ML18052B181
| ML18052B181 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/03/1987 |
| From: | Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8707090076 | |
| Download: ML18052B181 (6) | |
Text
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General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 July 3, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO INSPECTION REPORT 87-008 NRG Inspection Report dated May 22, 1987 transmitted two violations and requested a written response which follows.
The response also includes a discussion of several operations related events which were identified as concerns in the NRG letter.
Item 1:
Discussion of Operations Related Events (Paragraphs 3.d., e. and h. of IEIR 87-008)
Paragraph 3.d.
On April 24, 1987, at 2020 hours0.0234 days <br />0.561 hours <br />0.00334 weeks <br />7.6861e-4 months <br />, a power transient occurred from approximately 100% power when purification demineralizer, T-51B was placed in service.
The compliment of Operations personnel on shift at the time of this occurrence was the standard crew who consistently perform together through shift rotation with the exception of the Shift Supervisor (SS).
The on-duty SS was not a regular SS, however, he has performed duties as an SS for several.years at Palisades.
Because placing T-51B in service is not a frequent occurrence, the SS utilized available operating procedures and conducted a pre-job briefing with the crew.
The briefing included a discussion of the procedural caution concerning possible deboration and guidance on compensation.
As in stated, IEIR 87-008, paragraph 3.d, the procedure does not address sampling.the demineralizer for the boron concentration present prior to placing it into service.
This occurrence is determined to be due to the infrequent nature of placing T-51B in service and the identified procedural weakness.
This occurrence is not viewed as a lack of attention to details, nor to have resulted from having the regular SS off-duty.
OC0787-0097-NL04 8707090076 870703 PDR ADOCK 05000255 G
Nuclear Regulatory Commission Palisades Plant Response to IEIR 87-008 July 3, 1987 Appropriate procedures have been revised to address sampling the demineralizer prior to placing it into service.
The event was reviewed by the Operations Superintendent and salient details discussed with on-shift personnel.
The event and its corrective actions will be reviewed with all Operations personnel through the department continuing training program.
Paragraph 3.e.
2 On April 27, 1987, the results of a routine surveillance test showed that the excore nuclear detectors did not meet acceptance criteria for measuring quadrant power tilt or monitoring linear heat rate.
Later that afternoon, the incore monitoring system was also declared inoperable due to a plant computer failure during input of new incore alarm points.
Technical Specification (TS) 3.23.1 implies that power operation may continue if reactor power is reduced below 85% and manual monitoring of the incore detectors is performed every two hours.
At the time of the computer failure, three SRO qualified operators, including the SS, Shift Engineer (SE) and Shift Technical Advisor (STA) reviewed TS 3.23.1 and determined no time limit be imposed in reducing power to below 85%.
The Operations Superintendent was informed of the situation and directed that power be reduced at a slower than normal rate due to recent increases in primary coolant radioactivity levels.
Review of the events, TS 3.23.1, and discussions with involved personnel indicate that a conscious effort was undertaken to compensate for the instrumentation failure.
However, due to the poorly defined TS and concerns over primary coolant radioactivity increases, power was not reduced below 85% within two hours.
As indicated by the Resident Inspectors in IEIR 87-008 paragraph 3.f, "a historical review of TS and the Safety Evaluation indicate" that a power reduction to 85% within two hours is warranted.
This position is currently being followed with respect to TS 3.23.1.
A TS change request and a modification to Standing Order 54 are being processed to state this position and clarify the otherwise poorly worded TS.
The events of this situation have been detailed with licensed SRO's and will be provided to all Operations personnel through the continuing training program.
Consumers Power Company, therefore, maintains that the root cause of this event lies with a poorly worded TS and not with a lack of attention to detail, nor with the regular SS not being on-duty
- Paragraph 3.h.
On May 4, 1987, two events occurred where fire protection system features were rendered inoperable without the required compensatory actions being
_taken.
The first event o~curred at 0629 when Operations personnel OC0787-0097-NL04
Nuclear Regulatory Commission Palisades Plant Response to IEIR 87-008 July 3, 1987 isolated the sprinkler system for the cable spreading room and the lC switchgear room.
Compensatory measures were taken for the cable spreading room, but not for the lC switchgear room.
This event is discussed below.
The second event occurred at 0830, when welding cables strung through a fire door rendered the door inoperable and compensatory measures were not taken.
Applicable corrective actions and actions to avoid further noncompliance are discussed later in Consumers Power Company's response to Violation (255 87-008-02b) (DRP).
3 The failure to recognize that the lC switchgear room sprinkler would be isolated when the cable spreading room sprinkler was isolated is due to a lack of attention to detail.
The on-duty SS* failed to fully identify all potential effects and consequences of isolating the cable spreading room sprinkler shutoff valve, MV-FP127.
The requirements invoked by TS action statements, however, were recognized by the SS prior to closure of MV-FP127.
The SS involved with this event has been counselled on the significance of fully identifying all effects and consequences associated with removing equipment from service.
A copy of the report detailing the significance of this event will be required reading for all SROs.
Presently, existing Administrative Procedures regarding removal of equipment from service and Technical Specification related effects are felt to be adequate to preclude recurrence.
In summary, Consumers Power company does not feel these three events share a common link of inattention to detail or were solely caused by the presence of an SS whose primary responsibility is not shift watch.
It is true that an SS other than the one normally working with a particular crew was on-shift, however, input was provided from, and decisions made through the shared expertise of the crew and not one individual.
The aim at Palisades is to attain consistency and experience for Operations personnel who will work together as a crew.
This aim, however, will not always be able to be met and alternate sss.will have to sit watch.
ITEM 2:
Violation (255/87-008-04) (DRP)
Technical Specification 6.8.3 requires that temporary changes to procedures be approved by the appropriate senior manager predesignated by the Plant Manager.
Contrary to the above, between March 23 and April 30, 1987, seventeen tem-porary changes were approved by persons other than the appropriate senior manager.
Corrective Actions Takeri and Results Achieved Palisades Plant Administrative Procedure 3.06, Technical Specification Changes states that "the Technical Engineer shall ensure proper OC0787-0097-NL04
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Nuclear Regulatory Commission Palisades Plant Response to IEIR 87-008 July 3, 1987 4
implementation of each new Technical Specification amendment within 30 days of the date of the amendment".
This period of time is necessary to not only assure the appropriate procedural changes are in order, but to permit adequate time to coordinate essential activities of w~ich many are safety related.
The Technical Engineer did not aggressively pursue a procedure revision due to the 30 day grace period given in Plant procedures and the after the fact nature of the signature in question.
The signature in question, a review by a senior manager, is completed to document the need for the change becoming a permanent entity of a procedure.
This signature does not affect procedural changes implemented via the temporary change process, in that it occurs after the Temporary Change Notice (TCN) is otherwise approved and issued. All TCNs cited by the NRC Inspector have been formally reviewed and signed by a senior manager.
Appropriate Plant Administrative Procedures have been revised in accordance with the Technical Specification Amendment.
Corrective Action To Be Taken To Avoid Further Noncompliance Further discussion regarding Consumers Power Company's position on the implementation time of Technical Specification amendments has been provided to NRC in the Consumers Power Company letter submitted July 3, 1987.
Full compliance has been achieved.
ITEM 3:
Violation (255/87-008-02a) (DRP) 10CFR50 Appendix B Criterion XVI "Corrective Action" requires in part that in cases of significant conditions adverse to quality, measures shall be estab-lished to assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Palisades-Administrative Procedure 3.03, "Corrective Action", implements this requirement to take corrective action to preclude repetition in Articles 4.7, 6.3, 6.4, 6.5 and 6.6.
Contrary to the above, On April 29, 1987, the East Safeguards Room noble gas monitor was administratively inoperable while the associated dampers were open, a repeat of a violation that had previously occurred on January 22 and 30, 1984, and which corrective actions described in E-PAL-84-014 failed to prevent.
The corrective actions documented in LER 255/86038 for the administratively inoperable Liquid Radwaste Effluent line monitor also failed to preclude a similar event.
Response
Corrective Actions Taken And Results Achieved This occurrence was caused by a poorly worded Standing Order.
As written at the time of occurrence, Standing Order 53 c~uld literally be OC0787-0097-NL04
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Nuclear Regulatory Commission Palisades Plant Response to IEIR 87-008 July 3, 1987 interpreted to allow the opening of the Safeguards Room ventilation dampers as long as the function of the associated radiation detection instrumentation was verified by performing an operational test.
The Palisades Plant practice is to not allow the use of equipment until all adminis-trative functions have been completed.
However, due to the wording in Standing Order 53, the on-duty SS felt justified with his actions.
A memo has been issued to all Licensed Operators citing the examples presented in this violation and stating that prior to placing equipment back in service, all required operability testing and administrative reviews must be complete.
Standing Order 53' has been revised to state that the ventilation dampers associated with the radiation detection instrumentation shall not be opened until the affected instrumentation has been declared operable.
Corrective Action To Be Taken To Avoid Further Noncompliance Full compliance has been achieved.
ITEM 4:
5 Violation (255/87-008-Zb) (DRP) 10CFR50 Appendix B Criterion XVI "Corrective Action: requires in part that in cases of significant conditions adverse to quality, measures shall be estab-lished to assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Palisades Administrative Procedure 3.03, "Corrective Action", implements this requirement to take corrective action to preclude repetition in Articles 4.7, 6.3, 6.4, 6.5 and 6.6.
Contrary to the above, on January 6 and 8, 1986, fire doors were found open contrary to Technical Specification 3.22.5.1 (Inspection Report No 255/86003(DRP) and corrective measures were not adequate to prevent recurrence as evidenced by a repeat violation on May 4, 1987.
Response
Corrective Actions Taken And Results Achieved Guidance has been presented to Maintenance Supervisors as to fire dopr requirements and direction provided on how to log the need for violating fire door integrity in documents authorizing work.
Corrective Action To Be Taken To Avoid Further Noncompliance The Mechanical Maintenance continuing training program will be enhanced to include guidance on Technical Specification and Administrative Procedure requirements regarding fire door integrity and actions to take in the event integrity cannot be maintained.
OC0787-0097-NL04
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Nuclear Regulatory Commission Palisades Plant Response to IEIR 87-008 July 3, 1987 Metal signs will be placed on fire doors stating integrity 'requirements and actions to take in the event integrity cannot be maintained.
The feasibility of implementing an administrative control mechanism similar to that utilized for releasing equipment for repair will be reviewed.
This control mechanism may take the form of a tagging system under the control of the SB.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by October 9, 1987 for all* corrective actions detailed above with the exception of* the administrative control mechanism review..
This review will be completed by August 7, 1987.
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CJames L Kuemin Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades OC0787-0097-NL04 6