ML18052B482
| ML18052B482 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/28/1988 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8802030188 | |
| Download: ML18052B482 (8) | |
Text
.,.,~ :,. _.-.. **'.*... -
.~.--. -_' -::::., 1*.** *~:**.l"*t::::*,......;:-;.*...:... '*......* ---~~-
consumers
- Power PflWERINli MICHlliAN"S PRDliRESS General Offices:
1945 West Parriall Road, Jackson, Ml 49201 * (517) 788-1636 January 28, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO INSPECTION REPORT 87-027 - NOTICE OF VIOLATION Kenneth W Berry Director Nuclear Licensing
. NRC Inspection Report 87027. dated December 29, 1987 transmitted two violations which require a response by January 28, _1988.
The violations were in regard to the failure to comply with written procedures associated with the work.
order planning process and the failure to implement timely corrective actions pertaining to charging pump operability requirements and controlling contractor activities associated with motor operated valve testing.
The following is our response to the violations.
Violation (255/87027-0lA and 87027-0lB (DPR))
10 CFR 50, Appendix B, Criterion XVI, as implemented by Consumers Power Quality Assur.ance Standard NODS-QOl "Corrective Action and Control of Non-conforming Items", Revision 16, requires that conditions adverse to quality be promptly identified and corrected.
Contrary to the above:
- a.
The Licensee failed to implement timely corrective action for a previously identified NRC item pertaining to operability requirement of the.Charging Pumps.
As a result, the operability requirements.delineated in operating procedures, the FSAR and Technical Specifications were inconsistent for several months (255/87027-0lA).
- b.
The Licensee failed to implement timely corrective action *to control contractor activities that resulted in the loss of shutdown cooling capability for approximately 26 minutes on October 15, 1987 (255/87027-0lB)
.S0020301ee 0eo120 PDR ADOCK 05000255 G
PDR OC0188-0026-NL02
Nuclear Regulatory Commission Palisades Nuclear Plant IR 87-027 - Notice of Violation January 28, 1988 Corrective Actions Taken And Results Achieved 2
- a.
IE Inspection Report 255/86035 identified several open items regarding the chemical and volume control (CVC) system.
Of these open items, 255/86035-137 identified a concern regarding the ability of CVC system to provide charging flow equivalent to that assumed, in the main steam line break (MSLB) analysis.
Technical information relevant to this open item can be found in Palisades Plant Licensee Event Report 87-039, dated November 30, 1987.
During Consumers Power's Material Condition Task Force (MCTF) Program, an item (CVC-16) was identified regarding the concentrated boric acid pumps ability to provide sufficient boric acid to the eve system under the most limiting condition.
This item was detailed in Attachment 2 (CVC System Requirements) on Consumers Power's letter dated January 28, 1987.
Subsequent engineering analyses determined that as~built system configurations were adequate to provide required concentrated boric acid to the eve system.
A Final Safety Analysis Report (FSAR) change request was initiated to clarify FSAR Section 9.10.2.6.
An effort was then undertaken by Consumers Power to cross-reference NRC items and concerns identified during various Plant performance improvement programs.
During this effort, IE Inspection Report open item 255/86035-137 was erroneously cross-referenced to the concentrated boric acid item identified during the MCTF program.
After the FSAR change request for Section 9.10.2.6 was initiated, both the MCTF item and NRC open item 255/86035-137 were internally closed.
This resulted in no further efforts being undertaken in regard to NRC open item 255/86035-137.
Within this inspection, 255/87027 materials were presented to the inspectors for close out of past NRC open items.
For open item 255/86035-137, a copy of the FSAR change request regarding the concentrated boric acid pumps was presented to the inspectors.
This change request was identified within Consumers Power's Correspondence Logging and Commitment Tracking System (CLCTS) as the technical basis for internally closing 255/86035-137.
After the discrepancy was identified, efforts were immediately undertaken to resolve the technical issues regarding open item 255/86035-137.
These efforts are detailed within LER 255/87039.
- b.
In completing actions associated with IE Bulletin 85-03, "Motor Operated Common Mode Failures During Plant Transients Due to Improper Switch Settings", vendor services were contracted to perform di*agnostic
- testing of motor operated valve actuators.
Local valve control was to be obtained via a Jumper, Link and Bypass (JLB) installed and controlled in accordance with Administrative Procedure 9.31, "Jumper Link and Bypass".
Upon further review, it was determined that the JLB form would not be necessary for jumpers installed during testing.
This determination was based on the fact that:
- a.
all testing would be performed under an approved Work Order (WO)
OC0188-0026-NL02
~---------------~------------------
!.... ~..' **
Nuclear Regulatory Commission Palisades Nuclear Plant IR 87-027 - Notice of Violation January 28, 1988
- b.
equipment being jumpered would be inoperable
- c.
replacement of jumpers would be controlled by Special Test T-251, "Diagnostic Testing of Limitorque Motor Operated Valves" 3
This determination is in accordance with Administrative Procedure 9.31, Section 5.1.3, which does not require JLBs for work performed under WOs or procedures si~ce equipment will be inoperable.
In preparation for these activities, a member of the vendor staff was brought to the Plant approximately two months before work was to begin in order to gain assurrance, the vendor had the expertise to work under Plant procedures. Thereafter, WOs were written and planned assuming that jumpers would only be piaced on valve operators and without knowledge that other placement (ie, Control Room handswitches) would be required.
Vendor procedures for diagnostic testing_were submitted and approved for use, including the requirement to complete an attachment for the installation of any jumpers utilized. After vendor procedures were reviewed, the previously planned WOs were approved.
However, jumpers were to be installed by the contractor and verified by Plant Electricians.
On October 7, 1987 during diagnostic testing of the isolation valve for auxiliary feedwater to steam generator E-50B (M0-0798), a jumper was inadvertently placed in circuitry associated with M0-0760.
This error was identified when M0-0798 could not be locally closed as required by procedure.
After removing the incorrectly placed jumper and reviewing the incident, corrective actions were taken and consisted of having an Electrical Engineer review packages for proper jumper location, however, a corrective action document was not initiated.
On October 8, 1987 auxiliary feedwater isolation valve M0-0743 was re-energized following diagnostic testing without an installed jumper being removed.
This resulted in the valve cycling open and closed for approximately 2,000 cycles.
This,event resulted from contract personnel releasing the tagging orders for the valve prior to completing the administrative review of the WO.
A corrective action document was initiated with a corrective action to review the procedural requirements for review and approval of WO packages prior to releasing equipment."
On October 9, 1987, before completion of testing associated with high pressure safety injection mode selection valve M0-3080, vendor personnel identified that the off-going shift had not properly documented the lifting of wires.
The oncoming shift then verified and documented all lifted wires and completed required testing.
This problem was not immediately brought to Plant personnel's attention by the vendor.
As this problem was a matter of control within the vendor organization and immediately corrected, no other specific corrective actions were taken.
On October 15, 1987 a temporary loss of shutdown cooling occurred due to an improperly installed jumper.
A jumper was to be installed to allow local control for testing of redundant high pressure safety injection OC0188-0026-NL02
~----*~-----~-~--------
w
~ -** ~**
__,.. ~.,*,
Nuclear Regulatory Commission Palisades Nuclear Plant IR 87-027 - Notice of Violation January 28, 1988 4
valve M0-3062, however, the jumper was incorrectly installed on low pressure safety injection (LPSI) valve M0-3008.
This caused M0-3008 to begin cycling open and closed and ultimately resulted in operators securing LPSI pump P-67A due to erratic discharge flow.
Additional information regarding the temporary loss of shutdown cooling was submitted in Palisades Plant Licensee Event Report 255/87035.
In the events listed above, the primary cause of each specific incident was inadequate prejob WO planning and reviews.
As a corrective measure resulting from the October 7, 1987 event, additional reviews of job plans by an Electrical Engineer was required.
However, the WO's were not returned to Planning for additional required reviews.
After the October 8, 1987 event, Plant pers~nnel reviewed the procedural requirements with the vendor regarding proper WO package review and approval prior to releasing equ~pment.
Immediately after the October 15, 1987 incident an Event Report was initiated which directed:
- a.
the stopping of all vendor initiated diagnostic testing
- b.
the review of all in-progress diagnostic testing
- c.
the removal of all jumpers installed in support of diagnostic testing
- d.
the operation of all valves by Control Room personnel which would otherwise be jumpered at a Control Room handswitch.
No furthe.r incidents were noted.
Appropriate management reviewed each event after it was identified.
Actions taken for each event were felt to be adequate at the time.
Therefore, corrective action documents were not initiat~d for each event.
A review of Administrativ*e controls for job plan review of equipment removal from service and bypassing during maintenance activities has also been completed.
Note:
JLB, Jumper Link Bypass, are now identified as Temporary Mods in Administrative Procedure 9.31.
Corrective Actions To Be Taken To Avoid Further Noncompliance
- a.
Consumers Power Company's Correspondence Logging and Commitment Tracking System (CLCTS) addresses the two concerns that we~e identified in this violation and are being tracked as open item (255/87027-02):
In addition, the inspectors determined that the licensee did not have an adequate system to track or keep status of issues identified by the NRC.
Specifically, the licensee did not have:
An established method to verify acceptability of actions planned and/or implemented to close issues identified by the NRC.
OC0188-0026*-NL02
Nuclear Regulatory Commission Palisades Nuclear Plant IR 87-027 - Notice of Violation January 28, 1988 5
Ongoing knowledge of the specific steps and/or documentation required to close issues identified by the NRC.
These weaknesses should be reviewed by the licensee to ensure that timely closure of other NRG identified issues is accomplished.
This is an open item (255/87027-02).
CLCTS is a computer based system which is used to track all correspondence and commitments to and from the NRC.
When a document is received from the NRC, the document is reviewed and all commitments, ie, open items, unresolved items and violations are identified.
Next a department manager and responsible individual within that department are assigned to the commitment.
The document title, date, description of the commitment, responsible manager, assigned individual, due date and any corrective action document that addresses the commitment are all entered into the system.
Weekly reports are generated and sorted by department manager and individual.
These reports are sent to both the department manager and individual for their update regarding open or closed status for the commitment.
A change to the CLCTS is presently underway and is planned for compietion by the end of 1988 which will allow a descriptive status of the work associated with the commitment to be entered and maintained in an active data base file that can be updated at any time.
This will allow the actual status of the commitment to be known and/or updated at any time by calling it up on the system rather than through. contacting the individual responsible.
The closure of a commitment is performed when the responsible individual provides to Nuclear Licensing a document reference that closes the particular commitment.
In addition, commitments tracked as NRC open items, unresolved items or violations_ remain open under seperate category "NRG open" until documentation is received via Inspection Report from the NRC that specifies the item has been closed. It also should be noted that the adequacy of CLCTS for tracking commitments was reviewed in the May 16, 1986 report covering the NRG Region III special task force review and the following st~tements were made:
"First, an item is closed "internally" when CPCo considers it closed.
Secondly, the item is said to be closed "externally" when an NRC inspection report says that it is satisfactorily closed.
When a "closure" is entered into CLCTS, the report number is usually entered, also.
(Less frequently, the specific item number for the open item is entered into CLCTS.)
A spot check of the tracking of over one hundred open items, unresolved items, and violations (in total) from GLCTS was made and compared to Region III records, specifically to determine whether those classified as "externally" closed were in agreement with those listed as closed in the Region III records.
With only one exception all of the remaining items checked were accurately recorded in CLCTS.
For its intended purpose of tracking commitments, the CLCTS works adequately."
OC0188-0026-NL02
Nuclear Regulatory Commission Palisades Nuclear Plant IR 87-027 - Notice of Violation January 28, 1988 6
Based on the above, we believe the existing CLCTS system is adequate for accuractely identifying and tracking open/closed status of commitments.
We also believe the proposed improvements in interim status tracking will provide the additional "ongoing knowledge of the specific steps".
In response to the acceptability of actions planned to close issues identified by the NRC, Consumers Power Company believes this starts with good two-way communication between the inspector and the plant staff.
We believe that type of communication does exist, by evidence of our past actions that have been acceptable.
The particular issue on which the violation is based, is believed to be an isolated case.
Maintaining the present effective two-way communication among the inspectors, resident inspector and plant staff plus the addition of the statusing data base file to the CLCTs should ensure the acceptability of actions planned to close NRC identified issues.
- b.
A memo is being sent to all Plant personnel who supervise contractors.
This memo will review these incidents and discuss measures to assure work performed by contractors is appropriately managed by Plant personnel These measures will include:
- 1.
a review of contractor capabilities to perform work in accordance with Plant procedures
- 2.
a review of contractor knowledge of Plant diagrams,* prints and other documents
- 3.
Plant supervision of contractor activities
- 4.
Problem identification and evaluation within approved Plant procedures.
All Electrical and I&C personnel are to be trained on the potential for inadvertent equipment operation caused by improperly placed jumper links and bypasses.
Procedural controls are being developed which will required WOs involving the use of JLBs to detail the specific operation of the JLB and to receive independent technical reviews in the planning process.
Existing controls for independent verification of JLB installation will remain.
CP has been performing an evaluation of the corrective action process for changes which will enhance the effectiveness of our system.
As part of this review, INPO was requested to evaluate the corrective action process as part of a larger assist visit conducted in January 1988.
Based on the results of this assist visit and our review of the system, CP will evaluate ways to improve the documentation of as-found conditions in corrective action documents.
In addition, CP will clearly establish and define management expectations for initiation of corrective action documents.
These expectations will be defined in the Administrative Procedures.
OC0188-0026-NL02
Nuclear Regulatory Commission Palisades Nuclear Plant IR 87-027 ~ Notice of Violation January 28, 1988 Date When Full Compliance Will Be Achieved 7
- a.
The change in the CLCTS to provide a separate but cross-referenced statusing data base file in order that commitment status can be better updated and.
tracked is planned for completion during 1988.
- b.
Full compliance will be achieved by April 1, 1988 for all actions except those associated with the corrective action system.
Actions associated with the corrective action system will be completed by July 1, 1988.
Violation (255/87027-08 (DPR))
Administrative Procedure 5.01, "Processing Work Requests/Work O~ders",
specifies that work orders will receive a review by the Work Planner, Maintenance Supervisor and others to ensure all necessary documents, instructions, approvals and parts were identified; that necessary inspection and/or testing were required or specified; and that Quality Control (QC) requirements were included.
Contrary to the above, the licensee failed to review Work Order 24500885 that was written in 1985 but issued in 1987, and pertained to a preventive mainten-ance activity for the diesel generator crankcase exhaust blower motors.
As a result, required procedures were omitted from the work packages, the motor was not tested prior to disassembly, and QC was not notified prior to starting the maintenance activity.
Corrective Actions Taken And Results Achieved During the performance of WO 24500885, on October 26, 1987 an NRC inspector identified that the WO package did not contain or reference two applicable procedures.
When the anomaly was identified, maintenance activities were stopped.
However, the job had progressed such that pre-motor disassembly resistance tests were not completed and QC personnel not notified as required by procedure.
Prior to re-initiating maintenance activities, the WO was replanned to current standards in accordance with Plant Administrative Procedure 5.01, "Processing Work Requests/Work Orders".
This replanning included the addition of mainten-ance procedures; MSE-E-12, "Cable Terminations" and SPS-E-7, "Insulation Resistence Testing of Electrical Equipment" to the WO package and appropriate supervisory reviews.
The preventive maintenance activity was then completed without incident.
The failure to replan the WO was the result of a personnel error.
The involved individual recognized the need for replanning the WO, however, failed to follow up.
This error was fostered by the lack of formal direction available regarding "vintage" WO job plans.
Since the event, all WOs originated in 1985 have been replanned to the current standards or have been put in "Planning hold" awaiting replanning.
OC0188-0026-NL02
Nuclear Regulatory Commission Palisades Nuclear Plant IR 87-027 - Notice of Violation January 28, 1988 8
On December 1, 1987 Engineering and Maintenance Department Policy Memo 87-009 was issued.
The intent of this policy is to provide job planning direction for all Engineering and Maintenance personnel regarding "vintage" WOs.
This policy states *the effective December 1,.1987 planned WOs, nine months old or greater, shall be reviewed for adequacy of job planning in relation to current standards prior to scheduling the job. All Electrical, Mechanical Maintenance and Instrumentation and Control personnel involved in the job planning process have been trained on this policy and its int.ent to improve management of maintenance activities at the Plant.
Through this policy, and the Plant target to keep the once elevated WO backlog below 300 open WOs, the amount of outstanding "vintage" WOs will be signifi-cantly reduced and the probability of recurrence minimized.
Corrective Actions To Be Taken To Avoid Further Noncompliance No further corrective actions are planned at this time.
Date When Full Compliance Will Be Achieved All corrective actions were completed December 22, 1987 Kenneth W Berry Directorw Nuclear Lic~nsing CC Administrator, Region III, NRC NRC Resident Inspector "."' Palisades OC0188-0026-NL02