ML18058A948

Responds to NRC 920602 Ltr Re Violations Noted in Insp Rept 50-255/92-11.Corrective Actions:Licensee Submitted Program Plan for EQ of Electrical Equipment,Including Design Engineering,Maintenance & Further Assurance Per 10CFR50.49

ML18058A948
Person / Time
Site:	Palisades
Issue date:	06/30/1992
From:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9207070349
Download: ML18058A948 (7)

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• consumers Power GB Slade General ~anager l'OWERINli MICHlliAN'S PROliRESS Palisades Nuclear Plant: 27780 Blu.e Star Memorial Highway, Covert, Ml 49043 June 30, 1992 Director, Office of Enforcement Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 ~ LICENSE DPR PALISADES PLANT -

REPLY TO NOTICE OF VIOLATION AND PROPOSED CIVIL PENALTY -. FAILURE TO PROMPTLY IDENTIFY AND CORRECT SIGNIFICANT ENVIRONMENTAL QUALIFICATION NONCONFORMANCES (IR 92011)

NRC letter dated June. 2, 1992 notified Consumers Power Company of a severity level III violation and proposed civil penalty of $75,000. By letter dated June 12, 1992 paymeht of the civil .penalty was made. Our reply to the Notice of Violatio~ is provided in the attachment to this letter.

In your June 2, 1992 letter, it was stated that we at Palisades did not recognize the need for an independent evaluation (i.e., the contractor report in question) to be reviewed by personnel having sufficient expertise and time to assure operability issues are identified and promptly resolved. We have concluded that managem~nt attention to the Environmental Qualification progra~

has been lacking .. The lack of management attention in this case, resulted in an inappropriate priority being put on a detailed review of the contractor report. The additional failure to include the contractor report deficiencies in the plant corrective action process also further aggravated the untimeliness of detailed review. Accordingly, we will ensure proper management attention is brought to cont~actor reported deficiencies by initiating corrective action documents when conditions adverse to quality are I I

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9207070349 920630 PDR ADOCK 05000255 G PDR A CMS ENERGY COMPANY

• reported. Through such action proper assignment of personnel, timeliness of review, and resolution of operability issues will be appropriately made.

Additionally, our overall management commitment to our Environmental Qualification Program is evidenced by our recently submitted program plan to 2

enhance the-design engineering, maintenance, administrative, and training activities necessary to assure compliance with 10CFRS0.49.

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Gerald B Slade General Manager CC Administrator, Region Ill, USNRC NRC Resident Inspector - Palisades Attachment

CONSUMERS POWER COMPANY To the best of my knowledge, information and belief-,. the contents of this*

submittal_ are truthful and complete.

, Vice President at ions Sworn and subscribed to before IJ!e this . 30th day of June 1992.

[SEAL]

LeAnn Morse, Notary_ Public Van Buren County, Michigan My Commission Expires June 6, 1994

ATTACHMENT Consumers Power Company Pali sades Pl ant Docket 50-255 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT 92011 June 30, 1992 3 Pages

1 VIOLATION 10 CFR Part 50, Appendix 8, Criterion XVI, Corrective. Action,* requires, in part, that measures be estabUshed to assure that conditions adverse to quality, such as nonconformances, are promptly identified and corrected.

10 CFR 50.49(e) and (f) require,* in part, that eac.h item of electrical equipment important to safety must be qualified for the most severe design basis accident (harsh) environment during or following which th~ equipment is required or remain functional by appropriate testing, analysis~ or a combination thereof.

Contrary to the above, from December 1990 until November 199i, the licensee failed to establish measures to promptly identify and correct significant environmental qualification nonconformances identified in a contractor.report dated December 28, 1990, which were conditions adverse to quality.

Specifically, until jt initiated its detailed review of the contractor report in November 1991, the licensee failed to promptly identify and correct the following conditions adverse to quality and affecting electrical equipment '

important to safety:

1.. On January 20, 1992, the licensee identified that the residual heat removal heat exchanger temperature element TE-03518 was not qualified for a harsh envjronment (Licensee Event Report No. 255/92~006).

2. On February 5, 1992, the licensee identified that the main steam isolation

. valve actuator solenoid valves SV-0506, SV-0508, SV-0513, and SV-0524 were not qualified for a harsh environment (Licensee Event Report No.

255/92-007). .

3. On February 14, 1992, the licensee identified that the main steam line radiation elements RE-2323 and RE-2324 were not qualified for *a harsh environment (Licensee Event Report No. 255/92-012).

4. On February 17, 1992, *the licensee identified that the plant stack flow transmitter FT-1818 was not qualified for a harsh environment (Licensee Event Report No. 255/92-013). *

5. On February 25, 1992, the licensee identified that solenoid valves SV-0823A, SV-08238, SV-0826A, and SV-08268, and position switches POS-0823 and POS-0826 used for control and indication of the control valves for the service water outlet flow from the component cooling water heat exchangers were qualified for a harsh environment. Additioqally, they *were not electrica77y isolated from the environmenta71y qualified instruments in_

the same electrical scheme (Licensee Event Report No. 255/92-016).

6. *on March 5, 1992, the licensee identified that the containment electrical penetration conne.ctors for the solenoid valves which supply control air to the safety injection tanks pressure and fill control valves were not qualified for a harsh environment (Licensee Event Report No. 255/92-018).

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1. On March 9, 1992, the licensee identified that 39 position switch circuits were not qualified for a harsh environment, in that they contained unqualified wire nuts to make electrical connections (Licensee Event

. Report no. 255/92-019).

Admission The violation is acknowledged to have occurred.

Reasons for the Violation The cause is the lack of management attention given to the plant environmental qualification (EQ) program. -An additional cause is the failure to address the_

deficiencies identified in the contractor's report in the plant's corrective

~ction system. This failure led -to a lack of formal documented review of. the contractor's report and resulted in inadequate management attention to the deficienciei. The fail~re also led to otir placing a-low priority on the

. detailed review of the report.

As a result of deficiencies discove~ed in the plant EQ program, a review of.

the EQ equipment list was commissioned to a contractor~ The resultant review, received by CPCo in December 1990 identified several deficiencies. These defici~ncies were di~ided into four app~ndices to the contractor report in order to delineate whi~h were considered to have the greatest potential for impact on the EQ program. The initial review of this report indicate~ no immediate concerns, however, the review was not documented ~nd was not in '

sufficient detail to identify problems in the equipment electrical circuits.

Based on the results of the initial*review and other priorities, a more detailed review of the report was deferred until November 1991 ..

During review of the plant EQ list in January 1992, it was determined that* a deficiency existed in the RHR -heat exchanger temperature element. Further review resulted *in identifying the deficiency with the main steam isolation valve actuator solenoid valves, which lead to the plant shutdown on February 6, 1992. Other EQ deficiencies noted in the NOV were later identified. Additionally, there was another EQ deficiency which was not identified in the NOV. It involved terminal blocks f~r solenoid valves and position switches associated with the hot leg injection letdown valves (Licensee Event Report No. 255/92-021).

Further evidence of the lack of management attention to the EQ program has been discovered since the NOV was issued. During a Plant Review Committee (PRC) discussion on the issue of misrouted circuits on September 5, 1991 (PRC 91-032), a concern was noted on the lack of environmental qualification with the MSIV solenoid valves. The PRC minut~s state that if certain ~

• equipment in the CCW room failed due to a steam line break the entire scheme including the solenoid valves in the turbine building could fail. No apparent followup action was assigned at that time to complete a detailed docum~nted review. Recognition of the significance of this issue-was not understood Until the February 1992 detailed review, which culminated in the plant shutdown. At the time of the September PRC meeting knowledge prevailed that

3 the MSIV actuation solenoid valves in the Turbine Building were redun.dant to*

those in the CCW ioom and were not a coricern. This w~s later p~oven. in error.

Corre~tive Actions Taken and Results A~hieved Corrective actions related to each of the deficiencie~ noted in the LERs (92-006,92-007, 92-012,92-013, 92-016,92-018, 92-019 and 92-023) were described within those LERs. All deficiencies with 10CFRS0.49 were resolved prior to startup from the 1992 refueling outage.

Corrective Actions Taken to Prevent Future Violations To add~ess the issue of management attention to the EQ program, on April 30, 1992 Consumers Power Company submitted a Program Plan for the Environmental Qualification of Electrical Equipment. The program plan scope includes the design engineering, maintenance, administrative and training activities necessary to enhance the Palisades EQ program and further assure compliance with 10CFRS0.49. The plan is divided into five tasks: Design basis events, EQ program documentation, EQ equipment maintenance, EQ equipment condition monitoring, and personnel training with an expected implementation period of 1~ to 2~ years.

In the future, to address the lack of a formal review of contractor reports, following receipt of a contractor report or other contractor notification identifying plant deficiencies a corrective action .document. will be generated in accbrdance with Palisades Plant Administrative Procedure 3.03. This expectation will be the subject of a memorandum to be issued by the Plant General Manager:

To address Plant Review Committee followup action, PRC members and the PRC secretary wi 11 be tra tned on the nee-d to ensure action i terns are assigned for resolution of issues. *

• Date When in Full Compliance Full comp 1i ance was achieved prior to the end of the 1992 refueling outage.