ML18058A272
| ML18058A272 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/06/1992 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9203130231 | |
| Download: ML18058A272 (6) | |
Text
. consumers PmNer POWERINli MICHlliAN'S PROliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 March 6, 1992 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT NO. 91026 GB Slade General Manager NRC Inspection Report No. 91026, dated February 5, 1992, provided the results of an assessment that focused on the completeness and accuracy of information-provided to the NRC regarding licensed activities. The NRC staff emphasized in this inspection report, and at other occasions, the need to be able to rely on both oral and written communication.
We fully agree that all communications of significant information must meet with this expectation.
Consumers Power Company's reply to the notice of violation is attached.
$fi*_,:::Jc~
Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades
- Attachment 3130'"131 920306 920
~ ' 05000255 PDR ADOC~
PDR G
1-CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.
Sworn and subscribed to before me this 0 <<-day of ~, 1992.
et'/ERL V ANN AIJERY NOTARY PUSllC-J~CKSON courm
~~'
MY roMM1SSION EXPIRf.S 12*7*92
[SEAL]
ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 91026 March 6, 1992 3 Pages
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 91026 1
- 1.
10 CFR 50.9 requires, in part, that information provided to the Commission
- by a licensee sha11 be complete and accurate in. a11 material respects.
Contrary to the above, inaccurate fnformation was provided to the Commission in that:
- a.
Information pro_vided during the October 15, 1991 Enforcement Conference regarding seismic analysis of piping, was inaccurate in that it indicated Consumers Power Company recognized early in the Steam Generator Replacement Proj~ct that the seismic calculation basis described in the.Final Safety Analysis Report (FSAR) could not be met.. *
.(255/91026-0lA)
Background
The {nformation provided to the NRC ai the October 15, 1991 Enforcement Conference, in reply to item 09 from ~RC Inspection Report No. 91202 stated, "At the beginnirig of the SGRP it was recognized that the seismic calculation basis in the FSAR would be difficult to meet literally because no plant design data existed for elevations in the containment above el 649'.***" This
.statement was in a summary; paraphrasing a response to item 09, provided by Bechtel to Consumers Power Co~pany.. Bechtel was the ~ngineering contractor for the Steam-Generator Replacement Project {SGRP).
Bechtel's response to item 09 concluded that t~etf cal~ulation.met all design parameters ~pecified by CPCo and Bechtel design documents, and met the criteria agreed upon by CPCo and the NRC.
This criteria included the FSAR crit~ria. This conclusion was not clearly stated i.n the Enforcem~nt Conference information package.
The NRC concluded that conflicting information existed, with the potential for it-being considered a material false statement, and on November 20, 1991.
conducted a follow-up inspection. 'During t~is follow-up inspection it was
- determined that no material false statement exi ste_d, but. the NRC al so concluded the information provided them, at the Enforcement Conference, did not represent an accurate statement.
Reason for the Violation Personnel errors were made.
The individual who prepared the discussion of the deviation (IR 91202, item 09) paraphrased a response provided by Bechtel that
- had responded to the NRC special engineering inspection issues.
The wording of the paraphrased*response was not entirely cl~ar and the in~house reviewers did not ~hallenge the wording.
Corrective Steps that have been taken toward the*Results Achieved Awareness of the requirements of 10 CFR 50.9 has been a* topic of several discussions with the plant staff to emphasize _the need to communicate both completely and accurately with the NRC.
Meeting minutes of the IR 91026 exit meeting were routed to ~anagers and superintendents.
Routing of the inspection report and our reply to*the Notice of Violation will also pemade to managers and superintendents at Palisades and our General Office support
- staff.
Corrective Steps that will be taken to avoid further violations.
By May 1, 1992, guidelines for improving the quality of licensing submittals will be issued. These guidelines will include expectations to help ensure accuracy and tompleteness.of information~
Date when Full Compliance will be Achieved Full compliance was achieved on ~ovember 20, 1991 when the accurate information was provided to the NRC staff.
2
- 1.
10 CFR 50.9 requires, in part, that information provided to the Commission by a licensee sha77 be complete and accurate in a77 material respects.
Contrary to the above, inaccurate information was provided to the Commission in that:
- b.
Information provided in the licensee's response to the NRG date.d December 9, 1991, to the Notice of Violation dated November 14, 1991, regarding the start testing of electrical equipment upon return to service, was incomplete in that it did not account for the instructions which were posted on 2400v cub_icle doors to test energize equipment after racking in breakers.
(255/91026-018)
Background
NRC Inspection Report No.. 91017, which identified a violation concerning the inoperability of a containment spray pump, contained a chronology of the containment spray pump operability in 1991.
In this chronology it was stated that two shift supervisors were questioned, by the NRC inspector, about returning equipment to an operable status after the equipment breakers had been taken out of service.
The shift supervisors replied that the components
- are always test started. Thii requires clarification in that in_some plant configurations test starting equipment is not al~ays feasible as plant conditions may not support operation of the equipment.
Because of this the operations staff relied on Administrative Procedures and Operating Procedures to ensure equipment operability before entering an operating condition when the equipment is required to be operable. These plant administrative
controls, during the time of the containment spray pump inoperability; were not adequate to provide this operability assurahce in that the procedures did not always lead the operators through an operability verification sequence.
Corrective action~ have bee~ put in place to ensure that equipment is test started to verify operability prior to the equi prrient being re qui red operable.
These corrective actions were discussed in the Enforcement Conference and in our December 9, and December 13, 1991 replies to the Notice of Violation.
3 In our December 9, 1991 submittal we stated that, "It ~as generally believed that racking the breakers out and in and removing and reinstalling the closing coil and cbntrol power fuses did not warrant an o~erability verification since the activity was considered r6utine." This statement was discussed internally prior to th_e submittal but not recognized as being inaccurate. _ It was, however, a generalization and an ina~curate statem~nt of fact. A revised reply correcting the inaccuracy was submitted on December 13, 1991.
Reason for the Violation Personnel errors by both the preparer and reviewers of the December 9, 1991 submittal were made.
The reviewers did not challenge the wording which made an ina~curate conclusion about operating practi£e.
The conclusion was not
_fully verified.
Corrective Steps that have been taken and results achieved The December 9, 1991 reply to the Notice of Violation was re~ised and resubmitted on December 13, 1991.
Awareness of the requi rem'ents of 10 CFR 50.9 has been a topic of several discussions with the plant staff to emphasize the need to communicate both completely and accurately with the NRC.
Meeting minutes of the IR 91026 exit meeting were routed to managers and superintendents.
Routing of the inspection report, and our reply to the notice of violation will also be made to managers and superintendents at Palisades and our General Office support staff.
Corrective Steps that will be taken to avoid further violations By May 1, 1992 guidelines on improving the quality of licensing submittals will be issued. These guidelines will include expectations to help ensure accuracy and completeness of information.
Date when Full Compliance will be Achieved Full compliance was achieved on December 13, 1991 with the submittal of the revised reply to the Noti~e of Violation.