ML18058B893
| ML18058B893 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/25/1993 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9307010173 | |
| Download: ML18058B893 (6) | |
Text
'..
consumers Power POW ERi Nii MICHlliAN'S PROliRESS Palisades Nuclear Plant:
27780 Blua Star Memorial Highway, Covert. Ml 49043
- June 25, 1993
. Nuclear Regulatory Commission
- Document Control Desk
. Washington, DC 20555
. GB Slade General Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT - REPLY TO NOTICE OF VIOLATION; NRC INSPECTION REPORT No. 93008 NRC Inspection Report No. 93008, dated May 28, 1993, forwarded the results of an unannounced NRC inspection of authorized activities at the Palisades Nuclear Plant.
The -inspection report identified an apparent violation of NRC requirements pertaining to the implementation of fuel handling procedures in accordance with Technical Spe~iftcation 6.8.lb. Our reply to the Notic~ of
. Violation is provided in the Attachment to this letter.
In addition, the inspection report requested that we provide a written response to an unresolved item pertaining to a perceived increase in operator errors at the Palisades Nuclear Plant.. As.discussed with the NRC Senior Resident Inspector on June 24, 1993, our reply to the unresolved item identified in IR 93008, will be provided in a later submittal.
x:S.L/~~---
Gerald"B Slade General Manager CC Admiriistrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment 300003 9307010173 930625 PDR ADOCK 05000255 G
CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.
P Hoffman, V Nuclear Operat i Sworn and subscribed to before me this 25th day of June 1993.
LeAnn Morse Notary Public Berrien County, Michigan Acting in Van Buren County, Michigan
- My commission expires February 4, 1997
[SEAL]
ATTACHMENT
- Consumers Power Company Palisades Plant Docket 50-255
- REPLY TO NOTJCE OF VIOLATION NRC INSPECTION REPORT No. 93008 June 25, 1993*
3 Pages
REPLY.TO NOTICE OF VIOLATION Violation Technical Specification 6.8.lb requires implementation of procedures for fuel handling activities. Standard Operating Procedure (SOP) 28, "Fuel Handling System," implements this requirement. of SOP 28 requires
. permission of the.shift superv.isor prior to use of the spent fuel poo.1 h.and1ing machine "Override Key Switch."
1
- Contrary to the above, on March 21, 1993, an operator used the spent fuel pool handling machine "Override Key Switch" without permission of the Shift Supervisor.
A machine malfunction resulted in which the main cable became partia11y unwrapped and an attached spent fuel assembly dropped about six inches.
Reason for the Violation
- auri~g the movement of spent fuel in the spent fuel pool, an operator experienced difficulty in seating spent fuel assembly XF-04 into storage location QW-35.
Datalog information and the operator's written report confirm that the assembly alignment pins were not properly entering the guide holes in the bottom of the spent fuel storage cell. After several unsuccessful maneuvers to seat the spent fuel assembly, the operator attempted to seat the*
spent fuel assembly by placing the full weight of the spent fuel assembly on
_the locating pins.
To accomplish this, the operator had to manually override the hoist underload interlock by us*ing the interlock ov~rride key.
The override key had been issued to the operator when he was assigned the task of moving fuel in the spent fuel pool.
The spent fuel handling machine (SFHM) override key switch has multiple uses and bypasses all of the SFHM interlocks.
The interlocks that are allowed to be bypassed are delineated in the standard operating procedu~e (SOP) 28, "Fuel Handling System."
SOP 28-requires that prior to bypassing any interlock, the shif~ supervisor's permission must be obtained.
The operator mistakenly took the issuance of the bypass key as constituting the permissio_n required by the procedure for using the interlock bypass key.
Furthermore, the operator failed to refer to the procedure to determine if the hoist underload was allowed to *be bypassed.
While lowering.the spent fuel handling machine (SFHM) fuel hoist beyond the "hoist underload interlock," and even further beyond the "cable slack" interlock, the SFHM hoist cable became slack on the hoist cable drum.
- The hoist cable improperly re-wrapped on the drum when hoisting was resumed.
As the hoist was raised approximately two feet to the "bridge/trolley" interlock elevation, the hoist speed increased in accordance with the design of the machine.
The additional cable stress caused by the hoist acceleration*
was sufficient t6 cause the mis-wrapped cable to "wal~" over the retaining edge of the drum, to partially unwrap from the drum, and to wrap* around the drum drive shaft.
2 To correct the machine malfunction, a temporary clamp was manufactured to
.* support the main cab 1 e and the spent fue 1 bundle.
The temporary c 1 amp was.
suspended from the spent fuel pool overhead crane while the SFHM was repaired.
Following repair of the SFHM, the bundle was lowered into a spent fuel storage cell and ungrappled.
Corrective Actions and Results Achieved The following corrective actions were proposed and implemented:
- 1.
A memorandum was issued to all licensed operators describing the use of and the issuance of override keys. lhe memorandum states that the directions provided in Attachment 5 to SOP 28 should be adhered to.
In addition, the memorandum states that the issuance of an override key, in _
and of itself, does not authoriz~ its use ~nd.~hat the individual issued the key must gain an SRO's concurrence prior to using the override.key.
- 2. -A ~evisiori to.SOP 28, "Fuel ijandling System," has been prepared that enhances the dlrections on the issuance and use of override keys frir the*
spent fuel haridling machine, the tilt/transfer.machine, and th~
refueling machine.
These enhancements were incorporated into Revision 13 of SOP 28.
- 3. A memorandum was issued to all operations department personnel reinforcing the requi~ements of Administrative Procedure (AP} 4.00, "Operations Organizati-0ri, Responsibilities and Cond~ct," regarding the use of reference type procedures.
The memorandum reiterated the AP 4.00 requfrement that if an evolution had not been performed in the last seven days, the procedure describing the evolution* should be reviewed prior to performing the e~olution.
- 4.
This event, including management's expectations regarding issuance and use of override keys, has been incorporated into the initial and
. continuing opeiator training programs.
In addition, the following actions have been proposed to investigate the possibility of physical damage to the spent fuel assembly or obstruction of
- the storage cell.
- 1. - Remove spent fuel assembly XF-04 from storage cell QW-35 and examine the lower tie plate alignment pins for bending, etc.
In addition, examine storage cell QW-35 for debris blocking the alignment pin guide holes.
u 3
- 2.
Eval_uate refueling m~chine and spent fuel handljng machine control software with respect to unusual but non-emergency operating mode~.
Determine whether additional programming, utiljzing the bridge/trolley interlock, ~ould further reduc*e the requirement to use the override key for non-emergency situations.
Lastly, a human performance evaluation (HPES) was conducted to ascertain the cause(s) for personnel errors that resulted in the cable misalignment on the spent fuel handling machine.
The HPES evaluation concluded that (I) the licensed auxiliary operator failed to review SOP 28, "Fuel Handling System,"
prtor to performing the procedure, even though sufficient time was available for the operator to review the procedure prior to commencing work, and *(2) the licensed au?Ciliary operator violated SOP 28 by using the override key without
.consulting the senior reactor operator (SRO) in charge of spent fuel movement.
Corrective Action to Avoid Future Non-Compliance The corrective acti6ns described in the above secticin are coniidered sufficient to avoid future non-compliance, therefore, no further corrective is necessary.
- Date of Full Compliance*
Full compliance has been achieved.