ML18065B117
| ML18065B117 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/12/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18065B118 | List: |
| References | |
| 50-255-97-14, EA-97-567, NUDOCS 9712220075 | |
| Download: ML18065B117 (3) | |
See also: IR 05000255/1997014
Text
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December 12, 1997
EA 97-567
Mr. T. Palmisano
Site Vice President and General Manager
Palisades Nuclear Generating Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT:
NRC SPECIAL INSPECTION REPORT 50-255/97014(DRS)
Dear Mr. Palmisano:
This refers to the special inspection conducted on October 28 through November 19, 1997, at
the Palisades Nuclear Power Plant. The purpose of the inspection was to determine whether
activities authorized by the license were conducted safely and in accordance with NRC
requirements. At the conclusion of the inspection, the findings were discussed with those
members of your staff identified in the enclosed report.
Areas inspected are identified in the enclosed report. The inspection was conducted to review
the events and circumstances surrounding removal of power from all the control rods to perform
maintenance on a* single control rod drive on October 17, 1997. The inspection consisted of
selective examinations of procedures and representative records, and interviews with
personnel.
Based on the results of this inspection, two apparent programmatic problems involving multiple
violations were identified and are being considered for escalated enforcement action in
accordance with the "General Statement of Policy and Procedure for NRC Enforcement
Actions" (Enforcement Policy), NUREG-1600. There were multiple apparent violations
regarding conduct of operation activities which included: (a) the breakdown in crew
communications; (b) the failure to ensure that equipment could be removed from service by
ensuring that Technical Specification limiting conditions for operations were met prior to
removing the equipment from service; (c) the failure to complete the required risk-based
assessment prior to maintenance; (d) the failure to perform operability testing following
maintenance activities that had the potential to affect equipment operability; and (e) the failure
to perform post maintenance testing prior to declaring equipment operable. There were also
multiple apparent violations regarding maintenance activities which included: (a) the failure to
satisfy the control rod drive system conditions required by the maintenance procedure; (b) the
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T. Palmisano
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December 12, 1997
failure to identify that the maintenance activity could not be performed as scheduled; (c) the
failure to _replan the work order prior to expanding the work scope; (d) the failure to revise the
testing requirements after the work scope was changed; and (e) the failure to document the
work performed.* These violations represent the failure of multiple barriers designed to ensure
safe plant operations.
In addition, we are concerned by your staff's actions to not question the appropriateness of
removing power from all the control rods while at power, returning control rod drive equipment *
to an operable status without conducting post maintenance testing, and the apparent lack of
understanding of the appropriate Technical Specification by control room operators. Also, we
are concerned that on night shifts, you reduce the margin of safety by decreasing the level of
management oversight for maintenance activities.
No Notice of Violation is presently being issued for these apparent violations. In addition,
please be advised that the number and characterization of apparent violations described in the
enclosed inspection report may change as a result of further NRC review.
A predecisional enforcement conference to discuss these apparent violations has been
scheduled for 1 :00 pm CST, December 19, 1997, at the Region Ill office. The decision to hold
a predecisional enforcement conference does not mean that the NRC has determined that a
violation has occurred or that enforcement action will be taken. This conference is being held to
obtain information to enable the NRC to make an enforcement decision, such as a common
understanding of the facts, root causes, missed opportunities to identify the apparent violations,
corrective actions, significance of the issues and the need for lasting and effective corrective
action. In addition to the specific apparent vilations, please address your views on the concerns
described above. Finally, we want you to address why you have assurance that these broad
failures that occurred In the operations and maintenance areas are not prevalent in other
routine activities.
In addition, this is an opportunity for you to provide any information concerning your
-perspectives on (1) the severity of the violations, (2) the application of the factors that the NRC
considers when it determines the amount of a civil penalty that may be assessed in accordance
with Section Vl.B.2 of the Enforcement Policy, and (3) any other application of the Enforcement
Policy to this case, including the exercise of discretion in accordance with Section VII.
You will be advised by separate correspondence of the results of our deliberations on this
matter. No response regarding these apparent violations is required at this time.
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.
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T. Palmisano
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December 12, 1997
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
Original Signed by J. Grobe
Docket No. 50-255
License No. DPR-20
John A. Grobe, Director
Division of Reactor Safety
Enclosure: Inspection Report 50-255/97014(DRS)
cc w/encl: .
Robert A. Fenech, Senior Vice President,
Distribution
Nuclear, Fossil and Hydro Operations
Thomas C. Berdine, Licensing Manager
Richard Whale, Michigan Public
Service Commission
Michigan Department of Environmental Quality
Department of Attorney General (Ml)
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A. B. Beach, Riii w/encl
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