IR 05000255/1996006
| ML18065A807 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/26/1996 |
| From: | Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18065A806 | List: |
| References | |
| 50-255-96-06-EC, 50-255-96-6-EC, NUDOCS 9607030385 | |
| Download: ML18065A807 (47) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION II I INSPECTION REPORT No. 50-255/96006(0RS)
FACILITY Palisades Nuclear Generating Plant LICENSEE Palisade Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 DATE June 21, 1996 INSPECTORS
. E. Cobey, Reactor Inspector APPROVED BY R. N. Gardner, Chief Engineering ~ranchJ
+
Meeting Summary Enforcement Conference on June 21. 1996 (Report No. 50-255/96006CDRS))
Areas Discussed:
Apparent violations identffied during the inspection were discussed, along with corrective actions taken or planned by the license The apparent vi~lations involved (1) the failure to provide an operable alternative or dedicated shutdown capability where systems required for hot shutdown were not protected, and (2) the failure to promptly identify and take effective corrective actions for several ~ignificant fire protection conc,i it i _Qf!_S adyer~e to qua 1 H PDR ADOCK 05000255 G
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DETAILS Persons Present at Conference
.Consumers Power Company D. Joos, Chief Operating Officer, Electric R. Fenech, Vice President, Nuclear K. Powers, Nuclear Services Manager T. Palmisano, Plant Manager D. Smedley, Licensing Manager H. Linsinbigler, Design Engineering Manager D. Fadel, System Engineering Manager K. Toner, Acting Manager Nuclear Performance Assessment Department D. Crabtree, Safety and Design Review Supervisor R. Brzezinski, Electrical Design Engineering Supervisor B. Vanwagner, System Engineering, Balance of Plant Supervisor S. Wawro, Planning, Scheduling, and Construction Manager R. Vincent, Licensing Supervisor G. Sleeper, Operations Support Coordinator S. Oakley, Operations Support Coordinator R. Philips, System Engineering D. Crane, System Engineering*
G. Jarka, Nuclear Fuels D. Leone, Sargent & Lundy Project Director J. Tilton, Electrical/l&C Engineering Supervisor (Big Rock Point)
U. S. Nuclear Regulatory Commission A. Beach, Deputy Regional Ad~inistrator, Riii G. Grant, Director, Division of Reactor Safety, Riii B. Burgess, Enforcement Officer, Riii R. Gardner, Chief, Engineering Branch 2, Riii E. Cobey, Regional Inspeftor, Riii P. Pelke, Enforcement Sp~cialist, Riii P. Madden, Senior Fire Protection Engineer, NRR T. Polich, Acting Chief, Reactor Projects Branch 3, Riii M. Parker, Palisades Senior Resident Inspector R. Lerch, Regional Inspector, Riii C. Osterholtz, Operator Licensing, Rill F. Reinhart, Acting Project Directorate 111-1, NRR B. Schaaf, Project Manager, NRR J. Beall, Office of Enforcemen M. Rafky, Office of General Counsel I Enforcement Conference An enforcement conference was held in the NRC Region III office on June 21, 199 This conference was conducted as a result of the*
findings of an inspectipn conducted from March 18 through April 29, 1996, in which apparent violations of NRC regulations were identifie Inspection findings were documented in Inspection Report No. 50-255/96004(DRS) transmitted to the licensee by letter dated May 20, 199 The purpose of this conference was to discuss the violations, root causes, contributing factors, and the licensee's corrective action During the enforcement conference, the licensee acknowledged the violation The licensee's presentation included some new information, a synopsis of the issues, investigation results, safety significance, and corrective actions. A copy of the licensee's handout is attached to this repor Attachment:
As stated
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PALISADES NUCLEAR PLANT 10 CFR 50 APPENDIX R COMPLIANCE June 21, 1996
~
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MKI0&4#'S NtJlaESC
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. JUNE 21, 1996-;
=====================. PREDECISIONAL ENFORCEMENT CONFERENCE
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10 CFR 50 APPENDIX R COMPLIANCE
AGENDA INTRODUCTION AND OVERVIEW OF PRESENTATION RA FENECH FIRE PROTECTION ENHANCEMENT PROGRAM TJ PALMISANO DISCUSSION OF VIOLATIONS DP FADEL VIOLATION 1 - TWO EXAMPLES VIOLATION 2 - FIVE EXAMPLES
)
GENERIC MANAGEMENT IMPLICATIONS KP POWERS FOR OTHER PROGRAMS
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ENFORCEMENT POLICY IMPLICATIONS RW SMEDLEY CLOSING COMMENTS RA FENECH
.e JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE MANAGEMENTPERSP~CTIVES
HISTORICAL CONTEXT-PREVIOUS FIRE PROTECTION INITIATIVES NOT FULLY EFFECTIVE
CURRENT PALISADES FIRE PROTECTION ENHANCEMENT PROGRAM IDENTIFIED ISSUES
DID NOT CLOSE ISSUES AS QUICKLY AS WE COULD HAVE
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IMPACTED BY FIRE TOUR MIND SET.
CORRECTIVE. ACTiONS
ORGANIZATIONAL CHANGES
QUESTIONS REGARDING RESOURCES
COMMITTED TO ASSURE RESOURCES AVAILABLE TO SAFELY OPERATE
.PALISADES
QAACTIONS
LESSONS LEARNED INTEGRATED INTO OTHER PROJECTS
..
JUNE 21, 1996:
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE FIRE PROTECTION ENHANCEMENT PROGRAM OVERVIEW OF VIOLATIONS IDENTIFIED IN REVIEW OF PROGRAM
NRC IDENTIFIED TWO VIOLATIONS FOR ESCALATED ENFORCEMENT CONSIDERATION
VIOLATION 1:
FAILURE TO PROVIDE AN OPERABLE ALTERNATE OR' DEDICAT.ED SHUTDOWN CAPABILITY WHERE SYSTEMS REQUIRED FOR HOT SHUTDOWN WERE NOT PROTECTED
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ALTERNATE SHUTDOWN PANEL INOPERABLE
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INADEQUATE DIESEL GENERATOR CIRCUIT FUSE COORDINATION
VIOLATION 2:
FAILURE TO PROMPTLY IDENTIFY AND TAKE EFFECTIVE CORRECTIVE ACTIONS FOR SEVERAL SIGNIFICANT FIRE PROTECTION CONDITIONS ADVERSE TO QUALITY
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FIVE EXAMPLES
- .. CPCO ADMITS BOTH VIOLATIONS -
HOWEVER, ADDITIONAL INFORMATION TO BE PROVIDED
UNDERLYING ISSUES IN MOST EXAMPLES OF VIOLATIONS 1 AND 2 ARE OLD EMBEDDED DESIGN ISSUES WITH A COMMON CAUSE:
INADEQUATE ORIGINAL APPENDIX R ANALYSES (1980s)
UNDERLYING CONDITIONS WERE IDENTIFIED DURING CPCO's FIRE PROTECTION ENHANCEMENT PROGRAM
. '.
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JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE FIRE PROTECTION ENHANCEMENT PROGRAM BACKGROUND
STARTED IN JUNE 1994 IN RESPONSE TO CPCO AUDIT AND DET
SCOPE: APPENDIX R (SAFE SHUTDOWN ISSUES)
REVIEWS BEGAN IN LA TE SUMMER 1994
PREEMPTIVE FIRE TOURS INSTITUTED AT THAT TIME
SCHEDULE PROVIDED TO NRC IN DEC. 1994 AND NOV. 1995:
SCHEDULE
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REVIEWS TO BE COMPLETED BY JUNE 1996 I
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MODIFICATIONS TO BE COMPLETED BY 8/97 (1997 REFUELING OUTAGE NOW RESCHEDULED TO 1998)
....
CURRENT STATUS
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REVIEWS TO BE COMPLETED IN JUNE 1996 (USE OF NEW METHODOLOGY BEGINS SUMMER 1996)
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_ANTICIPATE COMPLETION OF MODIFICATIONS DURING 1996
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REFUELING OUTAGE IF PRACTICAL, 1998 REFUELING OUTAGE AT LATEST
KEPT STAFF INFORMED OF SCOPE, PROGRESS AND FINDINGS
FIRST IN A SERIES OF REVIEWS TO UPGRADE PROGRAMS AT PALISADES------
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JUNE 21, 1996 '
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE FIRE PROTECTION ENHANCEMENT PROGRAM PROGRAM FINDINGS AND STATUS
ANAtYZED ABOUT 2200 CIRCUITS AND 450 SAFE SHUTDOWN COMPONENTS
PROBLEMS IDENTIFIED RESULTED IN 36 CORRECTIVE ACTIONS (SOME WITH MULTIPLE PARTS):
25 COMPLETED
REMAINDER SCHEDULED TO BE COMPLETED IN 1996
9 LERs ISSUED (5 FOLLOWED UP 50.72 PHONE CALL REPORTS)
TO VALIDATE PROGRAM, MID-COURSE AUDIT (OCT 1995) AND VERTICAL SLICE (MAY 1996) CONDUCTED:
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- . INDEPENDENT EFFORTS -AUDIT (ANATEC); VERTICAL SLICE (S&L)
- * ASSESSED APPENDIX R AND "CLASSICAL" FIRE PROTECTION
FINDINGS VALIDATED ENHANCEMENT PROGRAM EFFORTS
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JUNE 21, 1996
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PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE FIRE PROTECTION ENHANCEMENT PROGRAM PROGRAMMATIC CAUSES AND RELATED CORRECTIVE ACTIONS CAUSES FOR PROBLEMS IDENTIFIED IN ENHANCEMENT PROGRAM GENERALLY CATEGORIZED AS FOLLOWS:,
PRIOR TO 1994, MANAGEMENT WEAKNESSES RE SUL TED IN:.
INADEQUATE APPENDIX R COMPLIANCE EFFORTS
INADEQUATE APPENDIX R SELF-ASSESSMENTS
INADEQUATE MAINTENANCE OF THE APPENDIX R PROGRAM CORRECTIVE ACTIONS: REASON FOR THE PROGRAMMATIC.REVIEW -
FIRE PROTECTION ENHANCEMENT PROGRAM
- . PREEMPTIVE FIRE TOUR STRATEGY LED TO "MIND SET' THAT MINIMIZED CONSIDERATION.OF ADDED COMPENSATORY MEASURES OR ACCELERATION OF CORRECTIVE ACTIONS
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RELIANCE ON FIRE TOURS BASED ON INDUSTRY EXPERIENCE
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"MIND SET" NOT QUESTIONED -
LIKELY DUE TO "GROUP THINK".
'CORRECTIVE ACTIONS: REVIEWED ALL OPEN CONDITION REPORTS FOR
- ADEQUACY-TOOK SOME ADDITIONAL COMPENSATORY MEASURES *
AND ACCELERATED SOME CORRECTIVE ACTIONS. "GROUP THINK" TRAININ-G TO -BE GIVEN TO MANAGERS- --
- -- - - -
LACK OF SECOND TECHNICAL REVIEW OF SOME CORRECTIVEACTIONS CAUSED SOME INCONSISTENCY IN QUALITY
- - -- --CORRECTIVE ACTIONS: REVIEWED-ALt-CORRECTIVE-AC=rlONS-FGR - -
ADEQUACY AND TO ASSURE APPROPRIATE REVIEW-ADDITIONAL ACTIONS INSTITUTED
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JUNE 21, 1996*
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE FIRE PROTECTION ENHANCEMENT PROGRAM PROGRAMMATIC CAUSES AND RELATED CORRECTIVE ACTIONS CAUSES FOR PROBLEMS IDENTIFIED IN ENHANCEMENT PROGRAM GENERALLY CATEGORIZED AS FOLLOWS:
PRIOR TO 1994, MANAGEMENI WEAKNESSES RESULTED !N:
INADEQUATE APPENDIX R COMPLIANCE EFFORTS*
INADEQUATE APPENDIX R SELF-ASSESSMENTS.
INADEQUATE MAINTENANCE OF THE APPENDIX RPROGRAM CORRECTIVE ACTIONS> REASON FOR THE PROGRAMMATIC REVIEW -
FIRE PROTECTION ENHANCEMENT PROGRAM
PREEMPTIVE FIRE TOUR STRATEGY LED TO "MIND SET" THAT MINIMIZED CONSIDERATION OF ADQED COMPENSATORY MEASURES OR
.ACCELERATION OF. CORRECTIVE ACTIONS
RELIANCE ON FIRE TOURS BASED ON INDUSTRY EXPERIENCE
"MIND SET' NOT QUESTIONED -
LIKELY DUE TO "GROUP THINK" CORREGTIVE ACTIONS: REVIEWED ALL OPEN CONDITION* REPORTS FOR ADEQUACY-TOOK SOME ADDITIONAL COMPENSATORY MEASURES AND ACCELERATED SOME CORRECTIVE ACTIONS. "GROUP THINK" TRAINING TO BE GIVEN TO MANAGERS
LACK OF SECOND TECHNICALREVIEW OF SOME CORRECTIVE ACTIONS CAUSED SOME INCONSISTENCY IN QUALITY CORRECTIVE ACTIONS: REVIEWED ALL CORRECTIVE ACTIONS FOR ADEQUACY AND*TO ASSURE APPROPRIATE REVIEW-ADDITIONAL ACTIONS INSTITUTED
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JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE FIRE PROTECTION ENHANCEMENT PROGRAM IMPLICATIONS OF FINDINGS FOR OTHER FIRE PROTECTION ISSUES
"CLASSICAL" FIRE PROTECTION ISSUES AUDITED MANY TIMES BY CPCO AND NRC -
FAVORABLE RESULTS (LIMITED NUMBl;R OF DEFICl!=NCIES IDENTIFIED)
ACCORDINGLY, APPENDIX R ENHANCEMENT PROGRAM DID NOT ADDRESS
"CLASSICAL" FIRE PROTECTION ISSUES
UNDER PROGRAM AND IN VERTICAL SLICE, IDENTIFIED SEVERAL PROBLEMS ASSOCIATED WITH "CLASSICAL" FIRE PROTECTION ISSUES, QUESTIONS REGARDING FIRE AREA BOUNDARIES AND DAMPERS
IN RESPONSE, CPCO PLANNING FURTHER REVIEW OF THIS AREA -
VVILL KEEP NRC INFORMED
)
JUNE 21, 199&
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 1: ALTERNATE SHUTDOWN PANEL (C-150)
EXPLANATION OF "NORMAL" SHUTDOWN USING ALTERNATE.SHUTDOWN PANEL AND DESCRIPTION OF CONFIGURATION (SEE OUTLINE OF ACTIONS AND DIAGRAM ON FOLLOWING THREE PAGES)
INOPERABLE INVERTER DISCOVERED IN SEPTEMBER 1995 DURING SURVEILLANCE TEST
CAUSED BY FAILED ALARM BOARD
REPLACED WITHIN 7-DAY 1:-co PERIOD
REPLACEMENT LOW VOLTAGE CUT-OFF SET TO MINIMUM
DID NOT RECOGNIZE FIRE P,ROTECTION SIGNIFICANCE OF FAILURE FOR PAST OPERABILITY OF THE INVERTER. CPCO DISCARDED FAILED BOARD AFTER TAKING SEVERAL ~EADINGS (DISCUSSED LATER)
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IN JANUARY 1996, CPCO UNCOVERED "OPERABILITY" ISSUE DURING SYSTEMATIC REVIEW
REPORTED CONDITION IN LER 96-003. LER NOTED THAT:
INVESTIGATION CONTINUING
LOWVOLTAGE SET POINT MAY HAVE BEEN INCORRECTLY SET, POTENTIALLY CAUSING LOSS OF ALTERNATE SHUTDOWN PANEL DURING CERTAIN FIRES
)
JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 1: EXPLANATION OF "NORMAL" SHUTDOWN USING THE ALTERNATE SHUTDOWN PANEL (C-150)
CONDITION: FIRE IN CABLE SPREADING ROOM INCLUDING AN ASSUMED LOSS OF OFFSITE POWER
SHORT TERM CONSIDERATIONS:
INITIAL CONCERN IS TO SHUT DOWN REACTOR
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MANUALLY TRIP IF AUTOMATIC TRIP DID NOT OCCUR *
ACTIONS FOR DECAY HEAT REMOVAL
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STEAM DRIVEN AFW PUMP STARTS AUTOMATICALLY ON LOSS OF DC; OR, IF NO AUTO START, PUMP WOULD BE STARTED FROM C-150 ALTERNATE SHUTDOWN PANEL
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C-150 ENERGIZED. AUX FEED ESTABLISHED AND CONTROLLED**
FROM C-150
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DECAY HEAT REMOVED THEREAFTER BY AFW PUMP STEAM SUPPLY .
IN COMBINATION WITH THE HOGGING AIR EJECTOR AND/OR SECONDARY SAFETY VALVES
TO RESTORE AC POWER, DIESEL GENERATOR 1-1 IS STARTED AND TENDED LOCALLY, AND BREAKERS ARE CLOSED LOCALLY
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ACTIONS FOR PCS TEMPERATURE AND PRESSURE CONTROL
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CHARGING PUMP STARTED LOCALLY FOR PCS INVENTORY CONTROL
. _-*pcsBORON INJECTION NOT NEEDED FOR >20 HOURS
/
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 1: EXPLANATION OF "NORMAL" SHUTDOWN USING THE ALTERNATE SHUTDOWN PANEL (CONrD)
FOLLOW UP ACTIONS
USE C-150 CONTROL AND INDICATION TO THROTILE AfW FLOW TO MAINTAIN SIG LEVELS (MATCH DECAY HEAT)
CONTINUE REMOVING DECAY HEAT, FEEDINGS/Gs, AND MAKING UP TO THE PCS INDEFINITELY UNTIL COLD SHUTDOWN REPAIRS COMPLETE THEN INITIATE COOLDOWN
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JUNE 21, 19.96 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 1: DIAGRAM OF IMPACTED FIRE AREAS
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JUNE 21, 1996*
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1*EXAMPLE1: SUBSEQUENT INVESTIGATION WHAT VALUE WAS THE LOW VOLTAGE CUT-OFF SET TO?
ACCORDING TO C-150 PANEL INVERTER S'l.JPPLIER, "THE LOW VOLTAGE CUT-OFF SET POINT ADJUSTMENT WOULD HAVE BEEN FACTORY PRESET AND TESTED TO THE VALUE SPECIFIED IN THE [VENDOR] MANUAL, 105 voe, PRIOR TO SHIPMENT."
- C-150 PANEL FABRICATOR RECEIVED AND INSTALLED THE INVERTER WITHOUT TESTING OR ADJUSTMENT
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PALISADES INSTALLED THE COMPLETE.D C-150 PANEL WITHOUT TESTING OR ADJUSTING THE Sf;T POINT
)
AFTER INSTALLATION, NO RECORD OF EVER CHANGING OR ADJUSTING THE SETIING, OR OF ANY PREVIOUS DAMAGE OR FAILURE OF THE*
INVERTER
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REASONABLE CONCLUSION -
C-150 PANEL LOW VOLTAGE CUT-OFF SET POINT WAS CORRECTLY SET BY SUPPLIER IN ACCORDANCE WITH MANUAL AND REMAINED AT CORRECT 105 voe SETIIN.
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DO READINGS FROM FAILED BOARD REFLECT LOW VOLTAGE CUT-OFF?
CAUSE OF C-150 PANEL FAILURE WAS DEFECTIVE INVERTER ALARM LOGIC BOARD. BOARD WAS REPLACED AS A UNIT
INPUT VERSUS OUTPUT READINGS WERE TAKEN ON THE FAILED INVERTER AND SEEMED TO INDICATE A LOW VOLTAGE CUT-OFF AT 120 voe (SEE DIAGRAM ON PAGE 13)
JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 1: SUBSEQUENT INVESTIGATION (CONrD)
HOWEVER, INVERTER VENDOR STATED "A DETERMINATION OF THE ORIGINAL LOW VOLTAGE CUT-OFF SET POINT CANNOT RELIABLY BE MADE, WHILE ADJUSTING THE INPUT VOLTAGE TO THE INVERTER AND MEASURING THE INPUT VOLTAGE LEVEL AT WHICH THE INVERTER SHUTS DOWN, IF THE ALARM LOGIC BOARD INSTALLED IN THE INVERTER IS DEFECTIVE."
- THEREFORE, THE MEASURED INVERTER CUT-OFF VOLTAGE DOES NOT PROVIDE RELIABLE INDICATION OF THE TRUE LOW VOLTAGE CUT-OFF SET POINT HOW LONG WAS THE INVERTER INOPERABLE?
INVERTER LAST NOTED AS BEING OPERABLE DURING AUGUST 10, 1995 SURVEILLANCE
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1.NVERTER NOT POWERED AGAIN UNTIL SEPTEMBER 27, 1995 SURVEILLANCE WHEN FAILURE DETECTED
CONCLUSION -
BOARD LIKELY FAILED WHEN POWERED FOR SURVEILLANCE OF SEPTEMBER 27, 1995
.
- >,-<
.:/*
_.,,
BOARD WAS DECLARED OPERABLE AFTER REPAIR ON OCTOBER 2, 1995,
-WITHIN THE 7-DAYLCO PERIOD. ACCORDINGLY, BOARD AND INVERTER - --
LIKELY OUT OF SERVICE FOR <5 DAYS OVERALL CONCLUSION
' --- -----.-rHE-c:.150 PANEL WOULD HAVE PERFORMED AS INTENDED UPON LOSS OF
THE BATIERY CHARGERS EXCEPT DURING "SHORT' PERIOD OF FAILED BOARD
JUNE 21, 199&
PREDECISIONAL ENFORCEMENT CONFERENCE I
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10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1-EXAMPLE1: FAILED INVERTER "READINGS" ACOalpil
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DC Vallmllls
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DC Voltmeter Reading
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AC Voltmeter Reading 128.54 VDC 120.84 VAC
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127.60 VDC 121.31 VAC 126.62 VDC 121.34 VAC
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124.80 VDC 121.21 VAC.
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123.81 VDC 120.95 VAC 122.88 VDC 120.34 VAC 121.82 VDC 119.65 VAC 121.29 VDC 119.42 VAC Approx 120 VDC OVAC
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JUNE 21, 1996 IE 21, 199,,. f>REDECISIONAL ENIPJRCEMENT CONFERE,CE
. 1 * ::J
.J 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 1: SIGNIFICANT CAUSES DURING INITIAL INSTALLATION OF ALTERNATE SHUTDOWN PANEL IN EARLY 1980s, DID NOT VERIFY OR TEST OPERABILITY OF PANEL WHEN POWERED FROM BATTERIES ALONE, OR ESTABLISH PERIODIC SURVEILLANCE FOR THIS CONDITION CORRECTIVE ACTIONS AND SCHEDULE:
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CONFIRMED ACCEPTABLE LOW VOLTAGE CUT-OFF VALUE
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ESTABLISHED PERIODIC SURVEILLANCE
~URE TO IDENTIFY THIS ISSUE AS A RESULT OF GE SERVICE
RMATION LETTER IN JUNE 1965
CORRECTIVE ACTIONS AND SCHEDULE:
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IN RESPONSE TO 1995 CHP TRIP ISSUE, INDUSTRY EXPERIENCE INFORMATION NOW RECEIVES SYSTEM ENGINEERING REVIEW
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REVIEW OF PAST INDUSTRY INFORMATION IS BEING FACTORED INTO OTHER PROGRAM REVIEWS FAILURE TO RECOGNIZE THE SIGNIFICANCE OF LOW VOLTAGE CUT-OFF *
SET PQINT FOR PAST OPERABILITY OF PANEL IN SEPTEMBER 1995. SET POINT WAS RESET ON REPLACEMENT BOARD TO MINIMUM WITHOUT EVALUATIO * * CORRECTIVE ACTIONS AND SCHEDULE:
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SET POINT HAS BEEN RESET
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LESSONS LEARNED TRAINING PRIOR TO NOVEMBER 1996 OUTAGE
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j JUNE 21, 1996*
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 2: EOG FUSE COORDINATION
DESCRIPTION OF CONFIGURATION (SEE DIAGRAM ON FOLLOWING PAGE)
PROBLEM WAS IDENTIFIED IN NOVEMBER 1995 BY CPCO DURING REVIEW OF ASSOCIATED CIRCUIT ANALYSES
REAFFIRMED PRESENCE OF COMPENSATORY MEASURES
ALERTED OPERATORS TO CONDITION
REPORTED CONDITION TO THE NRG IN LER 96-013
- JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE
. DISCUSSION OF VIOLATIONS VIOLATION 1 * EXAMPLE 2: DIAGRAM OF EOG CONFIGURATION Potemial Transformer
I I
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c=~ 'o Primary Fuse
. Secondary Fuse
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- Fire Arca #S: Diesel Generator 1-1 j
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A fire oc:ammg iD adia' o( thae two rooms coold cause a loa of boch 001 *l md DG 1-2
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j JUNE 21, 1996°.
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 2: SIGNIFICANT CAUSES
INITIAL APPENDIX R COMPLIANCE ISSUE -
ORIGINAL APPENDIX R ANALYSIS DID NOT RIGOROUSLY VERIFY FULL COORDINATION
CORRECTIVE ACTION AND SCHEDULE:
-
NEW CALCULATION PERFORMED
WHILE TRAINING WAS PROVIDED TO OPERATORS, MORE PERMANENT MEASURES (E.G., PROCEDURE CHANGE) NOT TAKEN WHILE MOD WAS PENDING -
IMPACTED BY FIRE TOUR "MIND SET"
CORRECTIVE ACTIONS AND SCHEDULE:
"'
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REINFORCED TO OPERATORS THE GUIDANCE PREVIOUSLY GIVEN
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ACCELERATED MODIFICATION COMPLETION
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REVIEWED ALL OUTSTANDING CONDITION REPORTS TO ASSURE
- ADEQUATE COMPENSATORY MEASURES
FAILURE TO ACCELERATE FUSE REPLACEMENT IN VIEW OFTHE POTENTIAL SAFETY SIGNIFICANCE: -
IMPACTED BY FIRE TOUR "MIND SET"
.
CORRECTIVE ACTION AND SCHEDULE:
- * FUSE REPLACED ON JUNE 3, 1996 (ACCELERATED FROM JULY 1996)
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REVIEWED ALL OUTSTANDING CORRECTIVE ACTIONS FOR ACCELERATION POTENTIAL (3 ACCELERATED)
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JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 2: SIGNIFICANCE OF ISSUE
ACTUAL SAFETY SIGNIFICANCE -
OF THE NUMEROUS FIRE AREAS WHERE CREDIT IS GIVEN FOR USE OF EDG 1-1, ONLY 2 AREAS (2 ROOMS) IMPACTED BY PROBLEM
PROBABILITY OF DAMAGING FIRE IS LOW:
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LOW TO MODERATE FIRE LOAD
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DETECTION AND AUTOMATIC SUPPRESSION (EXCEPT NO AUTOMATIC SUPPRESSION IN CONTROL ROOM -
CONTINUOUSLY MANNED)
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FIRE TOURS (SINCE LATE SUMMER 1994) *
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REQUIRES MULTIPLE AND SELECTIVE FAILURES
EVEN IF DAMAGING FIRE AND LOSS OF EDGs: *
IF LOW VOLTAGE CUT-OFF FOR THE ALTERNATE SHUTDOWN PANEL WERE CORRECTLY SET (AS IS PROBABLE), BATTERIES WOULD HAVE PROVIDED DC POWER FOR OVER 72 HOURS..REVIEW CONCLUDES AC POWER COULD BE RECOVERED IN-3-5 HOURS
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IF LOW VOLTAGE CUT-OFF WERE INCORRECTLY SET, OPERATORS WOULD HAVE MAINTAINED LOCAL CONTROL OF AFW. WITHAFW,..
. PLANT COULD ACHIEVE AND MAINTAIN SAFE SHUTDOWN:
o FOR -8 HOURS WITHOUT OPERA TOR ACTION (AF\\/'/ STARTIN VERIFIED)
o FOR OVER 20 HOURS WITH MINIMAL ACTIONS o
POWER RESTORATION -
3 - 5 HOURS o
DISCUSSION OF ACTIONS ON NEXT TWO PAGES
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I JUNE 21, 1996 *.
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 2: DISCUSSION OF SHUTDOWN ACTIONS
CONDITION: FIRE IN CABLE SPREADING ROOM (BOUNDING CASE) WHICH CAUSES LOSS OF OFFSITE POWER AND BOTH DIESEL GENERATORS, COUPLED WITH ASSUMED FAILURE OF C-150 ALTERNATE SHUTDOWN PANEL
SHORT TERM CONSIDERATIONS:
INITIAL CONCERN IS TO SHUT DOWN REACTOR
-
MANUALLY TRIP IF AUTOMATIC TRIP DID NOT OCCUR ACTIONS FOR DECAY HEAT REMOVAL:
STEAM DRIVEN AFW PUMP STARTS AUTOMATICALLY ON LOSS OF DC; OR, IF NO AUTO START, PUMP WOULD BE STARTED LOCALLY FULL AFW FLOWS TO S/Gs WITHOUT OPERA TOR ACTION
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DECAY HEAT REMOVED, THEREAFTER, WITHOUT OPERATOR ACTION BY AFW PUMP STEAM SUPPLY IN COMBINATION WITH SECONDARY SAFETY VALVES
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HOGGING AIR EJECTOR MAY ALSO BE USED TO RELEASE STEAM WITH OPERATOR ACTION BUT NOT REQUIRED
ACTIONS FOR PCS TEMPERATURE AND PRESSURE CONTROL
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PCS INVENTORY INITIALLY STABLE (PCS TEMPERATURE CONTROLLED BY S/G SATURATION TEMPERATURE) WITHOUT OPERA TOR ACTION PCS MAKEUP FOR INVENTORY OR REACTIVITY CONTROL NOT NEEDED FOR >20 HOURS
j
)
JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1 - EXAMPLE 2: DISCUSSION OF SHUTDOWN ACTIONS (CONT'D)
WITH NO ADDITIONAL OPERATOR ACTION, CAN REMAIN IN THIS CONDITION FOR -3 HOURS UNTIL SIGs OVERFILL -
THEN ANOTHER -5 HOURS WITH AFW PUMP ASSUMED UNAVAILABLE UNTIL SIG INVENTORY DEPLETED
IF ADDITIONAL MEANS ARE PROVIDED TO MONITOR SIG LEVEL, AND AFW FLOW IS THROTTLED TO MATCH DECAY HEAT (USING EXISTING MECHANICAL FLOW INDICATION), TIME CAN BE EXTENDED TO >2rn HOURS BEFORE ADDITIONAL OPERATOR ACTION NEEDED
'
FOLLOW UP ACTIONS:
C-150 REPAIRS REASONABLY EXPECTED WITHIN 3-5 HOURS OR ALTERNATE PCS AND S£G INDICATION COULD REASONABLY BE PROVIDED RESTORATION OF DIESEL GENERATOR (OR OFFSITE) AC POWER, REASONABLY EXPECTED WITHIN 3-5 HOURS TO PERMIT VITAL
/.
EQUIPMENT RECOVERY
CONTINUE REMOVING DECAY HEAT, FEEDING SIGs AND MAKING UP TO THE PCS INDEFINIT~L Y -
UNTILCOLD SHUTDOWN REPAIRS_
COMPLETED. THEN PROCEED TO COLD SHUTDOWN IN NORMAL MANNER
.
~-!.
/.\\.
)
)
JUNE 21, 1996*
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 1: SUMMARY
CPCO ADMITS THE VIOLATION
SELF-IDENTIFIED
LOW SAFETY SIGNIFICANCE
CPCO UNDERSTANDS THE REGULATORYSIGNIFICANCE
ALL CORRECTIVE ACTIONS COMPLETED EXCEPT LESSONS LEARNED TRAINING-COMPLETION 6Y NOVEMBER 1996 REFUELING OUTAGE
~*
--*---*
JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS
. VIOLATION 2: OVERVIEW
FAILURE TO PROMPTLY IDENTIFY AND TAKE EFFECTIVE CORRECTIVE ACTIONS FOR SEVERAL SIGNIFICANT FIRE PROTECTION CONDITIONS ADVERSE TO QUALITY (FIVE EXAMPLES)
EXAMPLE 1:
PROCEDURES AND PARTS FOR LPSI PUMP REPAIR NOT IN PLACE EXAMPLE 2:
MOV CIRCUITS COULD BE DAMAGED BY HOT SHORTS AND FAIL IN UNDESIRED POSITION. MANUAL REPOSITIONING MAY BE IMPACTED
-.~'*
EXAMPLE 3:
RATING. OF flRE BARRIER BETWEEN EOG 1-2 POWER AND CONTROL CIRCUITS AND EOG 1-1 EXAMPLE 4:
MAIN POWER FUSES FOR 2 DC PANELS DO NOT
.
.
COORDINATE WITH THE PANEL BRANCH CIRCUIT BREAKERS
- * '*.2 EXAMPLE 5:
INADEQUATE EMERGENCY LIGHTING *
CPCO ADMITS-VIOLATION, BUT HAS ADDITIONAL INFORMATION REGARDING SOME EXAMPLES
ALL EXAMPLES OF VIOLATION 2 HAVE A COMMON UNDERLYING INITIATOR:
INA,DEQUATE ORIGINAL APPENDIX R ANALYSES AND REVIEW EFFORTS
JUNE 21, 1998'
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATION VIOLATION 2 - EXAMPLE 1: LPSI PUMP COLD SHUTDOWN REPAIR
DESCRIPTION OF CONDITION: PROCEDURES AND PARTS FOR LPSI PUMP COLD SHUTDOWN REPAIR NOT IN PLACE
IDENTIFICATION:
CPCO IDENTIFIED UNDERLYING DEFICIENCY AND FILED LER 95-009
NRC IDENTIFIED INADEQUATE PROCEDURAL GUIDANCE TO OPERATORS
SIGNIFICANT CAUSES:
NO INDEPENDENTTECHNICAL REVIEW.OF CORRECTIVE ACTION
CORRECTIVE ACTIONS AND SCHEDULE:
. "
.
-
VERIFIED HOURLY FIRE TOURS
-
PROVIDED AUGMENTED PROCEDURAL GUIDANCE TO OPERATORS
-
PLACED SPARE FUSES IN STOCK TO SUPPORT PROCEDURE
-
REVIEWED CORRECTIVE ACTION PROCESS AND MADE PROCEDURAL CHANGES TO ENHANCE PROCESS
ACTUAL SAFETY SIGNIFICANCE IS LOW: LPSI ONLY NEEDED TO TRANSITION TO COLD SHUTDOWN. AMPLE TIME AVAILABLE TO TROUBLESHOOT AND REPLACE FUSES, WHICH IS WITHIN.OPERATOR TRAINING
- JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 2-EXAMPLE 2: ALTERNATE SHUTDOWN MOVs
DESCRIPTION OF CONDITION: IN 92-18 NOTED THAT MOV CIRCUITS COULD BE DAMAGED BY HOT SHORTS AND FAIL *1N UNDESIRED POSITION. MANUAL REPOSITIONING COULD BE IMPACTED. CPCO DID NOT PROMPTLY ADDRESS THIS ISSUE
.
IDENTIFICATION: CPCO IDENTIFIED VALVES IMPACTED-LER 95-015
SIGNIFICANT CAUSES:
PRIOR TO 1994, DELAY WAS PRIMARILY RESULT OF PERCEPTION THAT ISSUE WAS NOT SIGNIFICANT (NUMARC POSITION WAS CONSISTENT)
AFTER 1994, ITERATIVE ANALYSIS WITH EVOLVING INFORMATION HAS DELAYED ULTIMATE RESOLUTION. DIFFICULT ISSUE AS EVIDENCED BY
. INTERACTION WITH OTt;ER UTILITIES AND LERs FILE[)
CORRECTIVE ACTIONS AND SCHEDULE:
.i:
-
1994 PREEMPTIVE FIRE TOURS VERIFIED AS IN PLACE
-
INTERIM GUIDANCE ISSUED TO OPERATORS -
NOTE: FIRE TOUR
"MIND SET' RESULTED IN DELAY IN ISSUINGTHIS GUIDANCE.
4 VALVE MODIFICATIONS SCHEDULED IN 1996
.: *
-
15 VALVE MODIFICATIONS WILL BE DONE IN 1996 REFUELING OUTAGE IF PRACTICAL, OR, AT THE LATEST, 1998 REFUELING OUTAGE
,,.
- L
-
~-----
ACTUAL SAFETY SIGNIFICANCE IS LOW: IN THE EVENT OF FIRE, MANUAL OPERATOR ACTIONS WILL ALLOW SAFE SHUTDOWN TO BE ACHIEVED AND MAINTAINED
- 25
e e
JUNE 21, 199 i PREDECISIONAL ENFORCEMENT CONFERENCE
]
.. )
10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS.
VIOLATION 2 - EXAMPLE 3: DIESEL GENERATOR CIRCUITS
DESCRIPTION OF CONDITION: EOG 1-2 POWER AND CONTROL CIRCUITS ROUTED IN AIR PLENUM OF EOG 1-1 ANO NOT SEPARATED BY RATED FIRE BARRIER. CPCO's ANALYSIS OF THE BARRIER HAS BEEN QUESTIONE.
.
- *
IDENTIFICATION:
- *
CPCO IDENTIFIED UNRATED BARRIER-* LER 95-004
NRC CONCERNED THAT CURRENT CPCO BARRIER ANALYSIS IS NOT RIGOROUS ENOUGH
SIGNIFICANT CAUSES;..
UNDERLYING ISSUE -AN EARL y 1980s MODIFICATION DESIGNED to.
PROVIDE APPENDIX R CIRCUIT SEPARATION WAS INADEQUATELY EVALUATED
.
. CORRECTIVE ACTIONS AND SCHEDULE:.
o. SPECIFIC ANALYSIS REVISED o
PLANT MODIF:ICATION PROCESS REVISED TO STRENGTHEN FIRE PROTECTION/APPENDIX R REVIEW CRITERIA, E.G., DETAILED CHECKLIST CREATED
- ***
.,
JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 2 - EXAMPLE 3: DIESEL GENERA TOR CIRCUITS (CONrD)
STAFF CONCERN THAT CURRENT ANALYSIS NOT BOUNDING AND LACKED CONSERVATIVE ASSUMPTIONS CPCO DISAGREES WITH CERTAIN ASPECTS OF THE NRC's POSITION, BUT AGREES THAT ANALYSIS SHOULD BE MORE RIGOROUS CORRECTIVE ACTIONS AND SCHEDULE:
o FIRE TOURS VERIFIED AS IN PLACE o
CPCO WILL ADDRESS TECHNICAL ISSUES WITH NRG FIRE PROTECTION PERSONNEL TO DETERMINE APPROPRIATE METHODOLOGIES TO BE USED IN EVALUATIONS
. *
ACTUAL.SAFETY SIGNIFICANCE IS LOW:
NON-FIRE RATED BARRIER IS OF SUBSTANTIAL CONSTRUCTION AND CAN WITHS1AND A FIRE LASTING OVER ONE HOUR
AREA HAS AUTOMATIC SUPPRESSION WITH WATER FLOW ALARMS HOURLY FIRE TOURS (SINCE LATE SUMMER 1994)
TIME IS AVAILABLE FOR. FIRE BRIGADE RESPONSE, IF NE~DED
0
JUNE 21, 1996..
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 2 - EXAMPLE 4: LACK OF PANEL BREAKER/FUSE COORDINATION
DESCRIPTION OF CONDITION: MAIN POWER FUSES FOR 2 DC PANELS DID NOT COORDINATE WITH THE PANEL BRANCH CIRCUIT BREAKERS. A FIRE INDUCED FAULT MAY HAVE RESLJL TED IN LOSS OF THE MAIN POWER SUPPL y TO TWO 125 voe PANEL *
IDENTIFICATION: CPCO IDENTIFIED CONDITION AND FILED LER 96-005
..
SIGNIFICANT CAUSES:
1986 MODIFICATION DESIGN INADEQUATELY ADDRESSED APPENDIX R FUSE COORDINATION.REQUIREMENTS
CORRECTIVE ACTIONS AND SCHEDULE:
-
VERIFIED HOURLY FIRE TOURS IN PLACE INSTITUTED MODIFICATION PROCESS TO CHANGE FUSES TO COORDINATE (SCHEDULED FOR 1996 REFUELING OUTAGE)
-
EVALUATED OTHER POSSIBLE 125 voe COORDINATION ISSUES
-
CONFIRMED ADEQUACY OF AC COORDINATION DESIGN
-
COMPLETED PROCEDURAL UPGRADES TO'THE MODIFICATION CONTROL PROCESS
ACTUAL SAFETY SIGNIFICANCE IS LOW: PLANT CAN BE SAFELY SHUT DOWN AFTER LOSS OF THESE PANELS
0
)
.)
JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 2-EXAMPLE 5: INADEQUATE EMERGENCY LIGHTING
DESCRIPTION OF CONDITION:*
LACK OF ADEQUATE EMERGENCY LIGHTING FOR POST-FIRE SAFE SHUTDOWN ACTIONS IN CERTAIN AREAS OF THE PLAN *
CONDITION HAS NOT BEEN FULLY RESOLVED FOR A NUMBER OF YEAR *
CONDITION INVOLVES AREAS OF REDUCED EMERGENCY LIGHTING, NOT
"BLACK CONDITIONS
IDENTIFICATION:
PRIOR TO 1994, LIGHTING PROBLEMS IDENTIFIED BY BOTH CPCO AN NRC AND REPAIRED ON SEVERAL OCCASIONS
SINCE 1994, CPCO IDEf'.!TIFIED THE PROBLEM AND FILED LER ~6-007.
SIGNIFICANT CAUSES:
INEFFECTIVE INITIAL APPENDIX R LIGHTING EVALUATIONS AND PREVIOUS CORRECTIVE ACTIONS
-
CORRECTIVE ACTIONS AND SCHEDULE:
o VERIFIED OPERA TORS HAD HAND-HELD LIGHTING AS COMPENSATORY MEASURE o
ALERTED OPERA TORS TO POSSIBLE CONDITIONS
... ___ ().. COMPLETED SCHEDULED STATION LIGHTING BLACKOUT TEST TO FURTHER CONFIRM THE ADEQUACY OF PROJECTED CORRECTIVE ACTIONS (GENERALLY, CONFIRMED CONSERVATIVE POSITIONS)
o RESULTING MODIFICATIONS TO BE COMPLETED SEPTEMBER 1996
.
-~
)
- ,
'
JUNE 21, 1996~
PREDECISION~\\L ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 2 - EXAMPLE 5: INADEQUATE EMERGENCY LIGHTING (CONT'D)
INSPECTORS CONSIDERED COMPENSATORY MEASURE OF USING HAND-HELD EMERGENCY LIGHTING INADEQUATE~
-
CPCO DISAGREES: NRC STAFF ACCEPTED USE OF SAME MODEUTYPE HAND-HELD LIGHTING AT PALISADES IN.PAST REVIEWS, E..G., IN A FEBRUARY 28, 1989 LEITE *
ACTUAL SAFETY SIGNIFICANCE IS LOW:
HAND-HELD LIGHTING AVAILABLE. EXISTING PLANT PROCEDURES INFORM OPERATOR TO USE THEM, AS NECESSAR *
EMERGENCY LIGHTING PROBLEM IDENTIFIED IS A REDUCED LIGHTING ISSUE AND NOT A "BLACK-OUT' ISSUE
!
/
JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE DISCUSSION OF VIOLATIONS VIOLATION 2: SUMMARY
CPCO ADMITS THE VIOLATION
CPCO IDENTIFIED THE UNDERLYING CONCERN FOR MOST EXAMPLES
LOW SAFETY SIGNIFICANCE
)
'*
MOST OF THE 5 ISSUES HAVE COMMON CAUSES:
HISTORICAL FAILURES OF INITIAL APPENDIX RRELATED EVALUATIONS
FIRE TOUR "MIND SET"
~
ALL CORRECTIVE ACTIONS COMPLETED BY END OF 1996 REFUELING OUTAGE EXCEPT SOME MOV CIRCUIT, MODS (COMPLETION ANTICIPATED DURING 1996 REFUELING OUTAGE, IF PRACTICAL; OR IN 1998 REFUELING OUTAGE AT THE LATEST)
,.
J:
- !...
..,
)
JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE GENERIC MANAGEMENT IMPLICATIONS FOR OTHER PROGRAMS LESSONS LEARNED
.
STAY INVOLVED/ENGAGED, ESPECIALLY AS.ISSUES EVOLVE AND DISCREPANCIES ARE UNCOVERED
CONSIDER CUMULATIVE EFFECTS OF DEFICIENCIES
THOROUGHLY CONSIDER IMMEDIATE/COMPENSATORY CORRECTIVE ACTIONS WHILE WORKING ON LONGER TERM, MORE COMPREHENSIVE ACTIONS
KEEP LOOKING/DIGGING FOR ISSUES WHILE BALANCING PRIORITIES AND RESOURCES*COMMENSURATE WITH SAFETY SIGNIFICANCE
,.
JUNE 21, 1996 PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE GENERIC MANAGEMENT IMPLICATIONS FOR OTHER TECHNICAL PROGRAMS
LESSONS MAY BE APPLICABLE TO CPCO's EFFORTS TO UPGRADE OTHER PROGRAMS, INCLUDING:.
,
PRESSURIZED THERMAL SHOCK (PTS)
DRY FUEL STORAGE
SAFETY ANALYSIS REPORT
DESIGN BASIS DOCUMENTS
ALLOY 600
MAINTENANCE RULE
SAFETY RELATED PIPING REVERIFICATION
MOTOR OPERATED VALVES
AIR OPERATED VALVES
ECCS FLOW MARGIN
SMALL PIPE ANALYSIS
INSTRUMENT SET POINTS
VENDOR MANUAL *
PRA/IPE/IPEEE
EQUIPMENT QUALIFICATION
WILL INCREASE EFFORTS TO AVOID SIMILAR PROBLEMS IN THESE
.
-
.
.
PROGRAMS
WILL CONTINUE PERIODIC BRIEFINGS TO KEEP NRC STAFF ADVISED OF PROGRESS AND FINDINGS FROM THESE PROGRAMS
)
JUNE 21, 1996 *
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE GENERIC MANAGEMENT IMPLICATIONS
- FOR OTHER PROGRAMS ACTIONS TO ENSURE WE LEARN THESE LESSONS
CONDUCT WORKSHOPS WITH ALL MANAGEMENT, SUPERVISORY, AND TECHNICAL STAFF
IMPLEMENT PROGRAM HEAL TH REPORT PROCESS SIMILAR TO.SYSTEM HEALTH REPORTS BY COMPLETION OF THE 1996 REFUELING OUTAGE
ENSURE _OUR ACTIONS REINFORCE OUR COMMUNICATIONS WITH EMPLOYEES SO THAT A CONSISTENT MESSAGE IS SENT
JUNE 21, 1996
" 'r.==========================================================~
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE ENFORCEMENT POLICY FACTORS INTRODUCTION IN ACCORDANCE WITH ENFORCEMENT POLICY AND NRC's MAY 20, 1996 LEITER, CPCO PROVIDES PERSPECTIVE ON THE FOLLOWING ENFORCEMENT POLICY FACTORS:
.;,.
.
SAFETY AND REGULATORY SIGNIFICANCE
MITIGATION FACTORS
FACTORS IMPACTING NRC DISCRETION
)
)
}
JUNE 21, 1996,*
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE ENFORCEMENT POLICY FACTORS VIOLATION 1: SIGNIFICANCE FAILURE TO PROVIDE AN OPERABLE ALTERNATE OR DEDICATED SHUTDOWN CAPABILITY WHERE SYSTEMS REQUIRED FOR HOT SHUTDOWN WERE NOT PROTECTED (TWO EXAMPLES)
CPCO UNDERSTANDS THE REGULATORY SIGNIFICANCE OF ISSUE
ACTUAL SAFETY SIGNIFICANCE IS LOW:
FOR EXAMPLE 1 (ALTERNATE SHUTDOWN PANEL) FURTHER INVESTIGATION CONCLUDED:
-
LOW VOLTAGE CUT-OFF WAS CORRECTLY SET
"
ALTERNATE SHUTDOWN PANEL.WAS INOPERABLE ONLY FOR <5 DAYS (PERIOD OF ALARM BOARD REPLACEMENT) OF THE LCO
.PERIOD
FOR BOTH EXAMPLES 1 AND 2:
-
THE TWO COMPONENTS OF CONCERN (EDGs AND THE ALTERNATE SHUTDOWN ~ANEL) ARE DESIGNED TO ACCOMMODATE FIRES IN A NUMBER OF FIRE AREAS. THIS VIOLATION IMPACTS ONLY A LIMITED NUMBER OF THOSE FIRE AREAS
-
LIKELIHOOD OF A DAMAGING FIRE IS VERY LOW -
LOW TO MODERATE FIRE LOADING, FIRE TOURS (SINCE LATE SUMMER 1994), EXISTING PLANT FEATURES, AND NEED FOR MULTIPLE FAILURES
-
EVEN IF A DAMAGING FIRE, SAFE PLANT SHUTDOWN CAN BE ACHIEVED AND MAINTAINED
JUNE 21, 1996
"
PREDECISIONAL ENFORCEMENT-CONFERENCE
~
-
I!================================================================~
10 Ci=R 50 APPENDIX R COMPLIANCE ENFORCEMENT POLICY FACTORS VIOLATION 1: MITIGATING FACTORS
IDENTIFICATION:
BOTH EXAMPLES WERE LICENSEE-J.DENrlFIED. DURING SELF.:INITIATED ENHANCEMENT PROJECT
CORRECTIVE ACTIONS:
PREEMPTIVE COMPENSATORY FIRE TOURS WERE CONSERVATIVBf
BOTH DEFICIENCIES HAVE BEEN CORRECTED-FUSE*REPlACED AND TESTING/SURVEILLANCE SCHEDULE ESTABLISHED ON INVERTER
BROAD CORRECTIVE ACTIONS TAKEN TO ASSESS IMPLICATIONS FOR APPENDIX RAND OTHER PROGRAMS, E.G., REVIEWED ALL 125 voe
.
~
CIRCUITS FOR FUSE COORDINATION AND ARE IMPLEMENTING PROGRAM HEAL TH REPORTS
'"'
THIS WAS FIRST OF A NUMBER OF SELF-INITIATED, BROAD SCOPE REVIEWS TO UNCOVER POSSIBLE LONG TERM EMBEDDED ISSUES -
SHOULD BE GIVEN CREDIT FOR PROACTIVE ACTIONS
- l
,.*.,
JUNE 21~ 1996'.
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE ENFORCEMENT POLICY FACTORS VIOLATION 1: FACTORS SUPPORTING DISCRETION
.. e VIOLATION STEMMED FROM OLD DESIGN DEFICIENCIES
'
BOTH EXAMPLES IDENTIFIED BY CPCO's VOLUNTARY INITIATIVE
- * EMBEDDEO ISSUE NOT LIKELY TO HAVE BEEN IDENTIFIED EARLIER DURING
- 1 PERIOD OF CURRENTPERFORMANCE
'
.
i
).
- *
BOTH:EXAMPLES CORRECTED IN A REASONABLE TIME AFTER IDEN°TIFICATION-BROAD CORRECTIVE ACTIONS TAKEN FOR GENERIC
.IMPLICATIONS AND RECURRENCE CONTROL
DISCRETION IS WARRANTED
41, -
~ J
- *
JUNE 21, 1996 PREDECISlONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE ENFORCEMENT POLICY FAC.TORS *
VIOLATION 2: SIGNIFICANCE FAILURE TO PROMPTLY IDENTIFY AND TAKE EFFECTIVE CORRECTIVE ACTIONS FOR SEVERAL SIGNIFICANT FIRE PROTECTION CONDITIONS ADVERSE TO QUALITY (5 EXAMPLES)
ACTUAL SAFETY SIGNIFICANCE IS LOW:
LIKELIHOOD OF A DAMAGING FIRE IS REMOTE BECAUSE OF:
EXISTING. PLANT FEATURES FIRE TOURS (SINC.E LATE SUMMER 1994)
NEED FOR MULTIPLE FAILURES BEFORE PROBLEM CC.CURS
EVEN IF DAMAGING FIRE, PLANT COULD STILL ACHIEVE AND MAINTAIN SAFE SHUTDOWN
(*
- .~
)
)
JUNE 21, 199~ _
PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE ENFORCEMENT POLICY FACTORS VIOLATION 2: MITIGATING FACTORS
IDENTIFICATION:
UNDERLYING CONDITIONS WERE LICENSEE-IDENTIFIED AND REPORTED *
TO NRC DURING SELF-INITIATED ENHANCEMENT PROJECT. (FLAW IN LPSI CORRECTIVE ACTION IDENTIFIED BY NRC)
CORRECTIVE ACTIONS:
PREEMPTIVE COMPENSATORY FIRE TOURS WERE CONSERVATIV *
MOST CORRECTIVE ACTIONS COMPLETED -
REMAINING ARE PRIORITIZED TO BE COMPLETED IN REASONABLE TIME
ADDITIONAL ACTIONS TAKEN, TO ASSESS IMPLICATIONS FOR OTHER PROGRAMS
WHERE NRC QUESTIONS PROMPTNESS OF RECENTACTIONS -
IN
. HINDSIGHT CPCO DECISIONS.RESULTED FROM FIRE TOUR "MIND SET'
- JUNE 21, 1996
~i;::=:===============
~..
PREDECISIONAL ENFORCEMENT CONFERENCE I!:::===========================================================~
10 CFR 50 APPENDIX R COMPLIANCE ENFORCEMENT POLICY FACTORS VIOLATION 2: FACTORS SUPPORTING DISCRETION
HISTORICAL ASPECTS OF EXAMPLES OF VIOLATION 2 WARRANT DISCRETION (E.G., EXAMPLE 4-CbORDINATION OF FUSES FOR DC PANELS):'
STEMMED FROM OLD DESIGN DEFICIENCIES IDENTIFIED BY CPCO's VOLUNTARY INITIATIVE
- '
EMBEDDED ISSUES NOT LIKELY TO HAVE BEEN IDENTIFIED EARLIER DURING PERIOD OF CURRENT PERFORMANCE
PREEMPTIVE COMPENS.ATORY ACTIONS WERE CONSERVATIVE; CORRECTIONS WERE MADE IN A REASONABLE TIME AFTER
.
IDENTIFICATION; GENERIC IMPLICATIONS WERE BROADLY REVIEWED
- * DISCRETION IS WARRANTED
- i
)
t)
JUNE 21, 19SS, PREDECISIONAL ENFORCEMENT CONFERENCE 10 CFR 50 APPENDIX R COMPLIANCE CONCLUDING REMARKS
SUMMARY
-
.
CONCUR WITH THE VIOLATIONS--ADDITIONAL INFORMATION PROVIDE;D
VIRTUALLY.ALL UNDERLYING COMPLIANCE ISSUES _SELF-IDENTIFIED VIOLATION 1 AND ALL BUT ONE EXAMPLE OF VIOLATION 2 GROUNDED IN HISTORICAL ISSUES
- *
ANY DELAY IN ACTION WAS IMPACTE~ BY FIRE TOlJR "MIND SET", WHICH Bl::GAN AS A PROACTIVE, PREEMPTIVE COMPENSATORY MEASURE.
WE UNDERSTAND THE. REGULATORY SIGNIFICANCE; ACTUAL SAFETY-SIGNIFICANCE LOW
IMPORTANT MANAGEMENTQUESTIO_NS
DO WE UNDERSTAND THE MESSAGE?
DID OUR ACTIONS CONCERNING THE FIRE PROTECTION ENHANCEMENT PROGRAM REFLECT AN IMPROVING PLANT CONDITION AND ORGANIZATION?
IS CPCO COMMllTED TO APPL YING ADEQUATE RESOURCES TO ASSURE TIMELY COMPLETION OF THE OUTSTANDING CORRECTIVE ACTIONS AND CONTINUED SAFE OPERATION OF THE PLANT?
- !'