ML18058A508
| ML18058A508 | |
| 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 9206150483 | |
| Download: ML18058A508 (11) | |
Text
. consumers Power POWERINli lllllClllliAN'5 PROliRE55
.. Palisades Nucle.ar Plant: 27780 Blue Star Memorial.HighWl!Y* Covert,.1\\111 49043 June 5, 1992 Nuclear Regulatory Commission Document Control Deik Washington, DC 20555 GB Slade General Manager DOCKET 50-255 - LICENSE DP~ PALISADES PLANT - REPLY TO NOTICE OF VIOLATION; NRC INSPECTION REPORT No. 92004 NRC Inspection Report No. 92004, dated May 1, 1992, provided the results of an inspection of previously identified environmental qualification {EQ) concerns and the implementation of Regulatory Guide {RG) 1.97 at the,Palisades Plant.
The inspection report identified two apparent violations-of NRC requirements~
On May 29, 1992, Mr. Frank Jablonski-of the NRC Region III staff granted a one week delay in replying to the Notice of Violation..
An additional document search concerning proposed violation 9200~-0l revealed that the item, identified as violation 255/86032-020 in Inspection Report 92004, was never previously identified as a violation,. but was identified as
~n Open Item.
As:discussed in the enclosed reply, Consumers Power Company disputes the conclusion that a violation of Appendix B, criteria XVI, exists.
- .x::S~g~*
Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC _Resident Inspector - Palisades
- Attachment 9206150483 920605 PDR ADOCK 05000255 0
CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.
4 Sworn and subscribed to before me this r2__ day of r
~:/.~
Linda L. Bumb
- Notary Public Jackson County, Michigan.
MY.commission expires 9-~-:93 1992..
[SEA.L]
I 1*
ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT No. 92004*
June 5, 1992 8 Pages
I I
1 REPLY TO NOTICE OF VIOLATION Violation 1 10 CFR 50, Appendix B, Criteria XVI require that measures shall be established
-to assure that conditions adverse to quality are promptly identified and corrected.
- Contrary to the above, Consumers Power Company failed to perform corrective action concerning a previously identified Notice"of Violation issued in Inspection Report Number 50-255/86032(DRS}, violation 255/86032-02D(DRS},
where the licensee was to revise the applicable Periodic Activity Control
- sheets to provide steps to analyze oi7 and inspect sleeve-bearings for 2400
- Volt motors.
CPCo believes that the referenced item from inspection report 86032 is not a violation.
Basis for Disputing Violation NRC Inspection Report (IR) 86032, dated February 17, 1986, identified deficiencies in the EQ program as "Discrepancies in the PACS Listings for Positiori Switches and Motors" in Section 4c of the inspection report. This section discu~sed the deficienties in the Periodic Activity Control Sheets (PACS) regarding the inspection of the sleeve bearings of EQ motors if the motor oil appeared discolored when inspected.
In the inspection report, the NRC noted that CPCo committed to revising the PACS "... to provide steps to
- analyze the oil and inspect the sleeve bearings when the oil drained from the motor appeared discolored... " The NRC also noted in the inspectiori report that"... the apparent lack of control of the above activities had not compromised the EQ of the motors... " The inspection report summary and the text in Section 4c, identified these discrepancies as "open items" and not as "potentially enforceable items."
On A~ril 20, 1987, CPCo responded to IR 86032, and addressed the o~en item identified as 86032-02, stating that corrections to the PACS for the EQ motors would be completed by May 15, 1987.
In March 1987, CPCo issued an internal corrective action document, Action Item Record {AIR) A-PAL-87-20, to address*
the issue of correcting the PACS to perform 6il analysis and inspect the sleeve bearings as discussed in IR 86032.
A-PAL-87-20 was completed on May 18, 1987.
The subject Periodic and Predetermined Activity Control {PPAC) sheets had been revised to require that the oil drained from the motors ~ould be sampled and analyzed and must meet certain acceptance criteria defined in the Electric Power Research Institute {EPRI) Lubrication Guide.
Attached to the revised PPAC sheets was correspondence that stated "... if the results come back above what they should be, per our EEQ {i.e., EQ) program, the sleeve bearings may need to be inspected...
11 This i.ndicates that an' engineering judgement was made related to the validity of initiating an_ inspection of the motor sleeve bearings based solely on the motor oil showing discoloration.
This judgement concluded that oil analysis results that. were within the EPRI Lubrication Guide acceptance criteria was a more appropriate and objective indicator of sleeve bearing wear than oil di~c6loration, which is a more subjective determination.
For this.reason the specific requirement to inspect.
the sleeve bearings was not included in the revised PPAC; however, this change in commitment was never identified to the NRC.
The information contained in A-PAL-87-20 was apparently not retrieved or provided to the NRC inspector during the 92004 inspection.
We have recently forwarded the information to*
the inspector.
In a letter dated June 16, 1988, the NRt i~formed CPCo of an Enforcement Conference pertaining to EQ issues identified as enforceable items in IR 86032.
On June 24, 1988, an Enforcement C6nference was held at the Region III headquarters.
The information presented by CPCo i_nd i cates that Open Item
- 86032-02 was not discussed in the Enforcement Conference as a poteritial violation.. By letter. dated July 7, 1988, CPCo provided information,*
concerning the qualification of certain equipment, that the NRC req~ested in the June 24, 1988 Enforcement Conference.
The information also made no
- mention of the.oil analysis issue 86032-02.
- By letter dated November 23, 1988, the NRC transmitted a Notice of Violation
- (NOV) and Proposed Imposition of Civil penalty regarding the environmental qualification of electrical equipment deficiencies at the Palisades Nuclear Plant.. The Notice of Violation.made no mention of the oil analysis issue, Open Item.86032-02.
By letter dated December 23, 1988 CPCo responded to the NOV. *Once again, our response made no mention of the oil analysis issue 86032-02.
By letter* dated January 24, 1989, the NRC acknowledged the receipt of our December 23, 1988 letter.
Our evaluation-of the Open Item 86032-02 has led to the determination that.the issue concerning the oil analysis and sleeve bearing inspection of EQ motors has never been identified as a violation. Therefore, CPCo disputes the conclusion that a violation of Appendix B, criteria XVI, presently exists as no condition existed that was adverse to quality.
We do conclude that we failed to properly inform the NRC of our intent to change our commitment.
It is our understanding that a failure to complete a commitment could result in a Notice of Deviation in accordance with 10 CFR, Part 2, Appendix C,Section V, subsection H.(2). Accordingly, we provide the following response.
Corrective Actions and Results Achieved-A new corrective action document was initiated to ensure completion of the open item (IR 86032-02).. This new corrective action document required that the 2400V motor PPACs be revised.
The PPACs have been revised to alert the operator to note discoloration of the oil removed from.the motor.
Furthermore, the PPAC also directs the op~rator to inspect the drain plug of the motor oil reservoir for the presence of metal chips. If any metal chips are observed, the PPAC directs the operator tq initiate corrective action to inspect the motor sleeve bearings.
In addition an oil sampling program for safety related equipment has been in pl~ce for approximately three years*and is administered through an Engineering Manual procedure EM-27, "Lube Oil and
3 EHC System Chemistry." This sampling program is independent of the referenced PPACs and samples oil in the safety related equipment, including the 2400V motors. *Analysis results from samples obtained over.the past three years for the 2400V motors have not indicated any problems with oil discoloratiori or the presence of metal chips.
Corrective Action to Avoid Future Non-Compliance At the time the corrective actions associated with the original AIR were being implemented, there were no procedurally controlled licensing commitment tracking practices to assure the commitments had been properly resolved.
Palisades Administrative Procedure (AP) 3.14, "Commitment Tracking System,"
has been established. as a management tool which will provide increased confidence in the completion of and compliance with commitments.
The commitment tracking system requirements are* integrated into admini strati ve procedure (AP) 3.03, "Corrective Acti6n," and AP 3.02, "Action -Item Recofdj" to provide a separate verification by the commitment tracking coordinator that commitments have been properly met.
Date of Full Compliance Full compliance has been achieved.
Violation 2 10 CFR 50.49, paragraphs (f) and (g}, require that electrical equipment important to safety must be qualified by test-and analysis. prior to the EQ deadline of November 30, 1985.
Contrary to the above, Consumers Power Company failed to qualify various
- configurations of Raychem heat shrink tubing used in electrical splice.
assemblies for 10 CFR 50.49 designated applications inside containment cable penetrations, prior to the EQ deadline of November 30, 1985.
Introduction The.violation actually stems from fo~r distinct issues which are discussed in the body of the inspection report.
The four issues are identified as follows:
- Eight Raychem cable splices were not qualified prior to the EQ deadline of November 30, 1985.
The licensee reported this event. However, the LER was issued 75 days after the event was identified as reportable.
I 4
The licensee failed to perform an adequate engineering review during a previously identified deviation report (D-QP-88-003), which reworked splices on some of the same equipment outside containment, but failed to
-fo17ow through and_extend the review to the containment penetrations.
If an adequate engineering review would have been performed at that time, this occurrence may have been prevented.
The licensee failed to report the discovery of non-qualified Raychem cable splices identifi_ed in the 1988 deviation report via an LER.
Each of the issues will be disc~ssed separately in the followfng paragraphs.
Eight -Raychem cable splices were not qualified prior to _the EQ deadline of November 30, 1985.
Reason for the Violation The root ~ause of the unqualified Raychem:splices being in place after the environmental qualification (EQ) deadline of November 30, 1985 is that modification and design controls were inadequate during 1981 when the equipment was either installed or modified. This issue was previously addressed in 1 icensee event report (LER)91-002, _dated January 28, 1991.
Corrective Actions and Results Achieved The corrective action for this portion of the violation is addressed in LER 91-002.
The corrective action included modifying the envi'ronmentally non-qual ified splices on the reactor head vent valve, the shutdown cooling valves and, the hydrogen recombiners.
Furthermore, the administrative controls_ for the modification process were reviewed.
No further corrective action is required as a result of this violation.
Corrective Action to Avoid Future Non-Compliance The admiriistrative controls.that are currently in place for the modification process are considered adequate to. prevent this condition from re-occurring and, therefore, no furth~r correcti~e action i~ required as a result of this violation.
Date of Full Compliance Full compliance has been achieved.
Discussion of Contributing Factors The licensee reported this event.
However, the LER was issued 75 days after the event was identified as reportable.
Reason The root cause of this occurrence was a break down of communications between*
the Plant Corrective Action Review Board, the Regulatory Compliance Group and the Licensing group of Plant Safety and Licensing Department.
The present Palisades Li~ensing group was establ~shed foll~wing a reorganization in 1990 which eliminated the General Office Licensing Department.
The old plant licensing group was responsible for both the initiation and processing of corrective action documents (event reports - ER) and the development of licensee event reports (LERs).
Under the new organization these responsibilities were divided between the new Regulatory Compliance Group and the new pl~nt Licensing Group.
At the time of this
. occurrence, the plant Licensing group, which was responsible for the **
development of the LERs, was stationed in a trailer approximately one-half mn e from the main pl ant and the* Regulatory Compliance Group.
The pl ant Licensing group used reviews of the ER Log and telephone cont.acts to learn of ERs that were considered reportable and that required an LER to be developed.
5 A member of the Regulatory Compli-ance *staff, typically the group section head (lechnical Engineer)~ regularly attended the plant morning meeting and Plant Corrective Action Review Board (PCARB), and performed the scribe duties at PCARB~ On the day the subj~ct deviation report evaluation was brought bact to PCARB for review, the Technic~l Engineer was absent and andther staff member performed the scribe duties at PCARB~ When pCARB determined the event described in the deviation report (DR) to be reportable, no direction was given to the Corrective Action Coordinator (CAC) to initiate the in-house
. event report (ER).
It was generally assumed that the CAC automatically
- generat~d an ER if the event was determined to be reportable; however, the Technical Engineer believed the CAC initiated the ER only at his direction.
Later in December 1991, it ~as brought to the attention of the Technical Engineer that no ER had been initiated.
An ER was initiated for record keeping purposes since the corrective actions had been previously assigned via the DR.
The Technical Engineer incorrectly assumed the plant Licensing group had been informed of the reportability of the DR, its conversion to an ER and, that an LER had been develoe~d.
6*
Correctiv~ Actions and Results Achieved The plant Licens*ing group is no\\'! located in close proximity to the Regulatory Compliance Group.
Due to the previous corrective action related to a missed LER, the CAC now.forwards copies of all ERs to the plant Licensing group~. The CAC acts as the scribe for PCARB meetings and verifies who has responsibility for converting reportable DRs into ERs. and follows up to see that the ER is generated.
In,addition, corrective action documents for the period October 1990 through June 1991 were reviewed to determine if other events identified in corrective action documents, which may have been reportable, had not been reported.. This time frame was choien based upon the relocation ~f the Licensing Group from the corporate headquarters in Jackson, Michigan to the Palisades Plant and because it was during t~is tim~ period when the responsibility for developing the LER wai transferred to the plant Licensing group.
No events were found that had not been previously reported.
Corrective Action to Avoid Futu~e Non-Compliance A corrective action*system log has been developed.
The corrective action system log is used to identify corrective actions which are reportable or which.reportability has yet to be determined.
In addition, copies of all event reports and deviation reports that are determined to be reportable are
- forwarded to the plant Licensing Administrator. Since this occurrence is considered ari isolated incident, no further corrective action is necessary.*
Date of Full Compliance Full compliance has been achieved.
The licensee failed to perform an adequate engineering review during a previously identified deviation report' (D-QP-88-003), which reworked splices on some of the same equipment outside containment, but failed to fo71ow through and extend the review to the containment penetrations. If an adequate
, engineering review would have been performed at that time, this occurrence may have been prevented.
Reason The root cause of this item was the failure of the Environmental Qualification (EQ) engineer to perform ~ thorough review of the cable splices which made use of a braided jacket.
In February 1988 the EQ engineer completed an evaluation of the corrective action document, D-QP-88-003.
The EQ engineer provided an analysis to show that the splice for the component cooling pump motor leads was acceptable.
However, a conservative decision was made fo repair the splices and to revise
the Raychem maintenance procedure for splicing on braided jackets.
In July 1988 the maintenance engineer was revising th~ Raychem maintenance procedure for splicing on braided jackets and added an additional corrective action to D-QG-003 to review all electrical EQ f.iles and'. identify any connection where braided cable jackets existed. Based on the review of the EQ files, any incorrect splices were to be repaired.
Due to the magnitude of the review, a due date of December 31, 1989 was assigned to this new corrective action.
- 7 In October 1989 the EQ engineer completed the review of EQ files to identify any cases where braided cable jackets were used in conjunction with Raychem splices. Three cases were identified. One of the cases was considered acceptable because of a special test which. existed for the configuration. A second case was conside~ed acceptable because it was located outside the.
containment and the justification given for the Raychem splice used for the component cooling pumps was considered applicable.
The third case was for the hydrogen recombiners* (M-69A, M-698), located inside the containment.
The use of the Raychem splice in* this application was not acteptable. Again, an additional corrective action was added to D-QG-003 *to modify the splices at the hydrogen recombiner end to an environmentally qualified configuration; however, the EQ engineer failed to recognize that the other end of the cable at the containment penetration was also not environmentally qualified.
Corrective Actions and Results Achieved The Raychem splice at the conta1nment penetration for the hydrogen recombiners was one of the eight splices identified in the first item of this violation that were not environmentally qualified. The splice has been replaced as previously re~orted in LER 91-002 and no further ~or~ective*action is required.
C~rrective Action to Avoid Futu~e Non-Compliance Th*e administrative controls that are currently in place for the modification process are considered adequate to prevent this.condition from occurring again and, therefore, no further corrective action is required as a result of this violation.
Date of Full Compliance Full compliance has been achieved.
The licensee failed to report the discovery of non-qualified Raychem cable splices identified in the 1988 deviation report via an LER.
Reason The root cause for this item was the lack of a thoroijgh review by the EQ engineer and the Plant Corrective Action Revtew Board (PCARB) regarding the reportability of this condition. The initial PCARB review of the deviation report (DR), which occurred in February 1988, indicated that the conditions described in the DR were not reportable, therefore, an event report (ER) was not generated.
At the time of the initial evaluation of the DR, the ~nly components being considered were the component ~ooling water pumps.
- However, one of the corrective actions that was added after the initial evaluation was to review all of the electrical EQ files and identify any connection where braided cable jackets existed.
Bas~d on the review of the EQ files, any incorrect splices were to be repaired.
Due to the magnitude of the review, a due d~te of December 31, 1989 was assigned to thi~ new corrective action.
In October 1989 the EQ engineer completed the review of EQ files to identify any cases where braided cable jackets were used in conjunction with Raychem splices. The review indicated three cases where improper splices had been 8
. installed, two of which were determined to be acceptable and a third which was determined to be environmentally non-qualified. This information was included in the DR package and was reviewed by PCARB; however, PCARB and the EQ
. engineer failed to recognize that the enyironmentally non-qualified splice constituted a reportable condition as defined in 10 CFR 50.73, specifically, a condition outside the design basis of the plant. Since reportability was not recognized, a licensee event rep~rt was not developed.
The above condition was not addressed by the plant until a similar type of
- no*n-qualified splice was discovered in the reactor head vent circuitry. The discovery of the non-quafified splice on the reactor head vent was reported in licensee event report (LER) 91~002. Corrective action described in the LER included a review of all Raychem cable splices on containment penetration connectors for ctrcuits inside co~tainment. It was during this review that the non-qualified spli~es on the hydrogen recombiners were discovered and properly reported.
_Corrective Actions and Results Achieved CARB membership, as a minimum, now consists of major department head and a member of the Plant Safety and Licensing staff, as defined in administrative procedure 3.03, "Corrective Action System." The Plant Safety and Licensing staff have been trained.on the issue of reportability, specifically with respect to 10 CFR 50.72 and 10 CFR 50.73.. Having an individual trained in reportability requirements as a member of CARB will ensure that corrective action documents receive a more tho~ough review for reportable conditions_.
Corrective Action to Avoid Future Non-Compliance The corrective actions described above are sufficient to avoid futur~ non-compliance.
Date of Full Compliance Full compliance has been achieved.