ML18059A662
| ML18059A662 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/09/1994 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18059A663 | List: |
| References | |
| EA-93-027, EA-93-27, NUDOCS 9402150039 | |
| Download: ML18059A662 (8) | |
See also: IR 05000255/1993026
Text
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NUCLEAR REGULATORY COMMISSION
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Docket No. 50-255
License No. DPR-20
EA 93-277
801 WARRENVILLE ROAD
LISLE. ILLINOIS 60532:-4351
Februarv 9. 1994
Consumers Power Company
ATTN:
Mr. David P. Hoffman
. Vice *President -
Nuclear
Operations
1945 West Parnall Road
Jackson, Michigan
49201
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTY -
$50,000
(INSPECTION REPORT 50-
255/93026(DRP))
This refers to the special inspection conducted from October 14
through November 22, 1993 at your Palisades Nuclear Plant.
The
inspection reviewed circumstances surrounding two recent events
and identified seve-ral related violations.
The first event,
which you reported.in Licensee Event Report (LER)93-008,
.involved inoperable engineered safeguards room cooler fans,
resulting from improper thermal overload protection .design.
The
second event,. which you also reported in Licensee Event Report
(LER)93-012, involved operability of containment high pressure
(CHP) and containment high radiation (CHR) actuation relays.
The
- * report documenting this inspection was sent to you by letter
dated November 24, *1993.
On December 3, 1993 we held an .open enforcement conference in the
Region 'III off ice with you and other Consumers Power Company
representatives, to discuss the apparent violations, their
causes, and your corrective actions.
The enforcement conference
summary .was sent to you by letter dated December 23, 1993.
The violations in the enclosed Notice of Violation and Proposed
Imposition of Civil Penalty (Notice) involve the loss of control
over *certain electrical design activities regarding changes made
to plant equipment.
In the first case, inadequate design control
measures were applied to the.thermal overload setpoint change fqr
the engineered safeguards room cooler fan motors.
As a result,
both train~ of engineered safety features were degraded.
In the second case, design control measures failed to identify
that containment high pressure and containment high radiation
actuation relays with nine or more normally closed contacts
required larger relay coils.
As a result replacement relays were
installed with undersized coils where operation under design
140030
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9402150039 940209
ADOCK 05000255
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-* . PDR
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II I
Consumers Power Company
2
basis conditions involving a seismic *event or minimum electrical
voltage was not assured.
The enclosed Notice of Violation and Proposed Imposition of Civil
Penalty (Notice) describes two violations.
In addition, our
review of this matter disclosed underlying weaknesses including a
lack of available design information, acceptance and use of
unverified assumptions, inadequate post-modification testing, and
incomplete understanding of design.
Violation I in the enclosed Notice involving the inoperable
cooler fans represented a significant degradation of the
emergency core cooling systems and the containment cooling
systems in that those systems in an accident condition may have
been required to operate at temperatures well above their design
value.
We are aware that your subsequent detailed analyses
determined that the safety systems would have functioned for some
period of time at the elevated temperatures such that time may
have been available for troubleshooting which could have
identified the problem and restored adequate coo+ing.
Nonetheless, under certain conditions' (e.g., failure to promptly
restore fans operability) the emergency core cooling systems and
the containment cooling systems would not have been able to
perform their safety function to mitigate a serious safety event.
Therefore, *in accor~ance with the "General Statement of Policy
and Procedure for NRC Enforcement Actions," (Enforcement Policy),
10 CFR Part 2, Appendix c, this violation is classified as a
.Severity Level III violation.
Violation II in the .enclosed Notice involved
qualif icatioh and degraded capability during
conditions of certain safety related relays.
classified as a Severity Level IV violation.
inadequate seismic
minimum voltage
This violation is
We are concerned that these violations are indicative of
significant weaknesses in the engineering controls essential for
safe conduct of important activities.
As part of the
responsibility for safe plant operation, licensees are expected
to know how their plants are designed and must ensure that any
changes to the plant or its equipment are properly evaluated for
effects on safety.
If the original design is not known, or if
unverified assumptions are used, a proper evaluation of any
change may be difficult or erroneous and the change could have
negative consequences.
Your corrective actions included but were not.limited to forming
a Multidisciplinary Review Group to review this event and other
events involving electrical design or modification.
The thermal
overload settings for all four of the engineered safeguards room
cooling fans ~ere reanalyzed, revised, and tested.
Approximately
40 additional thermal overload setting changes and breaker
changes made during 1993 were reviewed to ensure appropriate post
Consumers Power Company
3
maintenance testing was performed, and 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 CHP and CHR relays with
nine or more normally closed contacts were upgraded by replacing
the coils with stronger ones and seismic qualification testing
was performed on all CHP and CHR relays.
To emphasize the need for increased management attention to
licensed activities, I have been authorized, after consultation
with the Director, Office of Enforcement to issue the enclosed
Notice ~f Violation and Proposed Civil Penalty in the amount of
$50,000 for Violation I.
The base amount of a civil penalty for a Severity Level III
violation is $50,000.
The adjustment factors in the Enforcement
Policy were considered.
The undersize.d thermal overload event
was self-disclosing and you reported it in a timely manner.
However, NRC initiative was required to identify that not just
one, but both trains of engineered safety features were impacted.
Based on this, mitigation is not appropriate.
Your corrective
actions as noted above appeared to be thorough and extensive.
However, NRC involvement was necessary before you recognized the
extent of the problem and took acceptable action to correct it.
Therefore, neither escalation nor mitigation is appropriate .
, Escalation was considered for prior performance, based upon your
most recent Systematic Assessment of Licensee Performance (SALP)
ratings.
However, escalation was considered inappropriate
because the events that are the subject of this enforcement
action were part of the reason for assigning a Category 3 rating
in the SALP engineering functional area.
The remaining factors
in the Enforcement Policy were considered and no further
adjustments were deemed appropriate.
Based on these
considerations, the civil penalty remai~ed at the base amount.
You are required to respond to this letter and should follow the
instructions specified in the enclosed Notice of Violation
(Notice) when preparing your response.
In your response, you
should document the specific actions taken and any additional
actions you plan to prevent rec~rrence. .Your response should
focus on corrective actions planned or- taken to. address each .of
the violations and to resolve the general. weakness in your
electrical design and engineering control program.
After
reviewing your response to this Notice and the ~esults of future
inspections, the NRC will determine whether furthe~ NRC
enforcement action is necessary to ensure compliance with NRC
regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of this letter and its enclosure will be placed in the NRC
Public Document Room.
Consumers Power Company
4
The responses directed by this letter and the enclosed Notice are
not subject to the clearance procedures of the Off ice of
Management and Budget as required by the Paperwork Reduction Act
of 1980, Pub. L. No. 96-5
Enclosure:
cc w/enclosure:
Gerald B. Slade, General
Manager
David W. Rogers, Safety
and Licensing Director
OC/LFDCB
Resident Inspector, RIII
Sincer ly,
,>J;f/tt$r
John B. Martin
Regional Administrator
James R. Padgett, Michigan Public
Service Commission
Michigari Departm~nt of
Public Health * *
SRI, Big Rock Point
A~ Hsia, LPM, NRR
B. Jorgensen, RIII '
W. Dean, PDIII-1, NRR
Consumers Power Company
Distribution:
SECY
CA
J. Taylor, EDO
H. Thompson, DEDS
J. Milhoan, DEDR
J. Lieberman, OE
J. Beall, OE
L. Chandler, OGC
J. Goldberg, OGC
T. Murley, NRR
J. Roe, NRR
Enforcement Coordinators
RI, RII, RIV, RV
F. Ingram, GPA/PA
D. Williams, OIG
B. ,Hayes, or
E. Jordan, AEOD
D. Dandois, oc
L. * Tremper, oc
State of Michigan
RAO:RIII
SLO:RIII
PAO:RIII
IMS:RIII,
Day File
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5
AND
.
PROPOSED IMPOSITION OF.CIVIL PENALTY
Consumers Power Company
Palisades Nuclear Plant
Docket No. 50-255
License No.
DPR~20
EA 93-277
During an NRC inspection conducted from October 14 to November
22, 1993, violations of NRC requirements were identified.
In
accordance with the "General Statement of Policy and Procedure
for NRC Enforcement Actions," 10 CFR Part* 2, Appendix c, the
Nuclear Regulatory Commission proposes to impose a civil penalty
pursuant to Section 234 of the Atomic Energy Act of 1954, as
amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205.
The particular
violations and associated civil penalty are set .fortp below:
I.
Violation Assessed a Civil Penalty
10 CFR Part 50, Appendix B, Criterion III 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, on May 3, 1993, the design control*
measures applied to change the engineered safeguards room
cooler fan motor thermal overloads were inadequate.
Specifically, the trip setpoints were set at or below the
normal operating current and there was no adequate design
review nor suitable testing to check the adequacy of the
design.
consequently, during the period from 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 degraded the operability of ECCS and
-* containment cooling equipment such that those safety systems
could not have performed their intended function'under
certain conditions, in this case, absent prompt manual
actions including troubleshooting and repairing the
engineered safeguards room cooler fan motor thermal
overloads.
(01013)
This is a Severity Level III violation (Supplement I).
Civil Penalty -
$50,000.
II.
Violation Not Assessed a Civil Penalty
10 CFR 50, Appendix B, Criterion III, requires in part that
design control measures shall be established for the
selection and review for suitability of application, of
parts, equipment, and processes essential to safety related
functions.
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- Contrary to the above, as of August 4, 1993, design control
measures established for the selection and review for
suitability of parts, equipment, and processes essential to
safety related functions were inadequate.
Specifically, in
1990 containment.high pressure and containment high
radiation relays, equipment essential -to safety related
functions, were selected such that relays with nine or more
normally closed contacts had an inadequately sized closing
coil for operation under design conditions involving seismic
events or minimum electrical voltage.
As a result, from the
1990 refueling outage until August 4, 1993, the containment
high pressure and containment high radiation actuation '
systems were not capable of performing their intended safety
functions under certain design basis conditions, i.e.,
seismic events-or minimal electrical vo+tage conditions.
(02014)
This is a Severity Level IV violation.
Pursuant to-the provisions of 10 CFR 2.201, Consumers Power
Company (Licensee) is hereby required to submit a written
statement.of explanation to the Director, Office of Enforcement,
U.S. Nuclear -Regulatory Commission, within 30 days of the dc:tte of
this Notice of Violation and Proposed Imposition of Civil Penalty
(Notice).
This reply should be cleariy marked as a "Reply to a*
Notice of Violaj:ion" and should include for* each alleged
.
. violation:
(1) admission or denial of the alleged violation, (2)
the reasons for the violation if admitted, and if denied, the
reasons why,* ( 3) the corrective steps that have .been taken and
the results* achieved, (4) the carrective,steps that will be taken
.to avoid further violations, and (5) the dqte when full
compliance will be achieved.
If an adequate reply is not
received within the time specified in this Notice, an Order or a
Demand for Information ~ay be issued as to why the license should
not be modified*, suspended,* or revoked or why such other actions
as may be proper should not be taken.
Consideration.may be.given
to extending the response.time for good cause shown.
Under the
authority of Section 182 of the Act, 42 u.s.c. 2232, this
response shall be submitted under oath or affirmation.
Within the same time as provided for the response required under
10 CFR 2.201, the Licensee may pay the civil penalty by letter
addressed to James Lieberman, Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, with a check, draft, money
order,. or electronic transfer payable to the Treasurer of the *
United States in the amount of the civil penalty proposed above,
or may protest imposition of the civil penalty in whole or in
part, by a written answer addressed to the Director, Office of
Enforcement, u. s. Nuclear Regulatory Commission.
Should the
Licensee fail to answer within the time specified, an order
imposing the civil penalty-will be issued.
Should the Licensee
elect to file an answer in accordance with 10 CFR 2.205
3
protesting the civil penalty, in whole or in part, such answer
should be clearly marked as an "Answer to a Notice of Violation"
and may:
{l) deny the violations listed in this Notice in whole
or in part, (2) demonstrate extenuating circumstances, (3) show
error in this Notice, or (4) show other reasons why the penalty
should not be imposed.
In addition to protesting the civil
penalty in whole or in part, such answer may request remission or
mitigation of the penalty.
In requesting mitigation of _the proposed penalty, the factors
addressed in Section VI.B.2 of 10 CFR Part 2, Appendix c, should
be addressed.
Any written answer in accordance with 10 CFR 2.205
should be set forth separately from the statement or explanation
in reply pursuant to 10 CFR 2.201, but may incorporate parts of
the 10 CFR 2.201 reply by specific reference (e.g., citing page
and paragraph numbers) to avoid repetition.
The attention of the
Licensee is directed to the other provisions of 10 CFR 2.205,
regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has
been determined in accordance with the applicable provisions of
10 CFR 2.205, this matter may be referred to the Attorney
General, and the penalty, unless compromised, remitted, or
mitigated, may be collected by civil action pursuant to Section
234c of the Act, 42 u.s.c. 2282c.
The responses noted above (Reply to Notice of Violation, letter
with payment of c~vil penalty, and Answer to a Notice of
Violation) should be addressed to:
James Lieberman, Director,
Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Control Desk, Washington, D.C. 20555 with a copy to the Regional*
Administrator, U.S. Nuclear Regulatory Commission, Region III,
801 Warrenville Road, Lisle, Illinois 60532-4351, and with a copy
to the NRC Resident Inspector at the Palisades Nuclear Plant.
Dated at Lisle, Illinois
this 9th day of February, 1994