ML18059A536
| ML18059A536 | |
| Person / Time | |
|---|---|
| Site: | Palisades |
| Issue date: | 11/23/1993 |
| From: | Kobetz T, Schweibinz E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18059A534 | List: |
| References | |
| 50-255-93-26, EA-93-277, NUDOCS 9312070121 | |
| Download: ML18059A536 (17) | |
See also: IR 05000255/1993026
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I I I
Report No. 50-255/93026(DRP)
Docket No. 50-255
Licensee: Consumers Power Co~pany
212 West Michigan Avenue
Jackson, Ml
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, MI
1993
Enclosure 2
License No. DPR-20
Dat1e'
Inspection Summary
Inspection from October 14 through November 3, 1993 (Report No. 50-255/
93026 CDRP))
Area~ Inspected:
A special unannounced safety inspection by the senior
project engineer.* The area inspected was Electrical Design Control and
consisted of a review of LERs and one retracted 10 CFR 50.72 notification.
Results: Four apparent violations which are be1ng considered for escalated
enforcement, one cited violation, and one non-cited violation were identified
(paragraphs 2.a and 2.b, 2.c, and 2.d respectively).
One of the apparent
violations involved a violation of Technical Specifications Limiting Condition
for Operation 3.3.1, 3.4.1 and 3.0.3 for reactor power operation with the
safeguards room cooler fans inoperable and incapable of performing their
design functio~. This rendered ECCS and containment cooling equipment
One of the apparent violations involved a violation of Technical
Specifications, Limiting Condition for Operation 3.17.1 for reactor power
operation since 1990 with containment high pressure and containment high
radiation actuation systems not capable of performing their intended safety
2
931207012c! 6~5~55
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.,
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functions under .certain design conditions.
The remaining two apparent
violations involved violations of IO CFR 50, Appendix B, Criterion III for the
inadequate design control measures applied to the change of setpoint for the
safeguard room fan coolers motor breaker thermal overloads, and for installing
- containment high pressure and containment high radiation relays with nine or
more normally closed contacts with an inadequately sized coil, such that their
operation under design conditions involving seismic events and minimum
electrical voltage was not assured.
The cited violation was a violation of
IO CFR 50, Appendix B, Criterion III, for a modification to a spare safety-
related breaker with inadequate (no) design control measures.
The non-cited
violation was also a violation of IO CFR 50, Appendix B, Criterion Ill, for a
modification to a class IE indicator, which resulted in its being connected to
a non-class IE power source .
3
1.
DETAILS
Management Interview (30703)
The inspector met with licensee representatives denoted in paragraph 9
on November 3, 1993, to discuss the scope and findings of the
inspection.
In addition, the likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspector during the .inspection was discussed.
The licensee did not
identify any such documents or processes as proprietary, except the
Farwell & Hendricks, Inc., reports. Regarding these reports, the
licensee did not identify as proprietary any of the information that the
inspector indicated would be used in this report.
2.
Licensee Event Reports (LER) (93702/37700)
a.
(Closed) LER 50-255/93008 The licensee discovered that the
thermal overload setpoints for fans which are used to cool the
safeguards rooms were set too low.
During performance of an engineered safeguards room cooling and
ventilation system technical specification (TS) surveillance
procedure Q0-30, on August 19, 1993, the V-27C safeguards fan
motor failed to start.
On August 24, 1993, fan V-27D failed to
start during a similar test.
The contactor for the fan motor had
tripped on thermal overload because the trip setting had been
reduced to near the normal running current prior to the 1993
refueling outage.
This was due to the installation of incorrectly
sized overloads on May 2, 1993.
All four engineered safeguards
room cooler fans were similarly affected because all had new
overloads.
The reduced settings would not have allowed continuous
operation of all fans, causing both trains of engineered safety
features to be inoperable.
A review of System Protection Engineering (SPE) files was
performed by the licensee prior to the 1991 NRC EDSFI inspection
(50-255/91019(DRS)).
SPE discovered that the design criteria
established in 1970-1971, for thermal overloads for T-frame
motors, had not been followed since the late 1970's. That
criteria called for a reduced setting of the thermal overload for
T-frame motors which use the Cutler-Hammer No. 789 overload relay
and have a service factor of 1.0.
In January 1992 the criteria
for reduced settings on the T-frame motors was re-instituted.
The
settings were recalculated using the criteria and the four
engineered safeguards room cooling fans were the only safety
related equipment affected.
The criteria used to resize the
thermal overloads protected the motor, but it did not consider the
operating conditions and, thus, led to insufficient margin between
running current and thermal overload current.
4
The.EDSFI
issued~ violation for inadequate design control and
inadequate verification of motor thermal overload design changes.
In response, the licensee committed to correct previous
def~ciencies in this area.
The change o~t of the thermal
overloads performed in May was a result of this commitment.
The licensee's LER stated that it was possible that one train of
the engineered safety features system may have been able to
operate.
However, they failed to quarantine the actual thermal
overloads that were removed in August.
Therefore, no "as found
testing was done.
One apparently successful test was run on
September 22, 1993, with thermal overloads that were the same size
as those installed in May.
These overloads have a tripping
current that can vary as much as 10 percent, however, and the test
was not performed in a controlled manner (i,e,. it was not
established whether the fan that ran for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> did so because
the thermal overload was on the high side of the tripping current
or for some other cause).
The full load amp rating for the fan motors is 24.5 amps.
The
approximate tripping current for the overloads installed in May is
24.0 amps.
The running currents measured (on one phase) prior to
replacement of the overloads for the A, B, and D fans (fan C was
the one that tripped on August 19, 1993) were 24.2 amps, 23.2
~mps, and 23.9 amps respectively. These values are so close to
the tripping current as to eliminate any confidence that the fans
would run during accident conditions.
Since the September 22,
1993, test was not done with the exact overloads that were
installed in May, nor were they duplicated in positioning (i.e.,
slight differences in the orientation will change the settings),
nor was the test performed under accident load conditions, very
little, if any, confidence can be given to the claim in the LER
that one fan may have worked.
The licensee did not perform an adequate post modification test.
Such a test would have identified that not enough margin existed
between the running current and the setpoint of the thermal
overloads.
Corrective Action
The following corrective actions.have been completed:
A Multidisciplinary Review Group was formed to review this
event and others involving electrical design or
modification.
The group issued a report on October 18,
1993, and an update to that report on October 23, 1993.
The
updated report was reviewed by the inspector, however, no
attempt was made to predict how effective the corrective
actions recommended will be .
5
The thermal overload settings for all four of the engineered
safeguards room cooling fans were reanalyzed, revised, and
tested.
The eight other iheimal overload settin~ changes made usfng
the re-implemented "T-frame" criteria (T-frame motors with a
service factor of 1.0 using a Cutler-Hammer No. 789 relay)
were reviewed and images found that the measured equipment
running current was sufficiently below the overload setting.
Additional thermal overload setting changes and breaker
changes (-40) made during 1993, to other than "T-Frame"
motors, were reviewed to ensure appropriate post maintenance
testing was performed.
Further protection device setting changes will not be made
until the multidisciplinary group reviews described above
are complete and effective design control measures are
implemented.
The following corrective actions are planned:
Review setting sheet implementation from a design control
perspective and determine necessary changes .
Review protective device setting methodology to determine if
any other weaknesses exist and determine necessary changes.
Determine appropriate post maintenance testing for
implementation of setting sheet changes.
Analyses to evaluate the potential effect on the safeguards
equipment assuming the safeguards room cooling fans failed
to function during a postulated accident will be completed.
Apparent Violations
10 CFR 50, Appendix 8, Criterion Ill, requires in part that design
control measures shall provide for verifying or checking the
adequacy of design, including necessary design reviews,
calculational methods, or performance of a suitable testing
program.
Contrary to the above, the design control measures applied to the
change of setpoint for the safeguard room fan coolers motor
breaker thermal overloads were inadequate, in that they were set
so close to the normal operating current that they would trip
during normal operation; further, an inadequate post modification
test was performed (50-255/93026-0l(DRP)) .
6
b.
Technical
Specifi~ations (TS) 3.3.1 and 3.4.1 respectively require
that the reactor shall not be made critical, except for
low-temperature physics tests, unless all of the ECCS and
containment cooling equipment are operable.
All heat exchangers,
valves, interlocks,* and piping required to functio*n as support
-
equipment are also required to be operable.
Technical
Specification 3.0.3 requires, when Limiting Conditions for
Operation or associated action requirements cannot be satisfied
because of circumstances in excess of those addressed in the
specifications, action shall be taken to place the unit in a
condition in which the specification does not apply, ultimately
including placing the unit in cold shutdown within not more than
37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Contrary to the above, on May 16 to June 5, 1993, the reactor was
critical with the safeguards room cooler fans inoperable and
incapable of performing their design function. This rend~red ECCS
and containment cooling equipment inoperable, but the licensee did
not place the unit in cold shutdown within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> as required
(50-255/93026-02(DRP)).
(Closed) LER 50-255/93011
Failure of containment high pressure
actuation relay during surveillance test.
Containment high pressure (CHP) actuation relays failed during
performance of a surveillance test in August 1993.
The cause of
the failure was the use of a relay with an inadequately sized
closing coil.
At the time of the event, the licensee was not in
possession of manufacturer recommendations regarding the size of
coils to use when this model relay has greater than eight normally
closed contacts.
The relays were purchased in 1987 and installed
in the 1990 refueling outage as*a replacement for the same make
and model that were originally installed. Additionally, the
licensee found that the design discrepancy applied to other relays
of this make and model having a contact configuration of nine or
greater normally closed contacts. All are in the CHP or
containment high radiatipn (CHR) systems.
The licensee reported this event on August 13; 1993, then
subsequently retracted the report on October 18, 1993, based on
further testing and investigation of system operability.
At that
time, they thought that the relays were fully operable at all
times and would have functioned as needed.
There was a previous
occurrence of a CHP actuation relay failure in 1991, but the
implications were not recognized at that time.
The inspector found that the seismic testing performed in 1987 and
1993 had flaws in both the methodology used in selecting the
sample for the seismic testing, and in the acceptance criteria (or
lack thereof), as specified by the licensee in their purchase
order .
7
Revi.ew of the Farwell & Hendricks, Inc., Report Number 60171,
dated M~rch 12, 1987, revealed the following: 8 relays were chosen
as a representative sample of the 18, Clark Cat. No. 5Ul2-76, 120
Volt A. C. relays which were being purchased; the firs~ seven
relays were- selected for inspection and the last one as the test
sample.
SAMPLE NO.
60171-01-01-01
60171-01-01-02
60171-01-01-03
60171-01-01-04
60171-01-01-05
60171-01-01-06
60171-,01-01-07
60171-02-01-01
AVERAGE PICKUP
VOLTAGE
113. 7
114.6
110.6
112.2
109.9
113.6
107.6
102.4
NORMALLY CLOSED
CONTACTS
0
0
0
0
0
0
0
0
The following operating basis earthquak~ (QBE) and safe shutdown
earthquake (SSE) tests*were performed on sample number
60171-02-01-01
..
TEST COMPLETED
AVERAGE PICKUP
DATE
NORMALLY CLOSED*
VOLTAGE
RECEIPT INSPECTION
102.4
03/05/87
- 1os.2
03/12/87
PRE-SEISMIC TEST
106.4
08/18/93
POST 2 SSEs
107.1
08/23/93
PRE-SEISMIC TEST
114.3
09/14/93
POST I SSE
115. 38
09/15/93
In.addition the licensee performed tests on the
CHR relays with th~ following results:
RELAY
MINIMUM PICKUP
VOLTAGE WITH
ORIGINAL COIL
114.0
114 .1
8
MINIMUM PICKUP
VOLTAGE WITH
NEW COIL
102.4
98.1
CONTACTS
0
0
8
8
11
11
i nsta 11 ed CHP
NORMALLY
CLOSED *
CONTACTS
11
11
and
114.3
103.0
9
104.5
93.0
9
114.1
97.5
9
113.5
94.5
10
Contacts on the above relays perform the following functions:
CLOSE DEMIN WATER TO QUENCH TANK
CLOSE PRI COOLANT PUMP CONTROLLED BLEED OFF
CLOSE PRI COOLANT LETDOWN ISOL VALVE
CLOSE STM GEN E-50B SURFACE BLOWDN LINE
CLOSE STM GEN E-50B BOT BLOWDN LINE
CLOSE SHIELD COOL SURGE TANK FILL
CLOSE PRI SYS DRAIN TANK VALVE
CLOSE PRI SYS DRAIN TANK VALVE
CIRCUIT SEAL-IN CONTACT
CLOSE RECEIVER TANK VENT VALVE
CLOSE HYDRAZINE TANK NITROGEN VALVE
CLOSE DEMIN WATER TO QUENCH TANK
CLOSE PRI COOLANT PUMP CONTROLLED BLEED OFF
CLOSE PRI COOLANT LETDOWN ISOL VALVE
CLOSE ~TM GEN E-50A SURFACE BLOWDN LINE
CLOSE STM GEN E-50B BOT BLOWDN LINE
CLOSE SHIELD COOL SURGE TANK FILL
CLOSE PRI SYS DRAIN TANK VALVE
CLOSE PRI SYS DRAIN TANK VALVE
CIRCUIT SEAL-IN CONTACT
CLOSE RECEIVER TANK VENT VALVE
CLOSE STM GEN E-50A SURFACE BLOWDN LINE
CLOSE MSIV CV-0501 AND CV-0510
CLOSE PRI SYS DRAIN TANK VALVE
CLOSE CLEAN WASTE REC TANK ISOL VALVE
CLOSE CLEAN WASTE REC TANK ISOL VALVE
CLOSE CLEAN WASTE REC TANK ISOL VALVE
CONTROL ROOM HVAC EMERGENCY SYS ACTIVATION (TRAIN B)
CLOSE CLEAN WASTE REC TANK PUMP SUCTION VALVE
. CLOSE RECEIVER TANK VENT VALVE
CLOSE HYDRAZINE TANK NITROGEN VALVE
CLOSE STM GEN E-50B SURFACE BLOWDN LINE
CLOSE PRI SYS DRAIN TANK VALVE
CLOSE CLEAN WASTE REC TANK ISOL VALVE
CLOSE CLEAN WASTE REC TANK ISOL VALVE
CLOSE CLEAN WASTE REC TANK ISOL VALVE
9
CONTROL ROOM HVAC EMERGENCY SYS ACTIVATION (TRAIN B)
CLOSE CLEAN WASTE REC TANK PUMP SUCTION VALVE
CLOSE RECEIVER TANK VENT VALVE
CLOSE NITROGEN ISOLATION VALVE
CLOSE CONTAINMENT BLDG HEAT STM DISCHARGE VALVE
CLOSE CONTAINMENT BLDG HEAT STM DISCHARGE VALVE
CLOSE CONT HYD MON ISL VALVES
CLOSE PRI. SYS SAMPLING ISOLATION VALVE
TRIP AIR ROOM PURGE FAN
CLOSE CONTAINMENT SUMP DRAIN VALVE
PREVENTS OPERATION OF ESS SUMP PUMP WHILf HS IN AUTO
PREVENTS OPERATION OF ESS SUMP PUMP WHILE HS IN AUTO
CLOSE NITROGEN ISOLATION VALVE
CLOSE CONT HYD MON ISL VALVES
CLOSE CONTAINMENT BLDG HEAT STM DISCHARGE VALVE
CLOSE CONTAINMENT BLDG HEAT STM INLET VALVE
CLOSE WASTE GAS SURGE TANK INLET VALVE
TRIP AIR ROOM PURGE FAN
CLOSE CONTAINMENT SUMP DRAIN VALVE
PREVENTS OPERATION OF ESS SUMP PUMP WHILE HS IN AUTO
PREVENTS OPERATION OF ESS SUMP PUMP WHILE HS IN AUTO
CONTROL ROOM HVAC EMERGENCY SYS ACTIVATION (TRAIN A)
One flaw was in the methodology used in selecting the test sample
for the seismic testing. A reference to Mil STD-105D was made for
the method of sample selection.
The acceptance criteria, as
specified by the licensee in their purchase order, failed to
identify a minimum average pickup voltage (another flaw).
The
minimum voltage supplied by the inverter is 114.5 volts. A
conservative sampling technique would select a relay that had an
average pickup voltage as close as possible to the minimum pickup
voltage.
If that voltage was not known, the*highest voltage
should be used.
Selection of a relay with a pickup voltage 12.2
volts lower than the highest relay was very nonconservative.
If the minimum average pickup voltage had been specified in the
acceptance criteria, the second sample would have failed the
receipt inspection.
Then, as defined in the SAMPLING PLAN FOR
PARTS INSPECTION AT F & H, on page 42 of the report, the entire
lot would have been rejected. Additionally, these relays are
constructed such that as the number of normally closed contacts
increases, it becomes harder for the relay to pick up, and the
average pickup voltage increases. Therefore, the relays should
have been tested with the maximum number of contacts in the
normally closed position, rather than the minimum number (zero).
Flawed 1987 acceptance criteria appeared to be at the root of this
problem.
The licensee was aware of this problem after the 1993
event that was the subject of this LER.
10
The.inspector also found that the recent seismic testing
(September 1993, Farwell & Hendricks, Inc. Report No. 10547.0) did
not prove that the relays with nine or more normally closed
contacts would have functioned as needed before, during, and after
a seismic event, in that the average pickup voltage for the relay
tested was 115.38 volts after the seismic event.
However, because
no minimum average pickup voltage was specified in the acceptance
criteria, the relay "passed" the testing without noting the
average pickup voltage being 0.88 volts above the minimum inverter
output of 114.5 volts.
Subsequent to these flaws being identified by the inspector, the
licensee re-classified this event as reportable on November 3,
1993.
Corrective Action
The following corrective actions have been completed:
A Multidisciplinary Review Group was formed to review this
event and others involving electrical design or
modification.
The group issued a report on October 18,
1993, and an update to that report on October 23, 1993 ..
The
updated report was reviewed by the inspector, however, no
attempt was made to predict how effective the corrective
actions recommended will be.
The relays with eight or fewer normally closed contacts were
determined not to need a stronger coil and remained as
recommended by the manufacturer.
A relay with the original
coil was subjected to seismic testing in August 1993, and
the average pickup voltage was found to be 107.1 volts after
the seismic event with 8 normally closed contacts and 4
normally open contacts.
The relays with nine or more normally closed contacts were
upgraded by replacing the coils with a stronger one as
recommended by the manufacturer.
A relay with a stronger
coil was subjected to seismic testing in September 1993, and
the average pickup voltage was found to be 99.54 volts after
the seismic event with 11 normally closed contacts and 1
normally open contact.
Apparent Violations
10 CFR 50, Appendix B, Criterion Ill, requi~es in part that
measures shall be established for the selection and review for
suitability of application of ... parts, equipment and processes
... essential to the safety-related functions of ... systems and
compartments.
This criterion applies to actuation relays for
safety-related functions .
11
Contrary to the above, containment high pressure and containment
high radiation actuation relays with nine or more normally closed
contacts which were selected, were not suitable due to an
inadequately sized coil, such that their operation under design
conditions involving seismic events and minimum electrical voltage
was not assured (50-255/93026-03(DRP)).
TS 3.I7.I requires plant instrumentation shall be operable in
accordance with Tables 3.I7.I through 3.I7.4. Table 3.I7.3,
requires containment high pressure and containment high radiation
shall each have a minimum of two operable channels during plant
operations, or the plant shall be placed in cold shutdown within a
total of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.
Contrary to the above, the containment high pressure and
containment high radiation actuation system relays installed in
I990 had no channels capable of performing their intended safety
functions under certain design conditions, but the plant was
routinely operated for periods far in excess of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />
(50-255/93026-04(DRP)).
c.
(Closed) LER 50-255/93005
Emergency diesel generator start due to
an inadvertent loss of power to safeguards bus IC.
(Closed) Unresolved Item 50-255/930I3-02(DRS) Same subject.
A modification to a spare "like for like" 2400 volt feeder breaker
was performed on July 9, I993, under a work order instead of
through a formal design review.
On July 20, I993, when the spare
breaker was racked into the start-up transformer cubicle, the in-
service feeder breaker (station power transformer to safeguards
bus IC
11
) erroneously sensed that another power supply was being
loaded onto the bus and tripped open.
This is a design feature,
to prevent paralleling two sources of ac power out of
synchronization (accomplished through a special limit switch which
is closed when the breaker is in the closed position). This
resulted in no power supply to the bus.
An undervoltage condition
on the bus followed, as did an autostart of both diesels - an
unplanned ESF actuation. It was later determined that internal
wiring of the replacement spare breaker was correct before the
modification.
The inspector determined that the system engineer erred in an
attempt to make the spare breaker look the same as the other
breakers.
The engineer requested that four apparently unused
auxiliary contacts be changed to a configuration similar to that
of the other breakers.
The system engineer knew of the existence
and use of the special limit switch in the installed breakers, but
was not aware that the spare breaker used an auxiliary contact
instead of the special limit switch, to perform the same function.
A lack of adequate vendor drawings contributed to the mistake .
I2
Corrective Action
The following corrective actions have been or will be taken:
Training was provided to system engineers on this event.
Auxiliary contacts for the spare breaker used in this event
were verified in the correct configuration for use of the
breaker ..
Vendor drawings depicting the internal wiring of the spare
breaker were obtained, and these drawings were included i~
the vendor files for these breakers.
Equipment numbers were assigned to spare breakers so that
they may be added to the equipment data base.
Methodology for the control of spare breakers will be
developed.
Violation
10 CFR 50, Appendix B, Criterion Ill, requires in part that design
changes, including field changes, shall be subject to design
control measures commensurate with those applied to the original
design and be approved by the organization that performed the
original design unless the applicant designates another
responsible organization.
Contrary to the above, on July 9, 1993, a modification was made to
a spare safety-related breaker during a maintenance activity and
no design control measures of any kind were applied
(50-255/93026-05(DRP)).
d.
(Closed) LER 50-255/93006 Regulatory Guide 1.97, pressurizer
level indicator powered from a non-class IE power supply.
The licensee determined that pressurizer level indicator LIA-0102A
was powered from a non-safety related AC power supply.
This
condition was discovered during the review of electrical prints in
support of the ongoing Configuration Control Program (CCP) drawing
review and resulted from a facility change package implemented in
1988.
The causes of this event were personnel error and inadequate post
modification testing.
In 1992 (as described in LER 92005), the LT-0103 circuit was found
to be connected to a non-class lE system without adequate circuit
isolation.
In LER 92005 the licensee stated that" ... The first
instrument loop, LT-0102, meets all the requirements of
13
RG 1.97." This was used to conclude that a qualified pressurizer
level indication instrument was available between the time of
installation of the RG 1.97 qualified instruments in 1988 and the
discovery of the inadequate isolation of LT-0103 from the
non-class lE critical functions monitor system computer in 1992.
The current LER (93006) reported that level indicator LIA-0102A
was also installed contrary to RG 1.97 requirements.
Corrective Action
The following corrective actions have been or will be taken:
A Multidisciplinary Review Group was formed to review this
event and others involving electrical design or
modification.
The group issued a report on October 18,
1993, and an update to that report on October 23, 1993.
Indicator LIA-0102A has been powered from the correct AC
power source.
Personnel training will address the confusion that may
result when dealing with wire labeling associated with
panels Y-10 and Y-01.
Also, the consider~tions that should
be given to the testing of modifications for the correct
power source will be addressed.
Procedure E~AD PMC&T-02, "Guideline for Prep~ring
Modification Test Procedure," will be evaluated with
- respect to including instructions for the test procedure
writer to check for proper power sources during a
modification.
10 CFR 50, Appendix B, Criterion III, requires in part that design
changes, including field changes,. shall b.e subject to design
control measures commensurate with those applied to the original
design and be approved by the organization that performed the
original *design unless the applicant designates another
responsible organization.
Contrary to the above a modification was made and an inadequate
post modification test failed to determine that a class lE
indicator was connected to a non~class lE power source.
However,
the licensee identified this violation.
It was not a violation
that could reasonably be expected to have been prevented by the
licensee's corrective action for a previous violation or a
previous licensee finding that occurred within the last two years.
It was corrected within a reasonable time, and the licensee
committed to comprehensive corrective actions to prevent
recurrence.
It was not a willful violation. Therefore, this
violation will not be cited because the criteria specified in
Section VII.8.2 of the General Statement of Policy and Procedures
14
- ~
3.
for.NRC Enforcement Actions (Enforcement Policy, 10 CFR Part 2,
Appendix C (1993).), were satisfied.
Per~ons Contacted
- G. B. Slade, Plant General Manager
- R .. D. Orosz, Nuclear Engineering and Construction Manager
R. M. Rice, Nuclear Performance and Assessment Department Manager
- T. J. Palmisano, Plant Operations Manager
- D. J. VandeWalle, Mechanical, Civil, and Structural Engineering Manager
D. W. Rogers, Safety and Licensing Director
- J. L. Hanson, Operations Superintendent
- K. E. Osborne, System Engineering Manager
- K. A. Toner, NECO Electrical/I&C/Computer
- M. T. Nordin, Systems Engineering, Electrical
R. K. Moceri, Electrical System Engineer
- J. L. Kuemin, Licensing Administrator
C. T. Hillman, Licensing Engineer
Nuclear Regulatory Commission (NRC)
- M. E. Parker, Palisades Senior Resident Inspector
- D. G. Passehl, Palisades Resident Inspector
- E. R. Schweibinz,.Senior Project Engineer
- Denotes those present at the management interview conducted on
November 3, 1993.
In addition, the inspectors interviewed other licensee personnel
including shift supervtsors, control operators, and engineering
personnel.
15
,I
)
Enclosure 3
Federal Resister I Vol. 67, No. U3 / l'riday, July 10. 1992 I Notices
n prior reviews for the Yankee Nuclear
power Station. The plant was licensed
~fore the requirement for i,Huance of a
final Environmental Statement.
J.sencies. and Persons Consulted
The NRC staff reviewed the licensee'*
request and did not consult other
agencies or persona.
randing of No Significant Impact
The Commiasion bas determined not
-to prepare an environmental impact
8tatement for the proposed exemption.
Based upon the foregoing environmental
assessment. we conclude that the
- proposed action will not have a *
significant effect on the quality of the
human environment.
For further details with respect to this
action. see the application for exemption
dated May 22. 1992. which is available
for public inspection at the
Commi11ion'1 Public Document Room.
2120 L Street. NW .. Washington. DC
20555, and at the local public document
room at Greenfield Community College.
l College Drive. Greenfield,
Ma88achuaetta 01301.
Dated at Roclcville. Maryland. this 2d day
of July 1992.
For the Nuclear Regulatory Commission.
Richard F. Dudley, Jr.,
Acting Dil"f!Ctor. Non*Power Reactors.
Decommissioning and Em*ironmenta/ Project
Directorate. Division of Reactor Projects-
D//IV IV. Offi~ of Nuclear Reactor
&gulotion.
(FR Doc. 92-18%32 Filed 7-9-92: 8:45 am)
AegulatOf)' .Guides; Issuance,
Avallablllty
The Nuclear Regulatory Commission
baa iasued a revision to a guide in its
Regulatory Guide Serie&. This series has
been developed to describe and make
available to the public such information
as methods acceptable to the NRC staff
for implementing specific parts of the*
Commission's regulations. techniques
used by the staff in evaluating specific
problems or postulated accidents. and
data needed by the staff in its review of
applications for permits and licenses.
Regulatory Guide 8.7. Revision l.
"Instructions for Recording and
Reporting Occupational Radiation
Exposure Data." describes an
acceptable program for the preparation.
retention. and reporting of records of
occupational radiation exposures. It
includes copies of NRC Forms 4 and 5
and detailed instructions on completing
them.
Comments and suggestions in
connection with items for inclusion in
guidet cun-ently being developed or
improvement* in all publilhed guides
are encouraged at any time. Written
comments may be aubmitted to the
Regulatory Publication.a Branch.
Diviaion of Preedom of Information and
Publicationa Service1. Office of
Administration. U.S. Nuclear Regulatory
CommiHion. Waahington. DC 20555.
Regulatory guide* are available for
inepection at the Commi1Sion"1 Public
Document Room. 2120 L Street NW ..
W aehington. DC. Copies of iaaued
guides may be purchased from the
Government Printing Office at the
current GPO price. Information on
current GPO prices may be obtained by
contacting the Superintendent of
Document.a. U.S. Government Printing
Office. Pott Office Box 37082..
Washington. DC 200lr7082.. telephone
(202) 512-2249 or (202) 512-2171. 11Sued
guide* may alao be purchased from the
National Technical Information Service
on a standing order basis. Details on
thi1 service may be obtained by writing
NTIS. 5285 Port Royal Road. Springfield.
VA2218l.
Authority. S US.C. SSZ(aj.
Dated at Roc:ltville. Maryland. thi1 30th day
of June 1992-
For the Nuclear Regulatory Commission.
Eric S. Bedqord. Director.
Office of Nuclear ~ulatory Rnearch.
(FR Doc. 92-16224 Filed 7-&-4J2; 8:45 am] *
Two-Year Tr1al Program for
.
Conducting Open EnfOt cement
Conferences; PoUcy Statement
AGENCY: Nuclear Regulatory
Commission. *
ACTIC>N: Policy 1tatement.
SUMMARY: The Nuclear Regulatory
Commission (NRC) is i11uing this policy
statement on the implementation of a
two-year trial program to allow selected
enforcement conferences to be open to
attendance by all members or the
general public. This*policy statement
describes the two-year trial program
and informs the public of how to get
information on upcoming open
enforcement conferences.
DATES: Thia trial program is effective on
July 10. 1992. while comments on the
program are being received. Submit
comments on or before the completion
of the trial program scheduled for July
11. 1992. Comments received after this
date will be considered if it is practical
to do ao. but the Commi88ion is able to
assure consideration only for comments
received on or before this date.
AOOR£Uf'S: Send comment.I to: The
Secretary of the Commlaaion. U.S.
Nuclear Regulatory CommiHlon.
Washington. OC Z0555. ATrN:
Docketing and Service Branch.
Hand deUver com.menta to: One White
f1int North. 11555 Rockville Pike.
Rockville, MD between 7:45-a.m. to 4:15 -
p.m.. Federal woritdaya.
Copies of comments may be examined
at the NRC PubUc Document Room. 2120
L Street. NW. (Lower Level).
FOR AMTHER INFORMATION CONT ACT.
Jamee Ueberman. Director. Office of
Enforcement. US. Nuclear Regulatory
Commission. Washington. DC 20555
(301-S0.-2141 ).
SUPA.DIENTARY INFORllATION:
Background
'The NRC'1 current policy on
enforcement conferences is addressed in
Section V of the latest revision to the
"General Statement of Policy and
Procedure for Enforcement Actions."
(Enforcement Policy) to Cf'R part 2.
appendix C that wae pubUahed on
February 18. 1992 (57 FR 5791). The
Enforcement Policy states that,
..enforcement conferences will not
normally be open to the public."
However. the Commission has decided
to implement a trial program to
determine whether to maintain the
current policy with regard to
enforcement conferences or to adopt a
new policy than~*ould allow most
enforcement conferences to be open to
attendance by all members of the public.
.Policy Statement
Position
The NRC la implementing a two-year
trial program to allow public
observation or selected enforcement
conferences. The NRC will monitor the
. program and determine whether to
establish a permanent policy for
conducting open enforcement
conference1 baaed on an assessment of
the following aiteria:
(1) Whether the fact that the
conference was open impacted the
NRC's ability to conduct a meaningful
conference and/or implement the !'1.'RC*s
enforcement program;
(2) Whether the open conference
- impacted the licensee'* participation in
the conference;
(3) Whether the NRC expended a
aignificant amount or reaources in
making the conference public: and
(4) The extent or public interest in
opening the enforcement conference.
T
Federal Register I Vol. 57, No. 133 I Friday, July 10. um I Notioe8
I. Criteria For Selecting Open
- ~ Eafon:emeot Confenmoes
Enforcement conference' will not be
n to the public if the enforcement
- on being comtemplated-
(1) Would be taken asainst an
individual or if the action. though not
taken asainst an individual. turns on
whether an individual has committed
wrongdoing:
(2) Involves significant personnel
failures where the NRC has requested
that the individual(s) involved be
present at the conference;
(3) la baaed on the findings of an NRC
Office of Investigations {Ol) report; or
(4) Involves safesuards information.
Privacy Act infonnation. or other
information which could be considered
proprietary.
Enforcement conferences involving
medical misadministrations or
overexposures will be open assuming
the conference can be conducted
without disclosing the exposed
individual's name. In addition.
enforcement conferences will not be
open to the public if the conference will
be conducted by telephone or the
conference will be conducted at a
relatively small licensee's facility.
Finally, with the approval of the
Executive Director for Operations.
forcement conferences will not be
n to the public in special cases
ere sood cause has been shown after
balancing the benefit of public
observation against the potential impact
on the agency's enforcement action in a
particular case.
.
The NRC will strive to conduct open
enforcement conferences during the
tw~year trial program in accordance
with the following three saals:
(1) Approximately Z5 percent of all
eligible enforcement conferences
conducted by the NRC will be open for
public observation;
(2) At least one open enforcement
conference will be conducted in each of
the regional offices: and
(3) Open enforcement conferences
will be conducted with a variety of the
types of hcensees.
To avoid potential bias in the
selection process and to attempt t.o meet
the three goals stated above. every
fourth eligible enforcement conference
involving one of three categories of
licensees will normally be open to the
public durins the trial program.
However. in cases where there is an
ongoins adjudicatory proceeding with
one or more intervenors. enforcement
conferences involving issues related to
the subject matter of the ongoing
udication may also be opened. For
purposes of this trial program. the
three cat~
or lioeasees will be
commercial operating reectoni.
hospit.ala, and other liceoaees, which
will conaiat of the remaining types of
licensees..
D. Annoandnz Open F.nforcemeat
Conferences
As soon as it is determined that an
enforcement conference will be open to
public observation. the NRC will orally
notify the licensee that the enforoement
conference will be open to public
observation as part of the asency's trial
program and send the licensee a copy or
this Federal Resister notice that outlines
the program. Licensees will be asked to
estimate the number o! participants it
will bring to the enforcement conference
. so that the NRC can schedule an
appropriately sized conference room.
The NRC will also notify appropriate
State liaison officers that an
enforcement conference hat been
scheduled and that it ia open to public
observation.
The NRC intends to announce open
enforcement conferenc;es to the public
normally at least 10 working dayt in
advance of the enforcement conference
through the following mecbanisn>s:
(1) Notices poeted in the Public
Document Room:
(2) Toll-free telephone messages; and
(3) Toll-free electronic bulletin board
messages.
Pending establishment of the toll-free
message systems, the public may call
(301) 492-1732 to obtain a recording of
upcoming open enforcement
conferences. The NRC will inoe another
Federal Register notioe after the toll-free
message systems are established.
To assist the NRC in making
appropriate arrangements to support
public observation of enforcement
conferences. individuals interested in
attending a particular enforcement
conference should notify the individual
identified in the meeting notice
announcing the open enforcement
conference no later than five business
days prior to the enforcement
conference.
Ill. Conduct or Open Enforcement
Conferences
In accordance with current practice,
enforcement conferences will continue
to normally be held at the NRC regional
offices. Members of the public will be
allowed access to the NRC regional
offices to attend open enforcement
conferences in accordance with the
"Standard Operatins Procedures For
Providing Security Support For NRC
Hearings And Meetings- published
November 1. 1991 (56 ffi 56251). These
procedures provide that visitors may be
subject to personnel eaeenin,g. that
signs.. bannera. poetera. etc.. not larger
than 18" ~permitted. and that
disruptive perao0a may be removed.
Each regional office will continue to
conduct the enforcement coaferenoe
proceedings in ac:cordanoe with regional*
practice. The enforcement conference
will continue to be a meeting between
the NRC and the lic:enaee. While the
enforcement conference ii open for
public observation. it ia not open for
public. participation.
Per&Onl attending open enforcement
conferences are reminded that (1) the
apparent violation.I di.cusaed at open
enforcement oonlerencee are aubject to
further review and may be aubject to
change prior to any resulting
enforcement action and (2) the
stat~menta of views or expreuions of
opinion made by NRC employees at
- open euforcement conferences or the
lack thereof. ere not intended to
represent final detenninatioris or beliefs.
In addition to providing comments on
the agency's trial program in accordance
with the guidance in this notice. persons
attending open enforcement conferences
will be provided an opportunity to
submit written comments anonymously
to the regional office. These comments
will subsequently be forwarded to the
Director of the Office of Enfon:ement for
review and consideration.
Dated at Rockville. MD. thia 7th day ol July
1992.
For the Nuclear Replatory Commiaaion.
Samuel J. Ciiik.
Secretary of the Commiuion.
{FR Doc. 92-16233 rded 7~
8:'5 a.m.)
~COO
75*).0MI
OFFlCE Of PERSONNEL
MANAGEMENT
Request for Clearance of* Revised
Information Conectlon to Add Form Al
36-7 to OU8 Clearance Number 3206-
0128
AGENCY: Office of Personnel
Management.
ACTIOM: Notice.
SUUMAAY: In accordance with the
Paperworic Reduction Act of 1980 (title
44, U.S. Code. chapter 35). this notice
announces a request for clearance of a
revised information collection. to add
form RI 38-7 to the Application for
Refund of Retirement Deductions
(CSRS). OPM must have SF 2.802
completely filled out and signed before
paying a refund of retirement
contributions. SF 2802B muat also be
complete if there are apouse(~J or former
-
..
i
NOV 2 4 1993
Consumers Power.Company
3
-
-
subject to enforcement action because your efforts in identifying and
correcting the violation met the criteria specified in Section VII.B of the
"General Statement of Policy and Procedure for NRC Enforcement Actions,"
(Enforcement Policy, 10 CFR Part 2, Appendix C).
The responses directed by
this letter and the enclosed Notice are not subject to the clearance
procedures of the Office of Management and Budget as required by the Paperwork
Reduction Act of 1980, PL 96-511.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of
this letter and its enclosures and your reply to this letter, will be placed
in the NRC Public Document Room.
Enclosures:
2. Inspection Report
No. 50-255/93026(DRP)
3. Federal Register Notice
cc w/enclosures:
David P. Hoffman, Vice President
Nuclear Operations
David W. Rogers, Safety
and Licensing Director
OC/LFDCB
Resident Inspector, Riii
James R. Padgett, Michigan Public
Service Commission
Michigan Department of
Public Health
Palisades, LPM, NRR
SRI, Big Rock Point
L. J. Callan, NRR
J. Lieberman, OE
J. R. Goldberg, OGC
(see attached concurrence)
Riii
Riii
Riil
Schweibinz
Kobetz
Gardner
RI II
Sincerely,
' .
- '***-~ *******- .... -.... ;...
Edward G. Greenman, Director
Division of Reactor Projects
Rill
RIII
De Fayette
Jorgensen
Pirok