ML18059B045
| ML18059B045 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/06/1994 |
| From: | Rogers D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9406130133 | |
| Download: ML18059B045 (13) | |
Text
consumers*
Power POW ERi Nii
/llllCHlliAN"S PROliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 June 6, 1994 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
.. \\ *'
David W. Rogers Plant Safety and Licensing Director DOCKET 50-255 - LICENSE DPR PALISADES PLANT - REPLY TO NOTICE OF VIOLATION - INSPECTION REPORT 94002 - SERVICE WATER SYSTEM OPERATIONAL PERFORMANCE INSPECTION NRC Inspection Report No. 94002, dated March 4, 1994, documented the results of the Service Water System Operational Performance Inspection {SWSOPI}.
The inspection report identified an apparent violation involving five examples where inadequate or no corrective actions were taken to previously identified concerns.
An enforcement conference was held at Region III headquarters on March 11, 1994, where we presented our initial assessment of the causes that allowed the violation to occur and our immediate and proposed long term actions to address the issues the NRC had raised.
NRC letter dated May 6, 1994, forwarded a Notice of Violation and Proposed Imposition of Civil Penalty {Notice} for a violation considered to represent a significant breakdown in the control of the Palisades corrective action program.
By letter dated May 24, 1994, payment of the civil penalty was made by Consumers Power Company as directed in the Notice.
We recognize that the civil penalty could have been significantly higher had the NRC not exercised discretion by considering our continuing aggressive actions to improve performance at the Palisades plant.
In late 1993 and early 1994, we initiated enhancements which address all matters warranting improvements at Palisades.
To ensure that the improvements are being integrated, planned, and managed such that improved performance is achieved and sustained, CPCo has created the Palisades Performance Enhancement Plan
{PPEP}.
The PPEP is a living document that will be revised to reflect*
completion of various action plans, to incorporate additional actions for objectives that may not be fully accomplished, and to address emergent issues.
We agree that weaknesses in management oversight and communications 9406130133 940606 bDR ADOCK 05000255 PDR A CM5 ENERGY COMPANY
contributed to our engineering organizations not fully understanding the design of the service water system and lacking clear definition of wh~ was responsible for maintaining the design. These weaknesses resulted in our failure to recognize and promptly correct the system design deficiencies noted in the inspection. Therefore, we agree that additional scrutiny of engineering activities is essential.
To this end, we are aggressively addressing design ownership and engineering standards and expectations.
We have established clear ownership for the plant design in the Nuclear Engineering and Construction Organization (NECO) and are strengthening the organization to fully assume the duties of design ownership.
Engineering standards and expectations are being addressed through increased management attention to plant priorities and significant enhancements to the plant corrective action process.
As a result, plant design issues are being given an appropriately high priority and engineering is aggressively working to resolve design issues.
In addition; improvements to our design engineering processes have been or are being made.
These improvements will help assure that future changes to the plant are consistent with the design basis and that the needs of the plant are being addressed.
They include more stringent standards for technical reviews of engineering work, a requirement for a multi-disciplinary review of design engineering and quality verification plans for modifications, and an engineering manager approval of all modifications.
The enclosure provides our response to the Notice of Violation and the concern of a signifitant breakdown in the control of the corrective action program.
. (1,,;r/_ ltJ. Q_~
David W. Rogers Plant Safety and Licensing Director CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Enclosure
CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.
By iJU{~
Robert A. Fenech, Vice President Nuclear Operations Sworn and subscribed to before me this ~
day of June 1994.
LeAnn Morse, Notary Public Beirien County, Michigan (Acting in Van Buren County, Michigan)
My commission expires February 4, 1997
[SEAL]
ENCLOSURE Consumers Power Company Palisades Plant Docket 50-255 REPLY TO NOTICE OF VIOLATION 50-255/94002 June 6, 1994 5 Pages
1 REPLY TO NOTICE OF VIOLATION Violation 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part,* that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the conditl'on is determined and corrective action taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action shall be documented and reported to the appropriate levels of management.
Contrary to the above, as of January 27, 1994, the licensee had failed to promptly correct significant conditions adverse to quality as demonstrated by the following examples:
A.
The licensee identified on May 25, 1989, and documented in its Component Cooling Water (CCW) Safety System Design Confirmation (SSDC) report, that backup cooling to_the Engineered Safeguards System (ESS) pumps from the Service Water System (SWS) could not be accomplished during a loss of coolant accident with a loss of offsite power because non-safety related instrument air was required for valve actuation. This was a significant condition adverse to quality in that the failure to provide cooling water to the ESS pumps could result in eventual pump failure.
B.
- c.
The licensee identified on May 17, 1990, and documented in its SWS SSDC report that the non-critical header isolation valve; CV-1359, was not included in the leakage test program.
This was a significant condition adverse to quality in that leakage through valve CV-1359 could affect the SWS's capability to perform its intended safety-related function at elevated lake temperatures.
The licensee identified on January 4, 1994, that the instrument tubing and unistrut supports located in front of the CCW heat exchangers were bent but failed to take prompt corrective action to evaluate the condition for seismic requirements. As a result of this failure and NRC prompting, the licensee's subsequent analysis, which was performed on January 24, 1994, determined that the tubing did not meet FSAR Section 5.7 requirements for allowable stress.
D.
On Hay 4, 1990,* the licensee identified and documented in its SWS SSDC report that the SWS inservice test pump reference values were not coupled to the SWS flow balancing test. The licensee failed to take prompt corrective action to address this condition which created the potential for the SW pump performance to degrade below minimum system flow requirements.
- f.
On May 4, 1990, the licensee identified and documented in its SWS SSDC report that SWS test T-216, "Service Water Flow Verification," Revision 4, balanced flow to the CCW heat exchangers at or very near their required flow rates.
The licensee failed to take prompt corrective action to address this condition adverse to quality which left little or no margin for reduced SWS flow that could result from SW pump degradation.
Admission of the Alleged Violation CPCo agrees with the violation.
Reason for the Violation As a result of internal and external investigations of the plant's corrective action system, CPCo determined that some previously identified discrepancies had not been corrected in a timely or comprehensive mannei.
These investigations revealed examples, in addition to those cited in the Notice of Violation, of failure of Palisades plant to fully evaluate identified discrep~ncies and provide complete implementation of the corrective actions.
This. represented a substantial decline in the control and implementation of the corrective action program.
The investigation did not identify a single cause for the deterioration of the corrective action program but identified several major causes which collectively contributed to the program's ineffectiveness. The causes are:
Inadequate individual performance.
Process problems presented barriers to performing evaluations, documentation, tracking, action definition, implementation, and assessment.
Management had not made clear its standards and expectations for the corrective action process and had not consistently enforced the existing standards.
2 Management had not fostered a strong nuclear safety culture which encourages a questioning attitude, critical self-assessment, and conservative decisions. Strict license interpretations were used instead
- of employing engineering approaches to problems.
There was a tendency to provide a legal response to a technical concern.
Limited experienced personnel impeded adequate planning and tmplementation of the work process.
3 Corrective Actions Taken and Results Achieved
- 1.
In mid to late 1993, CPCo and the NRC identified a decline in performance at Palisades and in early 1994 CPCo initiated a number of actions to enhance the Palisades performance.
CPCo has established a new management team for Palisades, increased management direction and oversight of plant activities, and communicated new management standards and expectations.
CPCo is also making improvements in design basis information and in the control of modifications. Furthermore, CPCo has made a number of improvements to its self-assessment program, corrective action process, and operability determinations, and has performed reviews and evaluations of plant systems, programs, and departments to confirm their adequacy for continued safe operation.
- 2.
The Corrective Action Process has been substantially upgraded in several respects.
The revised process lowers the threshold for including events in the corrective action program so that non-consequential events are captured, analyzed, and trended. All conditions affecting installed plant equipment are now reviewed for the effect on eqtiipment operability.
In addition, a reportability review is conducted for all conditions identified. A new screening group has been established to identify those conditions which are significant and need plant management attention and detailed root cause analysis.
The Corrective Action Review Board review of.significant items was improved through more structured meetings.
Completed root cause evaluations are being reviewed by a Management Review Board (MRB}, which has a quorum of three department managers.
For events that are reportable to the NRC or other significant events, the MRB is chaired by the Plant General Manager.
CPCo has identified the need for further revisions to improve both the root cause evaluations and analysis of trend data.
In addition; to monitor.the effectiveness of the changes~ the Nuclear Performance.
Assessment Department (NPAD} will conduct an assessment of the root cause evaluation process at Palisades.
- 3.
An evaluation was initiated to assess the failure to take adequate or prompt corrective action for the significant deficient condition~
identified during the service water system operational performance i~spection and determine the extent of the condition.
The evaluation assessed the technical adequacy of closure of those Safety System Design Confirmation (SSDC} Observations which had been elevated to corrective action documents (AIRs and DRs} in six representative important mechanical and electrical systems.
The evaluation concluded that a
~significant number (16 of 49 corrective action documents assessed}
contained inadequate determination and/or implementation of corrective action at *the time of closure.
As a result of this assessment, additional reviews of all open and completed SSDC Observations were initiated and are expected to be complete by August 1, 1994.
4 In preparation for restart from the current maintenance outage, all the open and closed SSDC related corrective action documents were reviewed for potential operability concerns.
As a result of reviewing all SSDC Observations which had been elevated to a corrective action document, it was discovered a total of six issues represented potential operability conce~ns not identified when the SSDC Observation was initially presented.
Four of these six had previously been elevated to a corrective action document and had received an operability determination.
Thus, only two new issues resulting from this operability review required an operability determination. These were appropriately addressed.
In addition, a review of Design Basis Documents (DBD) open items produced no new issues to be resolved prior to startup.
Corrective Actions to Avoid Future Non-Compliance Various assessments have identified performance issues facing Palisades.
Numerous corrective actions and enhancements have been identified and initiated.
To confirm that these actions address all areas warranting improvement, and to ensure that the improvements are integrated, planned, and managed such that improved performance is achieved, CPCo established the Palisades Performance Enhancement Plan (PPEP).
The PPEP.incorporates mechanisms to ensure that the corrective actions and enhancements will be implemented in a timely manner and that the actions will be effective in achieving and sustaining improved performance.
Each of the causes identified for the decline in the corrective action program are being addressed on a priority basis through the PPEP.
Action plans have been developed and are being implemented to support a number of objectives.
Of these, the following PPEP Objectives relate to the issues described in this violation:
Establish Clear Roles and Responsibilities - Objective 1.2 Establish Aligned Management Standards and Expectations - Objective 1.3 Define Management Information Needs - Objective 1.5 Determine Scope of Work - Objective 2.1 Establish an Improved Planning and Prioritization Process - Objective 2.2 Improve the Corrective Action Process - Objective 2.3 Establish a Root Cause Process Using the HPES Program as a Basis -
Objective 2.7 Enhance Employee Knowledge and Skills - Objective 3~1
Define and Conununicate the NOD Nuclear Safety Philosophy - Objective 4.1 Establish a Strong Sensitivity to the Plant's Design Basis - Objective 4.2 Establish a Program to Improve Plant Design Margin - Objective 6.1 Enhance the Quality of Design Basis Documentation - Objective 6.2 -
Corrective actions for the five specific examples cited in the Notice of Violation are addressed in Attachment 1 of this enclosure.
Date of Full Compliance Full compliance has been achieved *.
5
ATTACHMENT 1 OF THE ENCLOSURE Consumers Power Company
. Palisades Plant Docket 50-255 CORRECTIVE ACTIONS FOR THE SPECIFIC EXAMPLES IDENTIFIED IN NOTICE OF VIOLATION 94002 June 6, 1994 3 Pages
CORRECTIVE ACTIONS FOR THE SPECIFIC EXAMPLES IDENTIFIED IN NOTICE OF VIOLATION 94002 The Notice of Violation identified five examples of the failure t6 promptly correct significant conditions adverse to quality which were confirmed by our evaluations and were determined to have been caused by the reasons previously enumerated.
In addition to the programmatic enhancements for the overall performance improvements at Palisades, the following specific actions have been taken or are planned for the examples cited in the NOV.
Example A The licensee identified on May 25, 1989, and documented in its Component Cooling Water (CCW) Safety System Design Confirmation (SSDC) report, that backup cooling to the Engineered Safeguards System (ESS) pumps from the Service Water System (SWS} could not be accomplished during a loss of coolant accident with a loss of offsite power because non-safety related instrument air was required for valve actuation. This was a significant condition adverse to quality in that the failure to provide cooling water to the ESS pumps could result in eventual pump failure.
Corrective Actions
- 1.
The immediate corrective action was to place CCW valves CV-0913 and CV-0950 in their safety position {open) to eliminate the identified single active failure.
1
- 2.
A safety evaluation has been prepared for operating the plant in the new valve configuration. Additionally, a PRA evaluation concluded the valve.*
configuration with CV-0913 and CV-0950 normally open will eliminate the potential for the single failure of the CCW cooling to the ESS pumps.
- 3.
An analysis of Engineered Safeguard System pump cooling requirements will be performed to establish definitive cooling requirements for each of the safeguards pumps.
This analysis is needed to establish a correct design basis for the cooling of the pumps.
The analysis is expected to be concluded by June 30, 1994.
- 4.
A design review of the CCW and SWS systems, including a single failure analysis of the systems, wil 1 be performed and is expected to* be
___ comp 1 eted by December 1, 1994.
- 5.
While the current condition meets the license requirements, system modifications to improve the reliability of ESS pump cooling {beyond opening CV-0913 and CV-0950), resulting from the evalu~tions above, will be installed during a future refueling outage.
2 Example 8 The licensee identified on Hay 17, 1990, and documented in its SWS SSDC report that the non-critical header isolation valve, CV-1359, was not included in the leakage test program.. This was a significant condition adverse to quality in that leakage through valve CV-1359 could affect the SWS's capability to perform its intended safety-related function at elevated lake temperatures.
Corrective Actions
- 1.
A recent ~valuation concluded that leak testing of CV-1359 should be performed to permit a more accurate assessment of the Service Water*
System flow margins.
The evaluation also concluded corrective action is necessary when leakage through CV-1359 becomes excessive.
- 2.
A corrective action has been initiated to develop leak testing methods for CV-1359 and to implement testing. The testing is expected to be completed by the 1995 refueling outage.
- Example C The licensee identified on January 4, 1994, that the instrument tubing and uni strut_ supports located in front of the CCW heat exchangers were bent but failed to take prompt corrective action to evaluate the condition for seismic requirements.
As a result of this failure and NRC prompting, the licensee's subsequent analysis, which was performed on January 24, 1994, determined that
- the tubing did not meet FSAR Section 5.7 requirements for a11owab7e stress.
Corrective Actions
- 1.
An Engineering Analysis was prepared to address the seismic adequacy of the as-installed configuration of the instrument tubing lines from MV-CC-624 to HV-CC-6248 and from MV-CC-625 to MV-CC-6258.
It was determined that the instrument tubing meets the plant's operability criteria.
- 2.
A corrective action was initiated to modify the tubing to conform with FSAR requirements and has been completed.
- 3.
- A corrective *action was initiated to move or protect, as necessary, the instrument tubing and uni strut supports located in front of the CCW heat exchangers during the 1995 refueling outage when significant maintenance work is planned in the vic~nity of this tubing.
- 4.
The work order review process is being enhanced to include a timely*
review of work orders by the system engineers. Administrative Procedure 5.01, "Processing Work Requests/Work Orders," will be revised by June 15, 1994, to provide directions for informing system engineers of equipment status associated with their assigned systems.
- 5.
Continuing training for systems engineers will be provided on lessons learned regarding operability issues such as instrument tubing span criteria and hanger integrity criteria and will be completed by 3
October 1, 1994. This completion date is a delay from the July 1, 1994 date that was presented in the enforcement conference.
The delay is due to resource requirements for the present outage.
In addition, during the outage, extensive walkdowns of instrument tubing were performed by qualified structural engineers to assess its operability. Necessary corrective actions were taken to correct deficiencies and ensure operability.
Example p 1.*
On May 4, 1990, the licensee identified and documented in its SWS SSDC report that the SWS inservice test pump reference values were not coupled to the SWS flow balancing test.
The licensee failed to take prompt corrective action to address this condition which created the potential for the SW pump performance to degrade below minimum system flow requirements.
Corrective Actions
- i.
Reviews of the basis for reference values and. allowed degradation for all Section XI pump tests to ensure they are adequately coordinated with safety analysis performance criteria will be performed by August 1, 1994.
- 2.
A multi-disciplinary evaluation of the translation of analysis inputs and assumptions into system functional testing performance criteria will be performed by August 1, 1994. This evaluation will consider the establishment of testing methodologies for each system and include consideration of instrument inaccuracies and system degradation.
Example E On May 4, 1990, the licensee identified and documented in its SWS SSDC report that SWS test T-216, "Service Water flow Verification," Revision 4, balanced flow to the CCW heat exchangers at or very near their required flow rates.
- The licensee failed to take prompt corrective action to address this condition.
adverse to quality which left little or no margin for reduced SWS flow that could result from SW pump degradation.
Corrective Actions
- 1.
A recent evaluation of the hydraulic performance of the Service Water System concluded the Service Water System has adequate margin to provide equipment serviced by critical service water. Adequate margin exists for lake.temperatures up to 85°F when all the allowed system degradations, including pump degradation, are considered.