ML18046A323
| ML18046A323 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/16/1980 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML18046A324 | List: |
| References | |
| NUDOCS 8101220200 | |
| Download: ML18046A323 (3) | |
Text
consumers Power company General Offices: 212 Wat Michig11n Avenue, Jackson, Michigan 49201 * (517) 788-0550 December 16, 1980 Mr James G Keppler Office of Inspection and Enforcement Region III U S Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 -
LICENSE DPR PALISADES PLANT - RESPONSE TO IE INSPECTION REPORT 80-021 IE Inspection Report 80-021 dated November 21, 1980, transmitted three apparent items of noncompliance found at the Palisades Plant.
Our response to these in-fractions is as follows:
Item 1 Technical Specification 6.8.1.d. requires, in part, implementation of procedures as identified in Regulatory Guide 1.33, Appendix A, which includes procedures for the plant Fire Protectiott Program.
The Fire Protection Plan implementing procedure, paragraph 8.4.3.2.d requires designation of a qualified individual as firewatch who must be present at the scene when welding, cutting, open flame-work, or major grinding is in progress.
Contrary to the above, the inspector observed welding in progress on the T-25B fuel oil day tank on October.15, 1980, when no firewatch was present at the scene.
Response to Item 1 The welding in question was being performed by a contractor, and as required by the Plant procedures, was being administratively controlled by a "notice of Outside Construction"(NOC) form.
The NOC addressed fire protection requirements and specifically, stipulated that a firewatch was required for welding associated with the fuel oil day tank (T-25B).
The contractor has assigned a welding crew to perform this work, and one man on the crew was the assigned firewatch.
Welding had commenced (an arc had been struck) and the welder, not satisfied with the arc, instructed his helper (who was also the firewatch) to make the adjustment to the welding machine, and another arc was struck prior to his return.
At this point, the compliance inspector entered the work area and discovered that no firewatch was present.
s101220 ~oc DEC 191980
Mr James G Keppler Palisades Plant December 16, 1980 Corrective Action Taken and Results Achieved After making adjustments to the welding machine, the firewatch returned to the work scene and resumed his firewatch duties.
Corrective Action to Prevent Recurrence 2
The Contractor Construction Superintendent reviewed Plant fire protection require-ments with his welders.
A letter from the Palisades Plant Manager dated November 3, 1980, to the Construction Superintendent confirmed the commitment to adhere to the requ~rements of Palisades Plant Fire Protection Implementing Procedures.
Date When Full Compliance Will be Achieved Based on the actions taken above, Consumers Power Company requests that this item of noncompliance be classified as a deficiency; Full compliance is considered to have been achieved.
Item 2 Technical Specification 3.7.2.i provides, in part, that an emergency diesel gener-ator may be inoperable provided there are no inoperable engineered safety feature components associated with the operable diesel generator.
Contrary to the above, at abou~ 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br /> on October 30, 1980, with charging pump P-55C (associated with emergency diesel 1-1) inoperable, the licensee made emergency diesel 1-2 inoperable for testing.
Response to Item 2 A cylinder leak test (test procedure M0-7A "Emergency Diesels") is required to be performed 48 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following load testing of the diesel generator.
In this particular instance, charging pump P-55C was made inoperable during the interval between completion of load testing and commencement of *cylinder leak testing.
The procedure required verification prior to conduct of load testing that there were no inoperable safety feature components associated with the operable diesel generator.
Prior to commencement of the cylinder leak tests, however, the pro-cedure M0-7 A required determining that. the engine could be "temporarily spared from service" without stipulating the criteria for making that determination.
Although the individual authorizing the cylinder leak test apparently erred in not reading the initial portions of the procedure, the occurrence could have been avoided by stronger procedural controls associated with the cylinder leak test.
Corrective Action Taken and Results Achieved Because of its nature, no action to correct the specific occurrence could be taken.
Mr James G Keppler Palisades Plant December 16, 1980 Corrective Action to Prevent Recurrence The surveillance procedure governing diesel generator testing has been revised to be more specific in addressing ESF equipment operability prior to cylinder leak testing.
Date When Full Compliance Will be Achieved The corrective actions described above have been implemented~
Item 3 Technical Specification 3.1.1.3(1) provides a maximum pressure differential limit for the steam generator tubes during transient conditions of 1530 psia.
Contrary to the above, during plant cooldown on October 31, 1980, a steam generator tube differential pressure of 1590 psia was experienced.
Response to Item 3 Corrective Action Taken and Results Achieved 3
Steam generator secondary side water samples were taken to ascertain that the integrity of the steam generator tubes had not been violated as a result of the excessive differential pressure.
In addition, an analysis was performed to verify that the stresses imposed on the steam generator tubes were acceptable.
The results of the water samples and mathematical analysis indicated no breach of tube integrity had occurred.
Corrective Action to Prevent Recurrence The operator who was maintaining the temperature/pressure plot during the cool-down has been counseled regarding his responsibilities.
Additional disciplinary action has been taken with shift personnel involved.
Date When Full Compliance Will be Achieved The corrective actions described above have been implemented.
David P Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades Plant