ML18058A507
| ML18058A507 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/05/1992 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206150473 | |
| Download: ML18058A507 (6) | |
Text
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consumers Power POWERING MICHIGAN"S *PROGRESS Palisades Nuclear Plant:
27780 Blue. Star Memorial Highway, Covert. Ml 49043 June 5, 1992 Nudear Regulatory Commission Document Control Desk Washington, DC *2osss GB Slade Ge~ral Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT - REPLY TO NOTICE OF VIOLATION~ NRC INSPECTION REPO~T No. 92015 NRC Inspection Report No.. 92015, dated May 8, 1992 provided the results of the routirie monthly inspection and identified an apparent violation of NRC requirements pertaining.to procedural rion-compltance.
- Our reply to the Noiice of Violation is provided in the attachment to this letter..
CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment 9206150473 920605 PDR ADOCK 05000255 G
CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this submittal are tr~thful and complete.
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Sworn and sub.scribed to before me this !;;
day of ~ 1992.
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[SEAL]
Linda L. Bumb, Not~ry Public Jackson County Michigan My commission expires 7-S-:.-93
ATTACHMENT Co~sumers Power Company Palisades Plant Docket 50-255.
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT No. 92015
- June 5, 1992 -
3 Pages
1 REPLY TO NOTICE OF VIOLATION Violation 10 CFR 50, Appendix 8, Criterion V, requires that activities affecting quality.
sha71 be prescribed by documented instructions, procedures, or drawings, *of a fype appropriate to the circumstances and sha77 be accomplished in accordance with those instructions, procedures, or drawings..
Contrary to the above:
- a.
On February 25, 1992, while removing the reactor vessel head, the licensee failed to adhere to the requir~ments of procedure RVG-M-2, "Removal of Reactor Vessel Head," by not using a calibrated load ce11 (Step 3.7.2). and by exceeding the prescribed procedural maximum allowable lift weight (Step 5.19.15).
- b.
On March 30, 1992, while removing the Upper Guide Structure (UGS), the licensee failed to a.dhere to the requirements of procedure RVJ.,.M"-1, "Removal of Upper Guide Structure," by not using a calibrated load c~77 (Step 3.2.2) and by exceeding the prescribed procedural maximum allowable lift weight (Step 5.3.4).
- c. *On March 27, 1992, the licensee experienced a* Joss of shutdown cooling when testing the supply power breaker to "JC" bus, due to failure to adhere to Administrative Procedure 4.02, "Control of Equipment Status," Section J0.3.J., by cycling the bus supply breaker in the "Test" position.
- d.
On April 2, J992, the licensee experienced an inadvertent Safety Injection when technicians failed* to insta77 test equipment in accordance with Technical Specification Test RT-J3A, "Normal Shutdown Sequencer Test - Left Channel," Section 5.
- e.
On April 4, 1992, the licensee experienced an inadvertent actuation of a Shutdown Sequencer while perf'orming*Special Test T-325, "Timing of Emergency Diesel Generator J-1 Start*sequence," when an operator failed to para17e1 an alternate power supply to safeguards bus "JC" in accordance with Standard Operating Procedure 22, "Diesel Generator Operability," Section 7.5.4 prior to opening the diesel generator output breaker.
Reason for the Violation The root causes of the procedure violations are attributed *to a lack of clear understanding by Plant personnel and contractors of the need for strict compliance with the Plant procedures.
Two additional contributing causes involve inadequate management communi.cation of expectations and inadequate supervisory follow-up to assure expectations were being met.
2 As a result of an independent review conducted in January 1992, Palisades management became aware of the apparent 1ack of procedural compliance, and the employees lack of a clear understanding of management expectations regarding procedur.al compliance.
Palisades management has been actively developing
- remedial pl ans to imp rove in the area of procedural compliance.
Because these improvements deal with a fundamental principle to which the plant works, the changes which are necessary to correct the problem are being taken very seriously and deliberately to assure that all levels of plant personnel receive clear and specific direction.
In addition, feedback from the working levels is being c~nsidered and incorporated into the process of communicating management expectations to assure they are properly understood.
In addition, during the 1992 refueling outage, plant management became*
concerned with the increased number of inadvertent equipment actuations.
The Nuclear Performance A~surance Department (NPAD) was requested to perform a review of the causes of the inadvertent equipment actuations and to look for trends.
The results of the NPAD review revealed several common contributory factors which are discussed below:
- a.
Instructions, both verba i and written, were not adequate to control the job.
- b.
Coordination between and among workers and groups should have been better.
- c.
Existing procedures were used in unusual or special circumstances.
Correctiva Actions* and Resul~s Achieved Corre~tive actions which are currently in progress to improve in these areas are summarized below:
A.
Clearly communicate management expectations to all employees. and contractors.
- 1.
A lettei from the Plant General Manager has been issued to communicate the following:
- a.
Procedural compliance is mandatory.
- b.
Supervisory personnel are to increase their time spent observing work in the field to ensure compliance.*
- 2.
A task force of. supervisory personnel has been established to define and formalize management's *expectations and to communicate these expectations to all employees and contract6rs. This action is scheduled for completion in March 1993.
B.
Improve work instructions to maintenance personnel by developing work.
planning expectations and standards to achieve *consistent work plans.
These actions are scheduled for completion by December 1992.
C.
Maintenance Department work expectations and standards are scheduled to be developed by July 1992.
D.
The Maintenance Department has developed job ob~ervation expectations for their first and second line supervision to hav~ them monitor*
working level compliance with management expectations. These expectations are scheduled for implementation by October 1992.
E.
The Operations Department is performing an assessment of the current conduct of operational activities with respect to procedure usage.
- This assessment is scheduled for completion by December 1992.
3 F.
An improved process for verification and validation of surveillance procedures has been implemented.. In addition, special test procedures and technital specifications test procedures will receive an additional sehior reactor operator review prior to performance.
Corrective Action to Avoid Future Nori-Compliance The corrective actions described above are sufficient to avriid future non-compliance, therefore, n~ additional corrective actions are proposed.
Each of the occurrences cited have been reviewed on plant corrective action documents and actions assigned to deal with the individual circumstances involved.
Most of these actions have been identified in prior Licensee Event Reports submitted to the NRC.
The actions specified in this response deal with the generic aspects of the fi~e occurrences.
Date of Full Compliance.
Full compliance will be achieved by March 1993.
- . *- -