ML18057B220
| ML18057B220 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/12/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9108220115 | |
| Download: ML18057B220 (3) | |
Text
consumers Power POWERINli
.. MICHlliAN'S PRDliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial -Highway, Covert, Ml 49043
- August 12, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 GB Slade.*
General Manager DOCKET 50~255 - LICENSE DPR PALISADES PLANT - REPLY TO NOTICE OF VIOLATION CONCERNING THE FAILURE TO SUBMIT AN LER TO THE NRC WITHIN 30 DAYS Nuclear Regulatory Commission (NRC) Inspection Report 91-012, dated July 12, 1991, documented the results of a routine safety inspection and reported the issuance of a violation for the failure to submit an Licensee Event Report (LER) to the NRC within the prescribed 30 day period.
The following is Consumers Power Company's response to these violations.
Violation 50-255/91012-01 10CFRSO, Part 73.a.2.iv requires that any event or condition that resulted in manual or automatic actuatio~ of any Engin~ered Safety Feature (ESF) shall be reported by the licensee as a Licensee Event Report (LER).
10 CFR 50, Part 73.d requires that LERs be submitted to the U.S. Nuclear Regulatory Commission as specified in 10 CFR so; Part 4, within 30 days of discovery of a reportable event or situation.
.Contrary to the above, an LERwas not submitted within the prescribed 30 day period (by March 26) for a February 24, 1991, automatic ESF actuation - an unplanned auto-start of the 1-2 diesel generator.
The auto-start occurred when low voltage was sensed on*the "C" safeguards bus during the integrated performance of Q0-21, "Auxiliary Feedwater System Valves, Inservice Test Procedure," and T-297, "Diesel Generator 1-1 Load Reject."
. This is a Severity Level IV violation (Supplement I).
REASON FOR VIOLATION When special test T-297, "Diesel Generator 1-1 Load reject," was in progress, an unanticipated undervoltage condition occurred which resulted in the start of the 1-2 diesel generator. A plant corrective action document was initiated to determine the root cause and corrective actions.
As part of the required A OHS ENE'RGY COMPANV
initial management review of the occurr~nce and assignment of re~ponsibilities
- for follow up actions, the event is reviewed for NRC reportability. The event was ~etermined reportable per 10CFR50.73 as an event or condition that resulted in manual or automatic actuation of an engin.eered safety feature.
The corrective action document with the reportability determination was then transmitted to the plant Lic~nsing Section. The requirement to transmit a copy of corrective action documents that have been determined to be reportable is stated in the plant's Administrative Pro.cedure 3.03, "Corrective Action."
Until this occurrence~ this has proved to be a reli~ble method of notification. For this event however, the licensing section did not receive notice that a 30 day reportable event had occurred, and no Licensee Event Report was initiated and sent to the NRC.
A contributtng cause to the violation is logistics. Prior to September 1990~
when the plant licensing and corporate licensing departments were reorganized
- at the plant ~ite, the Corrective Action Coordinator reported to the Technical Engineer who was responsible for the initiation bf Licensing Event Reports.
The Technical Engineer also attends the corrective action review board (CARB) daily meetings, where corrective action documents are reviewed, and determines NRC reportability requirements.
In addition to this, the Technical Engineer and Corrective Action Coordinator office areas were in close proximity and corrective action documents were hand carried between offices. Following the September 1990 reorganization, the Licensing Administrator assumed the responsibility for submittal of LERs.
The Licensing Administrator's and Corrective Action Coordinator's offices are in ~eparate buildings and documents are transmitted by interoffice mail versus being hand carried as was previously done.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED As a result of the NRC Resident Inspector's periodic reviews to follow up telephone notifications made by the Licensee, the inspector questioned what follow up actions had been taken on the Licensee's 10 CFR 50.72 notification p~rtaining tb the unplanned auto start of the 1-2 diesel generator.
Follow up reviews to this question by the plant led to the discovery that an LER had not been submitted and a plant corrective action document was initiated to determine root cause and follow up actions.
An LER (91-010~ was subsequently submitted to the NRC on June 30, 1991.
CORRECTIVE ACTIONS TAKEN TO AVOID FUTURE NON-COMPLIANCE A review and evaluation of Plant Administrative Procedure 3.03, "Corrective Action," wa~ conducted to determine how the communications between the Corrective Action Coordinator and the Plant Licensing Administrator can be strengthened to assure that LER's are written for reportable events.
Minor clarifications will be incorporated into a future revision to Administrative Procedure 3.03.
In addition to the sending of copies of corrective a~tion documents that are reportable to the Plant Licensing Administrator, the Corrective Action Coordinator is now verbally notifying the Plant Licensing Administrator that a reportable event has occurred.
.Alio a future office telocation will place the Licensing Section in the same building as* the. Regulatory Compliance Section, which should increase communi"catfonsbetween the two groups.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Ful1 compliance has been achieved.
~:J, Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades