions to enhance the Palisades EQ program, including your decision to ~hut down the plant and initiate modifications to relocate or replace non-EQ equipment.
However, even at the Enforcement Conference, you did not appear to recognize the need for independent evaluations, such as the special contractor review performed in this case, to be reviewed by personnel having sufficient expertise and time to assure operability issues, where they exist, are identified and promptly resolved.
The EQ issues addressed in the contractor report are complicated from technical and regulatory viewpoints.
Notwithstanding, the process followed in this case to establish the significance of the contractor report findings and the course of licensee action was not acceptable *
. To emphasize the need for implementing adequate management controls to ensure that independent evaluations are promptly reviewed to-assess their impact on *equipment operability, I have been authorized after* consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civii Penalty.(Notice) in the amount of $75,000 for the violation described in the Notice.
The base value of a civil penalty for a Severity Level III violation is $50,000.
The civil penalty adjustment factors in the Enforcement Policy were considered.
We considered escalating the base civil penalty for' identification and reporting because the NRC identified your
.failure to take immediate corrective actions when you first reviewed the contractor's report *. However, you also identified that there was an EQ violation and promptly nQtified the NRC.
Therefore, no adjustment was made for this factor.
The base.
civil penalty was not mitigated for your corrective actions in that those actions were not sufficiently comprehensive, as discussed.above.
Likewise, escalation was not* considered to be warranted for this factor since you ultimately corrected the EQ
- Consumers Power Company
June 2, 1992 I
deficiencies.
The base civil penalty was escalated by 50 percent for past performance because of your prior EQ violations.
We considered escalating the base civil penalty for duration, considering the lengthy period of time during which the specific EQ deficiencies existed and the year during which corrective actions were not initiated following their identification by your contractor.
However, considering the proactive action on your part to initiate the contractor review which led to the eventual correction of the EQ problems, we have determined that additional escalation for duration is not appropriate.
The other factors in the Enforcement Policy were considered and no further adjustment to the base civil penalty was considered appropriate.
Therefore, *
based on the above, the base civil penalty has been increased by 50 percent.
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 accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
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, Public Law No.96-511.
/
Enclosure:
/
Sincerely,
- O.r*.tsJ.n.<~ '.'***; '***,(.;; *-'..
- .~i~ Be.:r:'t l'
1~: ').L3 A. Bert Davis Regional Administrator Notice of Violation and Proposed Imposition of Civil Penalty See Distribution Next Page
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J Consumers Power Company cc w/enclosure:
David P. Hoffman, Vice President Nuclear Operations P. M. Donnelly, Safety and Licensing Director DCD/DCB (RIDS)
OC/LFDCB Resident Inspector, RIII
James R. Padgett, Michigan*Public
.service Commission Michigan Department of Public Health Palisades, LPM, NRR SRI, Big Rock Point June 2, 1992
Consumers Power Company DISTRIBUTION SECY CA JSniezek, DEDR ABDavis, RIII JLieberman, OE JPartlow, NRR JGoldberg, OGC LChandler, OGC TMurley, NRR Enforcement Coordinators RI, RII, RIV, RV Fingram, GPA/PA DWilliams, OIG BHayes, OI EJordan, AEOD JLuehman, OE Day File EA File DCS state of Michigan RAO:RIII SLO:RIII PAO:RIII IMS:RIII
June 2, 1992