ML18057B414

Revises 911209 Response to Violation Noted in Insp Rept 50-255/91-17 Issued on 911114.Util Elected to Pay Civil Penalty in Amount of $50,000 Via Check Dtd 911122.Bank Records Indicate Check Cashed on 911129

ML18057B414
Person / Time
Site:	Palisades
Issue date:	12/13/1991
From:	Hoffman D, Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9112190003
Download: ML18057B414 (6)

Text

GB Slade General Manager Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 December 13, 1991 Director, Office of Enforcement Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - REVISED REPLY TO NOTICE OF VIOLATION; NRC INSPECTION REPORT No.91-017 By letter dated December 9, 1991 Consumers Power Company responded to the Notice of Violation issued on November 14, 1991 which resulted from Inspection Report 91-017. This letter was entitled "Response to Notice Of Violation" contrary to the request of the NRC in its November 14, 1991 letter that the response be titled "Reply to Notice of Violation." Furthermore, the letter was not addressed to the Director, Office of Enforcement as requested by the November 14, 1991 letter, but only to the Document Control Desk. In addition, our December 9, 1991 letter failed to provide a clear admission or denial of the violations. Our response to this question is that we admit that the violations did occur. Also, the final paragraph in our discussion of "Reasons for the Violation" for Violation A has been revised to more clearly explain the root cause of the violation and associated corrective actions.

Finally, Consumers Power Company elected to pay the $50,000 civil penalty associated with this violation, however, we failed to submit the payment with the required letter addressed to the Director, Office of Enforcement.

Consumers Power Company check no. 24562, dated November 22, 1991, drawn on Manufacturers Bank of Ann Arbor, was addressed to the Treasurer of the United States, US Nuclear Regulatory Commission, Washington, DC. The check memorandum wording was "Palisades Plant Civil Penalty re: NRC Inspection Report 50-255/91017 dated November 14, 1991." Bank records indicate the check was cashed on November 29, 1991.

We apologize for any inconvenience our oversight may have caused.

~~

General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades 9112190003 911213 ££01 PDR ADOCK 05000255 Q PDR A CMS ENERGY COMPANY , ( ,

CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.

By _.;.....__ _ _ _ _---\---i'l........,..---

Davi d P Hoffman, V Nuclear Operat Sworn and subscribed to before me this ..1.1_ day of December 1991.

[SEAL]

LeAnn Morse , Notary Public Van Buren County , Michigan My commission expires June 6, 1994 J:eANN MORSE, NOTARY PUBLIC

VAN BUREN COUNTY, STATE OF MICHIGAN MY COMMISSION EXPIRES 06*06'*94

ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 REVISED REPLY TO NOTICE OF VIOLATION 91-017 December 13, 1991

• 3 Pages

REVISED REPLY TO NOTICE OF VIOLATION NOTE: The corrective actions associated with both violations are similar and are discussed in the response to Violation B.

Violation A Technical Specification 6.8.1.a requires. that written procedures be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, "Quality Assurance Program Requirements."

Regulatory Guide 1.33, Appendix A, "Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," paragraph 3 requires, in part, that the licensee establish and follow written procedures for startup, operation and shutdown of safety-related activities, including instructions for energizing the Emergency Core Cooling System and the Containment Cooling System.

Palisades Plant Procedure No. GOP 2, "Plant Heatup (Cold Shutdown to Hot Shutdown}," Revision 10, implements the requirements of Technical Specification 6.8.1.a and Regulatory Guide 1.33, Appendix A.

Contrary to the above, as of March 10, 1991, the Licensee failed to establish adequate written procedures to energize the containment spray pumps, which are a part of the Containment Cooling System, and the high pressure safety injection pumps, which are a part of the Emergency Core Cooling System.

Specifica77y, Procedure No. GOP 2, "Plant Heatup (Cold Shutdown to Hot Shutdown}," Revision 10 which the Licensee uses to control system restoration during startup, did not have a requirement to test start the containment spray pumps and the high pressure safety injection pumps to verify operability after the breakers were racked in and appropriate plant conditions established.

Admission or Denial of Violation We admit that the violation did occur.

Reasons for the Violation When the Plant was placed on shutdown cooling, the discharge valves of the containment spray pumps (CSPs) were closed. This was done to avoid backflow in the containment spray system since the containment spray system and the shutdown cooling system share common piping. Furthermore, the CSPs were rendered inoperable by racking out the breakers and removing the closing coil fuses and the control power fuses. Similarly, the high pressure safety injection (HPSI) pumps were rendered inoperable (in the same fashion as the CSPs) when the primary coolant system (PCS) temperature was less than 260°F, as required by Technical Specification 3.3.2.g.l.a.

When the Plant began heatup, the CSPs were required to be operable when the PCS temperature was greater than 325°F. To make the CSPs operable, the breakers were racked in and both sets of fuses were installed, however, the pumps were not test started or "bumped" to verify operability.

The HPSI pumps were required to be operable when the PCS temperature was greater than 325°F. As with the CSPs, the HPSI pump breakers were racked in and both sets of fuses installed, however, the pumps were not test started or "bumped" to verify operability.

Administrative procedures and operating procedures did not specifically require that equipment should be "bumped" or test started following the racking out and in of breakers or the removal .and reinstallation of fuses.

The only instructions were placards placed on the 2400V breaker cubicle doors that stated equipment must be test energized each time the breaker is racked in. No similar instructions were given for the removal and reinstallation of the fuses.

Violation B Technical Specification 3.4.1 requires, in part, that the reactor sha77 not be made critical unless the equipment associated with diesel generator 1-1 is operable, including Containment Spray Pump P-54C.

Technical Specification 3.4.2 requires, in part, that during power operation, one of the components listed in Specification 3.4.1 may be inoperable provided that the corresponding redundant components shall be tested to demonstrate operability. If the inoperable component is not restored to operability within 7 days, the reactor shall be placed in a hot standby condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If the inoperable component is not restored to operability within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Contrary to the above, the reactor was made critical and was in power operation during the period of March 10, 1991 through March 25, 1991, and from March 26, 1991, until May 23, 1991, while containment spray pump P-54C was not operable. Although each period exceeds seven days, redundant component testing was not performed and the reactor was not placed in a hot standby condition nor subsequently in cold shutdown within the applicable time periods.

Admission or Denial of Violation We admit that the violation did occur.

~*

Reasons for the Violation As indicated in the response to Violation A, since the containment spray pumps were not test started or "bumped" when they were returned to service, it was unknown that containment spray pump P-54C was inoperable from March 10, 1991 until May 23, 1991, therefore, the compensatory measures of Technical Specification 3.4.2 were not implemented.

Corrective Actions Taken and Results Achieved The following corrective actions have been taken:

1. Administrative Procedure 4.02, "Control of Equipment Status", has been revised to include specific breaker testing requirements. This action was completed on October 7, 1991.

2. General Operating Procedure (GOP) 2 has been revised to require that the containment spray pumps and the high pressure safety injection pumps be test started to verify operability. This action was completed on October I4, I99I.

3. The members of the Plant Corrective Action Review Board (PCARB) have I i

been trained on this event, specifically regarding more detailed assessment of equipment operability. This action was completed on October 20, 1991. Additionally, the information pertaining to this event has been incorporated in the Corrective Action training program.

This action was completed on October 8, 1991.

Corrective Action to Avoid Future Non-Compliance I. Remote and local indication of closing coil power for safety related 2400/4I60V solenoid operated breakers for Buses IA, IB, IC and ID will be installed. This will provide the operator with positive indication as to whether or not the closing coil circuit and the control power circuit is energized. This action is scheduled for completion in the I992 refueling outage.

2. Remote and local indication of closing coil power for 2400/4I60V solenoid operated breakers for Buses IE, IF and lG will be installed.

Breakers on these buses are non-safety related, therefore, delaying the installation of these indicators is not a safety significant issue.

This action is scheduled for completion in the 1993 refueling outage.

Date of Full Compliance Full compliance has been achieved .