IR 05000255/1993032

Respond to Violation Noted in Insp Rept 50-255/93-32. Corrective Actions:All Deviation Repts & Event Repts Reviewed for Reportability by Licensing Engineers

ML18059A904
Person / Time
Site:	Palisades
Issue date:	03/24/1994
From:	ROGERS D W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9403300045
Download: ML18059A904 (7)

Text

.. ** consumers Power* POWERINli

/llllCHlliAN'S

• PROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 March 24, 1994 Nuclear Regulatory Commission Document Control Desk Washington, DC.* 20555 *"* -David w. Roger& Plant Safety and Licensing Director DOCKET 50,..255 *-LICENSE DPR-20 -.PALISADES PLANT -REPLY TO NOTICE OF VIOLATION; NRC INSPECTION REPORT No. 93032 NRC Inspect.ion Report No. 93032, dated February 22, 1994, documented the. results of an and a violation of NRC .requirements pertaining to actions to preclude failµres in submitting Licensee Event Reports (LERs) within thirty days as required by 10 CFR 50.73. The Notice of Violation*

identified four.occurrences, one

.* in 1990, 1991, 1992,. and 1993, wherein LERs were submitted

• beyond the day requiremen Two violations were previously issued for th"e occurrences rn* 1991 (Inspectiori Report 91012) and 1992 (Inspection Report 92004). * Our reply to the Notice of Violation is provided in the attachment to letter. David W Rogers Plant and Licensing D{rector CC Administrator, Region Ill, USNRC NRC Resident Inspector Palisades Attachment 9403300045 940324 PDR ADOCK OS0002SS GI PDR .---,.,,, vu \.I A CMS ENERGY COMPANY

• CONSUMERS POWER COMPANY To the besf of my knowledge, *1nformation and belief, the contents of this submittal are truthful and complet .. . Robert A Fenech, Vice President Nuclear Operations Sworn and subscribed to before me this. 24th day of March 1994. * LeAnn Morse, Notary Public Berrien County, Acting in Van Buren County, Michigan . My commission expires: February 4, .1997 [SEAL]

. ATTACHMENT

• Consumers Power Company Palisades Plant Docket 50-255 REPLY TO NOTICE OF VIOLATION

-NRC INSPECTION REPORT No. 93032 March 24, 1994 4 Pages 1 REPLY TO NOTICE OF VIOLATION Violation 10 CFR 50, Appendix 8, Criterion XVI, requires that conditions adverse to *quality such as fai7ures, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and correcte In the case of significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective.action taken to prec7ude repet.itio CFR 50.13 (a)(2)(i)(B)

requires that a licensee submit a Licensee Event Report (LER) within 30 days. of the discovery of any operation or condition prohibited by the Technical Specification Contrary to the above, the licensee has failed to take effective corrective actions to prec7ude repetitive fai7ures to submit LERs within 30 days of an event in accordance*

with 10 CFR 50.73. The 1icens fai7ed to submit an LER . within 30 days in the following instances: . . . 1. An LER for an Apri7 27, 1993 event involving the simultaneous

• inoperabi7ity of both emergency diesel generatOrs was required to be *submitted by May 27, 1993, and was submitted on December 23, 1993. 2. An LER for a May 6, 1992 event involving the simultaneous inoperabi7ity of both emergency diesel was required to be submitted by June 6, 1992, and was submitted on February 10, 1994. An LER for a February 24, 1991 event involving the unanticipated start * of an_emergency diesel generator was required to be submitted on March 26, 1991, and was submitted on June 30, 1991 [June 14, 1992]. -4. An LER for a lfoveniber 13, 1990 discovery of n_on-qualified electrical*

splices on equipmen inside containment was required to be submitted on December 13, 1990, and was submitted on January 28, 1991. * Reason for the Violation . The reason for the violation is the licensing not taken full_ ownership of the Licensee Event Report process. The corrective actions in 1990 and 1991 were narrowly focused on the specific events and did not identify or address the lack of process ownershi Inadequacies existed in the which did not require any follow-up*

checking of corrective action documents to ensure proper reportability decisions were being made. Inadequacies also existed in the knowledge of some individuals making reportability decision The process for initiating Licensee Event Reports is summarized below. This summary is provided to assist in the understanding of the process inadequacie Several steps in the process are left out. A deviation report "-

2 (OR) or an event report (ER) is used to document significant conditions adverse to quality. The ER is used when the condition may be reportable to the NRC or other regulatory agency. The corrective action document, DR or ER, is reviewed by an initiating department supervisor who makes the initial -determination on reportabil i ty. When necessary, the operations shift supervisor is contacted to make an operability and immediate reportability determinatio Aft.er initiation, determination of immediate corrective action and reviews, the DR or ER is taken to the Corrective Actiori . Review Board (PCARB). PCARB, consists of, as a m1n1mum, the Plant Manager or a plant department head and a plant licensing department representativ PCARB meets on a regular work-day basis to review all newly initiated .deviation reports or reports to assure that appropriate dec.i s ions have been made. At the PCARB * meeting the .DRs and ERs are presented.and discussed, with information, clarifications, and operability discussions being supplied by the DR or ER initiator or persons familiar with the event or conditio In the case of a deviation report, a reportability determination is made at the initial PCARB meeting. However, if a reportability determination is not at the initial PCARB meeting, action is assigned to an individual from the Plant Safety and Licensing Department to make a reportability determinatio Circumstances sometimes exist when an issue is brought to PCARB as something that appears but the problem may not be fully tQ determine reportabilit As a result, a reportability determination is not made and the reportability remains to be determined based on the At PC.ARB an evaluator is assigned and the Corrective Action Coordinator (CACJ assures other portions of the'DR or ER form are completed as necessar Following the PCARB meeting, the CAC logs DR or ER, copies the document, and sends the original to the evaluato Until this year only copies of ERs were sent to the licensing section administrator to assign a licensing engineer.to prepare an LE until this year, the licensing engineer's sole responsibility was to identify the LER due date on the section's calendar and ensure the LER was completed on time. Several engineers were assigned the duty of preparing LERs. This lacked any checking to ensure that all ERs were being receive There was no verification that the reportability determinations made at PCARB, for DRs and ERs, were correct, to assure that all requiring LERs were being identifie These deficiencies emphasize the lack of ownership of the entire LER process. As noted in the inspection report, there were two previous violations identified in Inspection Report 91012 (item 3 in this NOV) and Inspection Report 92004 (item 4 in*this NOV). Both of these previous violations were issued regarding the late submittal of licensee event reports. In our reply to the Notice of Violation in Inspection Report 91012, .dated August 12, 1991, we stated that the cause for not submitting a timely LER was that the Licensing Administrator had not received the corrective action document and was unaware that a reportable event had occurre As a result, an LER had not been issued for the event.* Corrective action for this violation was that the CAC would provide the Licensing Administrator with a copy of each event report documenting a reportable event. In addition, the CAC would verbally notify 3 . the Licensing Administrator.that a reportable event has been identifie This corrective action was a*gain narrowly focused and not fully effectiv * In our reply to the Notice of Violation in Inspection Report 92004, dated. June 5, 1992, we stated that the cause of the event, in which a DR was upgraded to an ER in a PCARB meeting where the event was determined . reportable, was a breakdown of communication bet.ween the PCARB, the acting CAC and the Licensing Administrato The corrective action at that time was to ensure that the Licensing Administrator received of all event reports {ERs) that were determined to be reportable or corrective action documents where reportability was yet to be determine This corrective action was designed to keep the licensing Administrator informed about reportable events. The process remained weak in that it did not ensure that all event reports were being received for processing into LERs as appropriate and it did not provide for a review of deviation The cause of the most recent events involving missed LERs {items 1 .and 2 of this violation, were the subjects of LER 93013 and its supplement)

is not similar to the causes for the previous violation In these events the reporting condition was misunderstood and in the PCARB meetings the events . were not considered 30-day reportabl This determination was in error. The cause for these events* can be attributed to a lack of knowledge by the pl ant personnel respQnsible for determinations

.. Furthermore,*the determination by PCARB was not reviewed, as no one in the plant organization was* assigned the responsibility to perform a review of the reportability . determination As a result of these events a more thorough evaluation of the process was initiated and resulted in the corrective actions described below. In conclusion, the 1990 .and 1991 events cited .in the Notice of Violation were evaluated on a scope. SincA the time the licensing section was moved to Palisades in 1990, ownership of the LER process was not .fully-accepte Evaluation of the December 23, 1993 event also pointed to deficiencies in the process and knowledge levels of some individuals making reportability decision The new Vice President, Nuclear Operations Department, has * . reaffirmed the Licensing Administrator's accountability for the LER process. Steps to correct these deficiencies have been taken and are described below. Corrective Actions and Results Achieved Since January 1, 1994, all deviation reports and event reports are reviewed for reportability by the licensing engineer The reviews conducted by the licensing engineers undergo a peer review within the licensing section. The reportability review is documented and retained as part of the permanent record of the corrective action documen A single licensing engineer was given the following responsibilities:

To prepare the licensee event reports; periodically review the corrective action coordinator's log to assure that all of the DRs and ERs have been received in the licensing section; maintain an independent log in the licensing section;.

identify upcoming.LERs on the section's calendar; and ensure timely submittal of the LERs. Corrective Action-to Avoid Future Non-Compliance 1. Revise plant admiriistrative procedures to designate the Licensing Administrator as having the responsibility for overview of the reportability determination process in accordance with lOCFRS0.72 and lOCFRS0.73, This responsibility will include assessment of process effectiveness and of reportability determination * 2. Determine the plant staff training requirements and qualify the individuals who determine reportability in accordance with lOCFRS0.72 and lOCFRS0.7 . To ensure proper management attention and a consistent and complete -evaluation of reportable events, management review of event report has begun. A consisting of the Plant* Manager, the Nuclear Engineering and Construction Organization Manager,*

the Nuclear Performance Assessment Department the Safety and Licensing Director, and'the department assigned the.action will convene to review all event report evaluation Our administrative procedures will be revised to incorporate this review activit Date of Full Compliance Full compliance has been achieved.