ML18065B068
| ML18065B068 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/18/1996 |
| From: | Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9611260039 | |
| Download: ML18065B068 (12) | |
Text
~I consumers Power POWERING llllCHlliAll'S l'IUllilfBS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 November 18, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT Thomas J. Palmlsano Plant General Manager REPLY TO NOTICE OF VIOLATION FOR TWO VIOLATIONS REPORTED IN INSPECTION REPORT NO. 50-255/96008 NRC Inspection Report No. 50-255/96008 contains a Notice of Violation which concerns a failure to follow Palisades Administrative Procedure 4.02, "Control of.
Equipment". Two examples were given of the failure to follow Section 5.3.4.f of AP 4. 02 which provided specific conditions to be satisfied before Non-Operations Department personnel would be allowed to operate plant equipment.--Attachment*1 --
contains our response to this violation.
NRG Inspection Report No. 50-255/96008 also contains a Notice of Violation which concerns a failure to adhere to Technical Specifications (TS) 6.2.2.b. TS 6.2.2.b requires at least one Senior Reactor Operator to be within the control room at all times during conditions other-than cold shutdown and refueling.* Two examples were given 'Of* * - -- -----
this failure. This violation was reported to the NRC by Consumers Power Co. in Licensee Event Report 95-012, "Technical Specification Violation Due to No Senior Reactor Operator in Control Room". Attachment 2 contains our response to this
/
violation.
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1 9611260039 POR ADOCK G
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961118 05000255 PDR A CM5 Ne?GY COMPANY
SUMMARY
OF COMMITMENTS This letter contains 2 new commitments and no revisions to existing commitments.
These commitments are:
2
- 1.
Appropriate department managers will review the NRC violation regarding the control of equipment and its two examples with Department personnel.
These department managers are to reinforce their expectations on equipment control requirements of Administrative Procedure 4.02.
- 2.
Operations Department will conduct a self assessment to identify if any similar equipment control occurences have taken place that would warrant further corrective action.
'_,.-*J/7~~
Thomas J. Palmisano Plant General Manager CC Administrator, Region 111, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades 2 Attachments
ATTACHMENT 1 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION 96008 CONTROL OF EQUIPMENT 5 Pages
NRC VIOLATION ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 96008-01 CONTROL OF EQUIPMENT During a NRG inspection conducted on July 27, 1996, through September 6, 1996, violations (sic) of NRG requirements were (sic) identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions,"
NUREG-1600, the violations are (sic) listed below:
- 1.
10 CFR 50 Appendix B, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Administrative procedure 4.02, "Control of Equipment," section 5.3.4f., states, in part, "Non-Operations Department personnel may operate valves and/or Plant equipment within a clearance boundary as directed by approved Plant procedures OR with the specific approval of the Shift Supervisor".
- a.
Contrary to the above, on August 4, 1996, a system engineer manipulated the fuel rack on the emergency diesel generator 1-1 during a surveillance,
- which was not covered by the procedure or authorized by the Shift Supervisor.
- b.
Contrary to the above, on August 20, 1996, an electrical maintenance technician operated the supply ventilation fan to the emergency diesel generator 1-2 room without pmper authorization of the Shift Supervisor of (sic) addressed by the tagout boundary.
This is a Severity Level IV violation (Supplem~nt I).
CONSUMERS POWER COMPANY RESPONSE
Background
Diesel Generator Technical Specification Surveillance Testing Monthly Technical Specification Surveillance MO-?A-1 was being performed on diesel generator 1-1 on August 4, 1996. The diesel was started and initially ran unloaded satisfactorily. Approximately five to seven minutes into the unloaded portion of the test, the diesel engine governing system began oscillating. The
magnitude of the oscillation at the fuel control shaft arm was +/- one-eighth to three-sixteenths inch of travel.
The operator tending the diesel generator became concerned. with its performance upon observing the governing system oscillation. He indicated to the system engineer that unless the oscillation stea~ied out soon he was going to stop the diesel and abort the test. The system engineer knew that the governing system oscillations were sporadic and difficult to repeat from experience. Recognizing an opportunity may be lost to learn more about the oscillation response and the ability to provide a better judgement on diesel generator operability, the system engineer applied hand pressure to the fuel rack to determine if the oscillation would steady out and/or dampen. The system engineer stated that he knew his action was being taken without the consent of the Shift Supervisor and that it would have to be subsequently reconciled regarding its impact on the test and diesel generator performance.
Diesel Generator Room Supply Fan Generator preventive maintenance was being performed on August 20, 1996 by two plant electricians. This work activity required the diesel generator to be removed from service.
During the electricians' work, the diesel generator room air supply fan cycled intermittently on and off. This hindered their ability to communicate to each other due to the noise level and to follow and maintain their procedure due to the air.
disturbance when the fan was running. The lead electrician took it upon himself to eliminate this nuisance by adjusting the room supply fan thermostat to a sightly higher temperature setting to prevent the fan from starting. The lead electrician then restored the thermostat to its original setting upon completion of their activity.
Operating and/or manipulating ancillary components occasionally that are not important to plant operating or support systems is common for non-operations personnel. Examples are office or workshop components such as lighting controls, low voltage electrical distribution and protection devices, water and air
. system components, heating. ~n9 vE:mtllation contro.ls, communication devices, and office machines.
This practice is sometimes extended into locations where operating and support systems exist. Individuals who interface extensively with operations personnel achieve a high degree of confidence in recognizing components, similar to those mentioned above, that are not sensitive to plant operations. Rather than burdening a Senior Reactor Operator with a request and for the sake of 2
efficiently accomplishing the activity, these components are occasionally operated without explicit consent of a Senior Reactor Operator.
The electrician in this event knew the administrative equipment control requirements. However, he operated the diesel generator room air supply fan controls given:
- 1.
The assumption that it was a typical commercial thermostat similar to those in office areas and worksnops.
- 2.
The thermostat setpoint would be temporarily adjusted for a _short duration with the setpoint being returned at the completion of the activity.
- 3.
The assumption that diesel generator room air supply had no operational significance, especially since the diesel generator was tagged out for personnel protection during maintenance.
The electrician did not realize that the diesel generator room ventilation had recently taken on a higher degree of importance regarding the operation of the.
- diesel generators.
System Operating Procedure SOP-22, "Emergency Diesel Generators," identifies the operability requirements for operation of the diesel generator room ventilation.
Since he did not know the significance of the diesel generator room ventilation, the electrician erroneously manipulated the diesel generator room supply fan thermostat without the awareness or consent of a Senior Reactor Operator.
General 3
The program requirements for equipment operation by non-operations department personnel are contained in Administrative Procedure 4.02, "Control of Equipment." These requirements define the components that may be operated and the controls to be applied. These requirements are reinforced and communicated further in other programs su_c.h as t_he n.i~in_teng,oce work.o[d_er.
-*-pro~fram, the confracfor control. program, and t_he general employee training program. These programs and requirements provide a high degree of confidence that personnel are aware of their responsibility toward equipment control.
Equipment manipulations by non-operations personnel are more likely for ancillary equipment than for equipment that directly supports plant operation.
For the latter equipment, strict compliance is typical.
Reasons for Violation In the first example, the system engineer chose to steady the fuel rack during the test.
He did this under the assumption that there would be no impact on nuclear safety or irreconcilable consequenses on the test validity.
In the second example, the individual understood there could be no nuclear safety consequenses since the diesel generator was out of service. He also believed that explicit approval by the Senior Reactor Operator was not required to operate the thermostat.
Both of the examples can be attributed to inadequate sensitivity to* the requirements of Administrative Procedure 4.02.
Corrective Action Taken and Results Achieved Diesel Generator Technical Specification Surveillance Testing Technical Specification Surveillance Test M0-7A-1 was performed on August 14, 1996, without intervention with the function of the fuel rack. The acceptance criteria were satisfactorily met. _
Diesel Generator Room Supply Fan The diesel generator room supply fan thermostat was_ re!LJ_rn~d to its_ Qriginal setting upon completion of the maintenance-activity.
General The inappropriate actions described in these events were brought to the attention of the individuals involved. The equipm~nt con__trolrequirements of Administrative Procedu-re 4.02-were reinforced.
Corrective Actions Remaining to Avoid Further Violations Appropriate department managers will review the NRG violation regarding the control of equipment and its two examples with department personnel. These department 4
managers are to reinforce their expectations on equipment control requirements of Administrative Procedure 4.02.
Operations Department will conduct a self assessment to identify if any similar equipment CO[ltrol occurences have taken place that would warrant further corrective action.
Date Full Compliance Will Be Achieved August 1, 1997 5
ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION 96008-02 SENIOR REACTOR OPERA TOR NOT IN CONTROL ROOM DURING POWER OPERATIONS 3 Pages
e--
ATTACHMENT 2 REPLY TO NOTICE OF VIOLATION 96008-02 SENIOR REACTOR OPERA TOR NOT IN CONTROL ROOM DURING POWER OPERATIONS NRC VIOLATION During a NRG inspection conducted on July 27, 1996, through September 6, 1996, violations (sic) of NRG requirements were (sic) identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions,"
NUREG-1600, the violations are (sic) listed below:
- 2.
Technical Specifications 6.2.2b., requires; inpart, that at least one licensed Senior Reactor Operator shall be in the control room at all times during conditions other than cold shutdown and refueling.
Contrary to the above, on August 9, and again on August 13, with the plant at full power, for less than one minute there were no senior reactor operators present in the control room who were cognizant of ongoing plant conditions.
This is a Severity Level IV violation (Supplement/).
CONSUMERS POWER COMPANY RESPONSE
Background
The Control Room and the Shift Supervisor's office were undergoing extensive remodeling from July 20, 1996, through August 31, 1996. This project prompted Operations Management to review the requirements for minimum manning included in Technical Specification 6.2.2.b and Administrative Procedure 4.00 "Operations Organization, R_esponsibilities, and Conduct," section 5.2.. 1. Both re.quire that an SRO be present in the Control Room. Under normal circumstances, three SROs work out of the Control Room: the Shift Supervisor, the Control Room Supervisor, and the Shift Engineer.
Administrative Procedures define the Control Room proper to be the area containing the ~Q~ipme.ni operating panels as well as the Shift Supervisor's.office. -During the initial phase of the project, the Shift Supervisor's office was demolished, thereby making it inaccessible. The Shift Engineer's desk was temporarily moved from the Shift Supervisor's office to the adjacent Viewing. Gallery area, which is visually part of the Control Room in that only a windowed wall separates the two areas. The normally-closed door between the Viewing Gallery and Control Room was designated as the primary entry into the Control Room, and was propped open. It was decided that.
redefining the Control Room proper to include the temporary Shift Engineer's area was
not necessary because of the ability to maintain the Control Room Supervisor's desk in the Control Room during the project.
On August 9, 1996, a relief SRO replaced the normal "A" shift (0000-0800 hours)
Control Room Supervisor. A question arose on a Technical Specification Surveillance Procedure operability determination. This question heightened the Control Room Supervisor's need to seek resolution by consulting with another SRO. Knowing that he would be briefly leaving the "at-the-controls" (ATC) area, he walked into the temporary Shift Engineer's area, assuming it to be part of the Control Room much like the former Shift Supervisor's office. The Shift Supervisor inquired why the Control Room Supervisor left the Control Room. The estimated time that the Control Room Supervisor was out of the Control Room was less than one minute. Additionally, the Control Room and Control panels were observable from the Viewing Gallery via the large windows between the two areas.
Immediate corrective action was taken by Operations Management by discussing the event with the SRO and entering a reminder in the August 9 Daily.Orders for all oncoming shifts that the Viewing Gallery (temporary Shift Engineer's area) was not considered part of the Control Room. On August 13, 1996, a follow-up memo was sent to all SR Os advising them of this occurrence; reinforcing the expectation that an SRO is required to be in the Control Room, and reiterating that the Viewing Gallery was considered to be outside the Control Room.
The second occurrence happened on August 13, 1996, when the normal on-shift Shift*
Engineer relieved the Control Room Supervisor as the SRO in the Control Room. The Shift Engineer was processing a work order. The work order would have normally been processed in the Shift Supervisor's office, but due to the remodeling, the processing location had been temporarily relocated into the adjacent Technical Support Center.
Without consciously thinking, the Shift Engineer proceeded out of the Control Room to place the work order in the relocated processing area. The Shift En_g!neer i~_meqiat~ly returned to the Control Rooni where the.Control Room-Supervisor had returned and identified the Shift Engineer's error.
Coincidentally, during this second occurrence, another SRO was in the Control Room performing a Control panel walkdown in preparation to take shift turnover. Having this 2
SRO !r:t 9q~trol Roqm tech!'1ically satisfied the JechniQal Specific~tio_ruequirement,.. buL___ _ _ __ _
did not meet the Operations Department expectation as this individual was not, at the time, an on-duty SRO.
3 Reason for Violation The first example occurred because of an individual's misunderstanding of the Control Room boundary limits during the remodeling process. The second example was due to a momentary lapse of attention.
Corrective Action Taken and Results Achieved The August 9, 1996, incident was reported to the NRC pursuant to the requirements of 10 CFR Part 50. 73(a)(2)(1). Immediate corrective action was taken by Operations Management by discussing the event with the SRO and entering a reminder in the August 9 Daily Orders for all oncoming shifts that the Viewing Gallery (temporary Shift Engineer's area) was not considered part of the Control Room. On August 13, 1996, a follow-up memo was sent to all SR Os advising them of this occurrence; reinforcing the expectation that an SRO is required to be in the Control Room, and reiterating that the Viewing Gallery was considered to be outside the Control Room.
Further corrective actions resulted from the second incident on August 13, 1996. First, Operations Management discussed the ev~nt with the involved SRO. Second, the door between the Control Room and the temporary Shift Engineer's desk was closed in an attempt to make it less convenient for an SRO to inadvertently leave the Con~rol Room.
The Operations Manager and/or the Shift Operations Supervisor discussed with the
- immediately available SR Os their responsibility to maintain an SRO in the Control Room at all times. SROs were reminded to pay particular attention to the Control Room boundary as it changed with the remodeling. This was captured as an entry on the SRO turnover sheet as a reminder for SROs who did not participate in the discussions.
Corrective Actions Remaining to Avoid Further Violations There are no outstanding corredive actions-on this.fasue.
Date Full Compliance Will Be Achieved N_Q f11db~f__.9Qr~~.ctiv~ a_ctic;>_ns are_!_"lec~SS8:ry._ J.h~_Qo11tr_9I_ ~9..Q~.r~_'!1__9deling __ P..!91~.2.t~~s_.:_ __
been completed. The Shift Supervisor, Shift Engineer, and Control Room Supervisor.
have now been restored to their normal locations.