ML18059A536

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Insp Rept 50-255/93-26 on 931014-1103.Violations Noted. Major Areas Inspected:Electrical Design Control & Review of LERs & One Retracted 10CFR50.72 Notification
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

EA No.93-277

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

inoperable.

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

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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

POST 5 OBEs & 1 SSE

  • 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

SP-1

SR-I

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

5P-4

114.3

103.0

9

5R-4

104.5

93.0

9

5R-5

114.1

97.5

9

5R-6

113.5

94.5

10

Contacts on the above relays perform the following functions:

5P-l

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

5R-l

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

5P-4

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

5R-4

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

5R-5

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

5R-6

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] *

SIL.UNG COO 79>41 ...

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).

Washington. DC

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:

1. Notice of Violation

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