ML18059A981
| ML18059A981 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/06/1994 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fenech R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18059A982 | List: |
| References | |
| EA-94-041, EA-94-41, NUDOCS 9405120280 | |
| Download: ML18059A981 (4) | |
See also: IR 05000255/1994002
Text
UNITED STATES *
NUCLEAR REGULATORY COMMISSION
Docket No. 50-255
License No; DPR-20
EA 94-041
Consumers Power Company *
REGION Ill
801 WARRENVILLE ROAD
LISLE, ILLINOIS 60532-4351
May 6, 1994
ATTN:
Mr. Robert A. Fenech
Vice President - Nuclear
Operations
1945 West Parnall Road
Jackson, Michigan
49201
Dear Mr. Fenech:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$50,000
(INSPECTION REPORT NO. 50-255/94002(DRS))
This refers to th~ service water ~ystem operational performance inspection
(SWSOPI) conducted from January _10 through February 11, 1994, at Pali sades
Nuclear Plant.
The report documenting this inspection was sent to you by
letter dated Maich 4, 1994.
During the inspection, a violation .of NRC
requirements was identified.
An enfo~cement conference was held on March 11,
1994, to discuss the apparent violation, its causes, and your corrective
actions.
'The inspection identified five*examples where prompt corrective actions were
not taken for significant conditions adverse to quality.* On~ example involved*
a single failure vulnerability that could have led to the loss of all
engineered safeguards system pumps.
Four additional examples were identified
by your service water Safety System Design Confirmation (SSDC) program in June
1989, and the component cooling water SSDC in June 1990.
All examples
exhibited inadequate engineering evaluations and lack of management
involvement in the SSDC process.
We have concluded that weaknesses in management oversight and communications
resulted in your engineering organization's not understanding the system's
de~ign and a failure to adequately define who was r~sponsible for maintaining
the design.
These failures directly contributed to your failure to recognize
- and promptly correct the design deficiencies.
We recognize you have taken
significant actions to address management and engineering issues at Palisades.
However; deficiencies o~ this nature take time to resolve and in the interim
you are susceptible to additional problems, thus additional scrutiny of
engineering activities is essential.
The enclosed Notice of Violation and Proposed Imposition of Civil Penalty
(Notice) describes one violation involving five examples of failure to take
. appropriate and timely corrective action to correct significant conditions
- aaver*se*'i-o -qua-nt_x .. The Rroblem *i,s considered to represent a significant
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breakdow~irt the control of your corrective action program.
Therefore, in
accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," (Enforcement Policy) 10 CFR Pa-rt 2, Appendix C, the
problem has been categorized at-Severity Level III.
The base value of a civil penalty for a Severity Level III violation or
problem is $50,000, with consideration for additional escalation and
mitigation as set forth in the Enforcement Policy.
In this case, we
considered escalating the civil penalty due to the NRC's identifying the
problem, your poor past performance, and the length of time that most of the
problem went uncorrected.
We considered mitigation because of your prompt
corrective action following our identification of the problem.
As a result of
these considerations and the application of these factors, the base penalty
could have been increased significantly under the normal application of the
We acknowledge your completed and ongoing corrective actions which include
opening CCW valves CV-0913 and CV-0950, completing a pump cooling requirements
analysis by April 30, 1994, reevaluating all SSDC findings by August l, 1994,
coordinating the pump inservice testing program with system performance
verifications, enhancing the work order review process by June 1, 1994,
conducting an individual accountability meeting with all employees, requiring
systems engineers to walk down their systems and review all system work
orders, and providing continuing training of system engineers on lessons
learned regarding operability issues.
We also acknowledge that you are
actively developing a Performance Improvement Plan and expect to have it
finalized by mid-May 1994.
In addition to these corrective actions, we are.
aware of numerous senior management changes recently undertaken at Palisades
and understand that these changes were made to increase the focus toward
identifying and correcting problems and improving overall performance.
Because of the very significant and broad managerial changes you have made in
an attempt to correct overall past poor performance at Palisades, and to
encourage you to continue with such aggressive actions to improve performance,
I have been authorized after consultation with the Director, Office of
Enforcement, and the Deputy Executiye Director for Nuclear Reactor Regulation,
Regional Operations and Research, to exercise discretion under Section VII of
the Enforcement Policy and issue the enclosed Notice in the base amount of
$50,000 for the problem descrfbed above, notwithstanding the fact that the
normal application of the escalation and mitigation factors would have
resulted in a substantially higher civil penalty.
Iri exercising this
discretion, I emphasize that the NRC expects Consumers Power Company to
continue its recent aggressive actions to improve performance at Palisades and
that .the __ effectiveness of implementation of these actions will be examined
closely by the NRC.
You are required to respond to this letter and should follow the instruction~
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific action taken and any additional
actions you plan to prevent recurrence. After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
..
Consumers Power Company
- 3 -
inspections, the NRC will determine Whether further 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, its enclosure, and your response will be placed in the NRC Public
Document Room.
The response 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, Public Law No.96-511.
Enclosure:
Notice of Violation and Proposed
Imposition of Civil Penalty
cc w/enclosure:
Thomas Palmisano, Acting General
Manager
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
G. E. Grant, Riii
o n . Martin
Regional Administrator
Consumers Power Company
DISTRIBUTION:
POR
SECY
CA
JTaylor, EOO
,./
JMil ho an, OEDR
Jlieberman, OE
LChandler, OGC
JGoldberg, OGC
WRussell, NRR
LReyes, NRR
LTremper, OC
Enforcement Coordinators
RI, Rll, RIV, WCFO
Fingram, GPA/PA
OW i 11 i ams , 0 I G
BHayes, 01
EJordan, AEOO
MSatorius, OE
EA File
[~cs. * f
- ~tate of Mi chi gan
RAO: RI II
SLO:RIII
PAO:RIII
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