IR 05000255/1992017
| ML18058A430 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/06/1992 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18058A431 | List: |
| References | |
| NUDOCS 9205120055 | |
| Download: ML18058A430 (18) | |
Text
SUBJECT:
NRC ENFORCEMENT CONFERENCE REPORT NO. 50-255/92017(DRS)
Dear Mr. Hoffman:
This letter refers to an Enforcement Conference conducted by Mr. H. J. Miller and other members of the Region III staff on May 1, 1992~ of activities at the Palisades Nuclear Generating Plant, authorized by NRC License No. DPR-20, and to the discussion of our findings with you and your staff.
We have enclosed a report summarizing the discussion.
You will be notified by.separate correspondence of our decision regarding the enforcement action based on the information presented and discussed at the Enforcement Conference.
No response is required until you are notified of the proposed Enforcement Action.
- In accordance with 10 CFR 2.790 a°f the Commission's regulations, a copy of this* letter and the enclosed rep.ort will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this Enforcement Conference. *
Enclosure:
Enforcement Conference Report No. 50-255/92017(DRS)
See.Attached RIII
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Consumers Power Company Distribution
REGION III==
Report No.:
50-255/92017(DRS)
Docket No.:
50-255 License No.: DPR-20 Licensee:
consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Meeting Conducted:
May 1, 1992 Meeting At:
Region III Office, Glen Ellyn, Illinois Reviewed By:
Approved By:
Conference D.s~
F. 41. viblonskl, Chief
.Maintenance and Outages Section
~~**
M. ~ Ringl hief Engineering Branch Meeting summary
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Date I
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Date
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Enforcement Conference on May 1, 1992 (Report No. 50-255/92017 *
(DRS))
Areas Discussed:
.An Enforcement Conference was held in the NRC.
Region III office on May 1, 1992.
The conference was conducted as a result of the preliminary findings of the inspection conducted in February, March, and April 1992, in which apparent violations of NRC regulations were identified.
The inspection findings were documented in Inspection Report No. 50..:..255/92011, mailed to the -licensee -on April 27-, 1992.
Results:
The licensee was informed that the final decision on enforcement action for the apparent violations would be forwarded by separate correspondence.
Subsequent to the conference, the NRC evaluated the information related to the apparent violation of 10 CFR 50.9 and determined that the licensee's actions appeared to have been reasonable and that a violation of 10 CFR 50.9 did not occur.
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DETAILS 1. 0 Persons Present at Conference Consumers Power Company CCPCo)
M. Morris, Chief Operating Officer T. Buczwinski, Engineering Programs Manager P. Donnelly, Plant Safety and Licensing Director R. Hamm, Instrumentation and Control Section Head D. Hoffman; Vice President, Nuclear Operations R. Orosz, Nuclear Engineering and Construction*Manager T. Palmisano, Administration and Planning Manager G. Slade, Plant General Manager
.
K. Toner, Electric/I&C/Computer Engineering Manager
.D. Vandewalle, Engineering Manager u. s. Nuclear Regulatory Commission, Region III H. Miller, Director, Division of Reactor Safety (DRS)
R. Bywater, Reactor Engineer, Division of Reactor Projects (DRP)
R. DeFayette, Director, Enforcement and Investigatibn ~
Coordination Staff
M. Gamberoni, Project Engineer, Office of Nuclear Reactor Regulatiot:l (NRR)
G. Hausman, Reactor Inspector, DRS
- J. Luehman, Enforcement Specialist, Office of Enforcement A. Masciantonio, Palisades Project Manager, NRR
'
P. Pelke, Enforcement Specialist M. Ring, Engineering Branch Chief, DRS
- By Telephone 2.0 Enforcement Conference An enforcement conference was held in the NRC Region III off ice on May 1, 1992.
This conference was conducted as.a result of the preliminary findings of the inspection conducted in February, March, and April 1992, in which apparent violations of NRC regulations were identified. -Inspection findings*are documented.
in Inspe~tion Report 50-255/92011(DRS), transmitted to the licensee by letter April 27, 1992.
2.1 NRC's Presentation The purpose of this conference was to: (i) discuss the apparent violations, their causes, and th~ licensee's corrective actions; (2) discuss areas of concern; (3) determine if there were any escalating or mitigating circumstances; and (4) obtain any information that would help determine the appropriate enforcement action.
The outline of the NRC's presentation is Attachment 1 to this report.
2.2 Licensee's Presentation Licensee staff members discussed the circumstances surrounding their involvement with a contractor's report that included several potentially significant environmental qualification problems, and the decision making process regarding the request for a temporary waiver of compliance.
The outline of the licensee's presentation is Attachment 2 to this report.
2.2.1 Contractors Report Regarding the review of the contractor's report, the licensee explained that the report was not immediat'ely reviewed in depth, after receiving it from the contractor, but instead a screening review for operability concerns was conducted.
Since no concerns were initially identified, other matters were judged to have higher priorities, and a more ~etailed review of the report was delayed.
There was no documented record of this screening review.
Also, since no significant problems were identified during the screening -review, none of the problems in the report were put into the licensee's formalized corrective action system.
The licensee contended that this did not represent a programmatic breakdown in the corrective action program, but rather only represented an individual's judgment.
The licensee noted that the most significant problem resulting from the subsequent detailed review of the contractor's report (MSIV solenoid circuitry) was not clearly described in that report~
The licensee also pointed out that once the operability concern with the MSIV solenoid valve circuitry was realized, prompt actions were taken to communicate with the NRC and to resolve the is.sue.
2.2.2 Temporary Waiver of Compliance CTWOC)
The licensee discusseq the amount of information available to the personnel engaged in discussions with the NRC at the time of the request-for a TWOC. *While some licensee personnel were aware of the existence of the contractor's report, the licensee noted that the only issue uncovered by the detailed review, ~hich up to that time indicated a potential operability concern, was the MSIV solenoid circuitry issue (subject of the TWOC).
The licensee described the thought process and actions of personnel involved in the TWOC, the very short "time clock" involved (including the
..
effects of xenon on the plant's ability to return to power), and their resultant actions to.provide clear and complete information to the NRC as the detarled review identified additional issues. *
2.3 conclusion At the conclusion of the meeting, the licensee was informed that they would be notified in th~ near future of the final enforcement action.
Subsequent to the enforcement conference, the NRC evaluated the information related to the apparent violation of 10 CFR 50.9 and determined that the licensee's actions appeared to have been reasonable and that a violation of 10 CFR 50.9 did not occur.
Attachment 1:
Attachment 2:
Outline of NRC's Presentation outline of Licensee's Presentation
ATl'ACHMENT 1 U.S. NUCLEAR REGULATORY COMMISSION
REGION III
CONSUMERS POWER COMPANY PALISADES El\\1FORCEME1'1T CONFERENCE l\\1A y 1, 1992 10 A.M..
EA 92-074 REPORT NO. 50-255/92011
- . REGION ill OFFICE GLEN ELLYN, ILLINOIS
CONSUMERS PO\\VER COl\\,1PANY ENFORCEMENT CONFERENCE Agenda May 1, 1992 INTRODUCTION & PURPOSE Mr. H. J. Miller, Deputy Director, Division of Reactor Safety CHRONOLOGY & APPARENT VIOLATIONS Mr. Darrell Schrum, Reactor Inspector ROOT CAUSES, CONTRIBUTING FACTORS AL~D NRC CONCERNS Mr. Mark Ring, Branch Chief LICENSEE PRESENTATION & DISCUSSION Mr. D~ Hoffman,. Vice President, Nuclear Generation, and Staff CLOSING REMARKS Mr. Miller
- PURPOSES OF MEETING
- -DISCUSS THE CIRCUMSTANCES SURROUNDING THE LICENSEE'S APPARENT FAILURE TO PROMPTLYIDENTIFYAND CORRECT EQ NON-
-CONFORMANCES CONTAINED IN A CONTRACTOR'S REPORT.
- .. DISCUSS THE LICENSEE'S APPARENT FAILURE TO PROVIDE COMPLETE INFORMATION REGARDING A CONTRACTOR'S REPORT WHEN REQUESTING A TEI\\1PORARY WAIVER OF COMPLIANCE.
- REVIEW AND DISCUSS THE LICENSEE'S EVALUATION, AND CORRECTIVE AND PREVENTIVE ACTIONS.
CHRONOLOGY OF EVENTS SPRING 1990 - LICENSEE INITIATES CONTRACT.
TO REVIEW EEQ ISSUES.
DECEMBER 1990 *- CONTRACTOR ISSUES
,,REPORT TO LICENSEE WITH NUMEROUS POTENTIALLY SIGNIFICANT COMPONENT EQ PROBLEMS. LICENSEE COMPLETES CURSORY REVIEW OF REPORT, BUT TAKES NO APPARENT
- ACTION.
l\\1ARCH 1991 - PLA.NT STARTS UP AITER SIX l\\*10NTH OUTAGE.
DECEMBER 1991 - LICENSEE STARTS DETAILED REVIEW OF C0~1TRACTOR'S REPORT.
.
FEBRUARY 5, 1992 - LICENSEE DECLtjIBS MAIN.*
STEAM ISOLATION VALVES INOPERABLE; REQUEST~ TEMPORARY WAIVER OF
. COMPLIANCE, WHICH NRC GRANTS BASED ON INFORMATION PROVIDED.
FEBRUARY 6, 1992, - LICENSEE SHUTS DOWN PLANT BECAUSE ELECTRICAL ISOLATION PROBLEMS COULD NOT BE REPAIRED IN THE TIME ALLOTTED.
SAFETY SIG1\\11FICANCE The most significant effect of violation A was. to place the plant in* a situation where off-site
- release of radiation greater than 10 CFR 100 limits was possible under design basis.conditions (steam line break). *
SAFETY SIGNIFICANCE The effect of violation_ B was to hinder NRC's review ait-d decision making process to grant a temporary waiver of compliance, which -
-contributed to the plant -potentially* operating -in a non-conservative condition.
The temporary
- waiver may not have been granted had the NRC known
~II the pertinent facts.
ROOT CAUSES, CONTRIBUTING FACTORS AND NRC CONCERNS
MANAGEMENT EFFECTIVENESS
COMMUNICATIONS & EXPECTATIONS
SELF ASSESSMENT
STAFFING,.EXPERIENCE, & TRAINING
SETTING OF PRIORITIES*
RESPONSE & FOLLOW UP OF ISSUES *
SCHEDULING PRESSURES
ATI'ACHMENT 2 NRC ENFORCEMENT CONFERENCE Timeliness o( Corrective Action and Completeness and Accuracy of Information Provided to NRC Relative to Equipment Qualification D~ficiencies May 1, 1992 INTRODUCTION CONTRACTOR'S REVIEW OF PALISADES ELECTRICAL EQUIPMENT QUALIFICATION MASTER LIST INITIAL EVALUATlON OF CONTRACTOR'S REPORT ON PALISADES EQ MASTER LIST CPCO RESPONSE TO MSIV DEFICIENCI(S CORRECTIVE ACTIONS SUMMARY RD Orosz, Nuclear Engineering and Construction Manager KA Toner, Electrical/l&C/Computer Engineering Manager RM Hamm, I&C Engineering Supervisor TJ Palmisano, Plant Planning and Administrative Manager GB Slade,
- Plant General Manager DP Hoffman, Vice President - NOD
CONTRACTOR'S REVIEW OF EQ KASTER LIST
BACKGROUND EQ lists developed in early 1980's EQ Program managed by several groups
. Audits/inspections identified deficiencies
REASON FOR INDEPENDENT REVIEW
-
Reconfirm that files clearly established qualification Desire~ expert opinion on Maintenance Program Desired validation of earlier work in developing lists
SCOPE OF CONTRACTOR'S FIRST REVIEW (CPCO RECEIVED 1/90)
Reviewed environmental zones/conditions Reviewed qualification files Overviewed EQ Maintenanc.e Program Conducted limited review of equipment list
SCOPE OF CON'l'RACTOR'S SECOND REVIEW (CPCO RECEIVED 12/90)
Continued review of conditions in certain zones Performed more comprehensive review of equipment list
EVALUATION OF CONTRACTOR'S EQ REPORT
INITIAL BQ OVERVIEW EVALUATION Initiated review 12/89 Received report 1/90 Address and document response 9/90
FOLLOW-UP EQUIPMENT DATA BASE REVIEW Initiated review 7/90 Received report-12/90 Initial evaluation of contractor's findings 1/91
EVALUATION FINDINGS
PRIORITIZATION OF FINDINGS
CONCLUSIONS
COMPONENT HS-05018 HS-05108 SV-0823A SV-08238 SV-0826A SV-08268 SV-0338 SV-0342 SV-0346 SV-0347 8/2327 8/2427 TE-03518 RE-2323 RE-2324 FT-1818 CONTRACTOR EQ REPORT EVALUATION FOR SEVEN DEVIATION REPORTS CONTRACTOR CONCERN
- Classification Incorrect
- Classification Incorrect
- Equipment ID required to be EQ, not on EO list.
- Classification Incorrect
- Equipment ID required to be EO, not on EO list.
- Equipment ID required to be EO, not on EO list.
- RG 1.97 Equipment not classified as such on equipment data base.
- RG 1.97 Equipment not classified as such on equipment data base.
-*RG 1.97 Equipment not classified as such on equipment data base.
INITIAL EVALUATION Backup MSIV solenoid valve provided in non-harsh environment.
EO list references engineering analysis which supports removing valves from list.
EO list references engineering justification which supports removing valves from list.
Components provide power to other EO components on list.
Other EO components were to be removed from list.
Equipment data base in error. Component located in mild environment.
Equipment data base in error. Component qualified based on RG 1.97 review documentation.
Equipment data base in error. Component located in mild environment.
FINAL EVALUATION Solenoid valves in both harsh and non-harsh environs share common power supply without without adequate electri-cal isolation. (2/5/921 Valves not required to be on list. However share common power supply with EO components without adequate electrical isolation. (2/25/921 Valves incorrectly removed from EO list. Documenta-tion referenced inadequate to support removal from list. (3/5/921 Deviation report written based on concerns unrelated to EO. (2/25/921 Component located in harsh environment, not EO qualified. ( 1 /21/921 Component not EO qualified. (2/14/921 Component located in harsh environment, not EO qualified. (2/17 /921 RM Hemm 4130/92
'*
CPCO RESPONSE TO MSIV DEFICIENCY
CORRECTIVE ACTION PROCESS Initial CARB review Operability determination Prompt notification to shift supervisor
TECHNICAL SPECIFICATION TIME REQUIREMENTS 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in hot standby 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in hot shutdown 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be in cold shutdown
PRC MEETING Thorough discussion of situation Evaluation *of options Need to make a timely decision to request waiver Review justification for waiver
COMMUNICATIONS WITH NRC Thorough discussion of current situation Thorough discussion of waiver' request