ML18045A767
| ML18045A767 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/26/1980 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-80-049, EA-80-49, NUDOCS 8010090167 | |
| Download: ML18045A767 (7) | |
Text
General Offices: 1945 Parnall Road, Jackson, Michigan 49201 * (517) 788-1217 September 26, 1980 Mr Victor Stello, Jr Director of Inspection and Enforcement US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANr - RESPONSE TO NOTICE OF IMPOSITION OF CIVIL PENALTIES -
NRG LETTER DATED SEPTEMBER 16, 1980 AND IE INSPECTION REPORT 50-255/80-12 Russell B. DeWitt Vice President Nuclear Operations EA-fro-4-C/
~d ctl3of'b--ci NRG letter dated September 16, 1980 identified five alleged items of noncom-pliance which occurred at our Palisades Plant.
NRG letter aated September 18, 1980 transmitted IE Inspection Report 50-255/80-12, also related to the alleged items of noncompliance.
Our response to these letters is as follows:
ITEM 1 Technical Specifications 3.3.1 and 3.3.2 require, during power operation, the operability of at least two high pressure and one low pressure safety injection pumps (including those valves directly associated with the pumps which are required ~o function during accident conditions).
Contrary to the above, the plant operated at approximately 88~~ power throughout the 36-hour interval from 7:35 p.m. on July 25, 1980 to 7:36 a.m.
on July 27, 1980, with two of the three high pressure safety injection pumps (P-66B and P-66C) and one of the two low pressure safety injection pumps (P-67B) inoperable with respect to their design function due to containment sump suction valve CV-3030 being mispositioned in the open position.
RESPONSE TO ITEM 1 Admission or Denial of Item of Noncompliance Containment sump isolation valve CV-3030 was open during the period specified above.
Analysis subsequent to this occurrence has demonstrated that high-pressure safety injection pUll)ps (P-66B and P-66C) and low-pressure safety injection pump (P-67B) were capable of performing their intended function (ie, Primary Coolant System inventory makeup) during a postulated accident.
The Q
Mr Victor Palisades September Stello~r Plant 26, 1980 2
results of this analysis were provided to you by letter dated August 20, 1980 with Revision 1 to LER 80-021.
Even though we have concluded that the pumps would have functioned as intended, we will not contest this item of noncompli-ance.
Reason for Item of Noncompliance Operator ina~tention during performance of valve testing resulted in the wrong valve being opened and left in that position from 7:35 PM on July 25, 1980 to 7:36 AM on July 27, 1980.
Corrective Actions Taken and Results Achieved
- After the SIRW tank level and containment sump level were verified at levels consistent for power operation, CV-3030 was closed, thereby restoring the HPSI and LPSI systems to their normal power operation lineup.
- The operator who opened CV-3030 was removed from licensed duties and was evaluated by senior Plant Management with respect to his ability to resume control operator duties prior to resumption of those duties.
Corrective Actions Taken To Prevent Recurrences The foliowing corrective actions have been taken:
- The shift turnover checklist was revised to fully address verification of correct valve alignment from the Control Room.
While the turnover checklist will not prevent valving errors, its use permits prompt (within one shift) detection of valving errors in safeguard systems.
- Shift Technical Advisors' (STA) relief times have been staggered such that their relief occurs two hours prior to the remainder of shift turnover.
This provides continuity during shift change.
- Control Room panels have been marked to indicate correct valve alignments for engineered safety feature systems during power operation.
- The Feedwater Purity Building data logger is now being used to indicate changes in state (ie, from close to open) of selected essential Plant valves.
A requirement has been established to.have the Shift Supervisor review this printout when it is available.
- Shift Supervisors, licensed control operators and STAs have been instructed to fully evaluate the significance of all off-normal conditions and to inform/consult with Plant Management or the Management on-call representa-tive if essential equipment is inoperable or if doubt concerning operability exists.
<-- I
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Mr Victor Stello~r Pal.:j.sades Plant September 26, 1980 3
- Keylock switches will be installed for selected valves such that inadvertent opening of these valves cannot occur.
The keylocks will be installed per the requirements of 10 CFR 50.59.
- A letter was p.repared by the Vice President of Nuclear Operations to the Plant Operations Department expressing his concerns as to this incident.
Date When Full Compliance Will Be Achieved With the exception of the keylock switches, the corrective actions specified above have been implemented.
Keylock switches will be installed when the parts are available and Plant conditions permit their instal~ation.
ITEM 2 Technical Specifications 3.4.3 and 3.4.4 allow continued power operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with containment spray pumps P-54B and P-54C (including valves directly associated with the pumps which are required to function during accident conditions) simultaneously inoperable provided the emergency diesel generator (1-2) connected to the opposite engineered safeguards bus is started to demonstrate operability.
If both pumps are inoperable at the end of the 24-hour period, the reactor is required to. be placed in the hot standby condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above, the plant operated at approximately 88% power during the 36-hour interval from 7:36 p.m. on July 25, 1980 to 7:36 a.m. on July 27, 1980, with containment spray pumps P-54B and P-54C inoperable with respect to their design function due to containment sump suction valve CV-3030 being mispositioned in the open position.
The emergency diesel generator (1-2) connected to the opposite engineered safeguards bus was not started during that interval to demonstrate operability nor was plant shutdown initiated.
RESPONSE TO ITEM 2 Admission or Denial Containment sump isolation valve CV-3030 was open during the period specified above.
Analysis subsequent to this occurrence has demonstrated that the containment spray pumps (P-54B and P-54C) were capable of performing their intended function during a postulated accident.
The results of this analysis were provided to you by letter dated August 20, 1980 with Revision 1 to LER 80-021.
Even though we have concluded that the pumps would have functioned as intended, we will not contest this item of noncompliance.
Reason for Items of Noncompliance This response is the same as in Item 1.
Mr Victor Palisades September Stell.r Plant 26, 1980 Corrective Action Taken and Results Achieved This response is the same as in Item 1.
Corrective Actions Taken To Prevent Recurrence This response is the same as in Item 1.
Date When Full Compliance Will Be Achieved This response is the same as in Item 1.
ITEM 3 Technical Specification 3.6.la requires that containment integrity not be violated unless the reactor is in the cold shutdown condition.
4 Contrary to the above, from 7:36 a.m. Juiy 25, 1980, to 7:35 a.m. on July 27, 1980, the reactor was operated in other than the cold shutdown condition with containment integrity violated.
Specifically, containment sump suction valve CV-3030 was open and would have allowed pumping a limited quantity of contami-nated sump water to the SIRW tank subsequent to a large LOCA.
RESPONSE TO ITEM 3 Admission or Denial Containment sump isolation valve CV-3030 was opened and the subsequent analysis indicates that the alleged item of noncompliance is valid as stated above.
Reason for Item of Noncompliance This response is the same as in Item 1 above.
Corrective Action Taken and Results Achieved This response is the same as in Item 1 above.
Corrective Action Taken To Prevent Recurrence This response is the same as in Item 1.
Date When Full Compliance Will Be Achieved This response is the same as in Item 1.
Mr Victor Stell~r Palisades Plant September 26, 1980 ITEM 4 5
Technical Specification 6.8.1.c requires written procedures for surveillance
- and testing activities on safety-related equipment to be implemented.
Safety-related surveillance procedure Q0-2 "Recirculation Actuation System" has, as a prerequisite, that the plant be in cold shutdown or refueling'mode when the test is performed.
Contrary to the above, on August 19, 1980, the licensee performed test Q0-2, when the plant was operating at 88% power.
RESPONSE TO ITEM 4 Admission or Denial Procedure Q0-2 was performed during Plant operation which did violate Palisades Plant Technical Specification 6. 8. le.
Reason for Item of Noncompliance Violation of plant procedures resulted in the noncompliance.
Corrective Action Taken and Results Achieved The following corrective actions have been implemented:
- Verification was made that CV-3031 was in correct position.
An Event Report was initiated and prompt notification to NRG was made.
- The Plant Operations Superintendent wrote a memorandum to all Operations Department personnel to review the occurrence, relate its significance and to stress the importance of individual responsibilities in adhering to procedures.
- The Shift Supervisor who authorized performance of the test was removed from licensed duties.
Corrective Action Taken To Prevent Recurrence The following action has been taken:
The Shift Supervisor involved is presently engaged in a requalification program.
Date When Full Compliance Will Be Achieved Requalification of the Shift Supervisor involved is expected to be completed by October 1, 1980.
Mr Victor Stell~r Palisades Plant September 26, 1980 ITEM 5 6
10 CFR 50.72 (a)(6) requires in part, that licensees notify the NRG Operations Center within one hour by t.elephone of personnel errors which prevent or could prevent during accident conditions the fulfillment of the safety function of components important to safety that are needed to shut down the reactor safely and maintain it in a safe shutdown condition or remove residual heat following reactor shutdown.
Contrary to the above, containment sump isolation valve CV-3030 which was found mispositioned due to personnel error in the open position during normal operation at 7:36 a.m. on July 27, 1980, and which could hav~ prevented the fulfillment of the safety function of components important to safety, was not reported to the NRG until 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> after the valve had been found open.
RESPONSE TO ITEM 5 Admission or Denial Consumers Power Company interpretation of the condition described above does not constitute an item of noncompliance and should be withdrawn.
The requirement to report items within a certain time frame (whether 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 2 weeks or 30 days) must be contingent upon recognition that a reportable occurrence or condition exists.
In essence, this means, in many cases, that some time will elapse during the evaluation of an occurrence or condition before reportability can be determined.
We share NRC's concern that 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> from discovery of the condition to the time the report was made was longer than should have been expected.
Ac-cordingly, Shift Supervisors, STAs and licensed Control Operators have been instructed to fully evaluate the significance of off-normal conditions and to report to Plant management whenever they have doubts concerning the sig-nificance of any off-normal condition.
To support this, our on-call manage-ment representation has been modified such that shift personnel have a single contact available during any backshift or weekend period.
SUMMARY
Although we admit that valve CV-3030 was opened as stated in our response to the items of noncompliance, analysis of the condition did not identify any safety concern during a postulated accident.
This fact was demonstrated through an analysis which was presented to you on August 20, 1980 (LER 80-021, Revis ion 1).
We have decided that the circumstances of these events have been thoroughly reviewed both within Consumers Power Company and the NRG.
Therefore, we do not intend to contest the imposed civil penalties.
Enclosed is a check for sixteen thousand dollars ($16,000.00) for full payment of imposed civil
Mr Victor Palisades September Stello-r Plant 26' 1980 penalties pursuant to Section 234 of the Atomic Energy Act of 1954 (42 USC 2282) and to 10 CFR 2.205.
Russell B DeWitt Vice President-Nuclear Operations CC Director, Office of Nuclear Reactor Regulation Director, Region III, USNRC NRC Resident Inspector-Palisades 7