ML18066A322

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Forwards Special Insp Rept 50-255/98-07 on 980413-1023.One Apparent Violation Identified & Being Considered for Escalated Enforcement Action.Violation Involved Inadequate Surveillance Test Procedure
ML18066A322
Person / Time
Site: Palisades Entergy icon.png
Issue date: 11/12/1998
From: Grant G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Thomas J. Palmisano
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML18066A323 List:
References
50-255-98-07, 50-255-98-7, EA-98-433, NUDOCS 9811170207
Download: ML18066A322 (3)


See also: IR 05000255/1998007

Text

EA 98-433

Mr. Thomas J. Palmisano

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION Ill

801 WARRENVILLE ROAD

LISLE, ILLINOIS 60532-4351

November 12, 1998

Site Vice President and General Manager

Palisades Nuclear Generating Plant

27780 Blue Star Memorial Highway

Covert, Ml 49043-9530

SUBJECT:

PALISADES SPECIAL INSPECTION REPORT 50-255/98007(DRP)

Dear Mr. Palmisano:

This refers to the special inspection conducted April 14, 1998, through October 23, 1998, at the

Palisades Nuclear Power Plant. The purpose of the inspection was to review the events,*

circumstances, and your staffs investigation of the Technical Specification test that rendered

both trains of high pressure safety injection inoperable on April 10, 1998. Areas inspected are

identified in the enclosed report. The inspection consisted of selective examinations of

procedures and representative records, and interviews with personnel. At the conclusion of the

inspection, the findings were discussed with members of y.our staff identified in the enclosed

report. On October 23, a re~exit was conducted with you to discuss a change in the inspection

results and to convey to you the details and circumstances regardin~ the apparent violation.

Your staff rigorously investigated this incident, identified applicable root causes, and the

identified corrective actions were thorough. However, the incident is of concern because

multiple barriers to preclude performing the inadequate test procedure failed for several years.

Based on the results of this inspection, one apparent violation was identified and is being

considered for escalated enforcement action in accordance with the "General Statement of

Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. The

apparent violation involved an inadequate surveillance test procedure. The violatiori occurred

because your staff failed to perform an adequate design review when the procedure was

revised in 1988 to incorporate the hot leg injection line into the test procedure. Also, your staff

missed several opportunities to identify this issue. Inadequate design reviews were performed

when the procedure was revised on two separate occasions and the inadequate procedure was

performed five other times in the past. In addition, your staff's failure to recognize the

applicable Technical Specification implications contributed to the event. The circumstances

surrounding the apparent violation and the corrective actions taken and planned to correct the

violation and prevent recurrrence and the date when full compliance was achieved are

adeql!atel~ addressed oo the docket in Licensee Event Report 98::-007. As a re~~lt, it may no.t

be necessary to conduct a predecisional enforcement conference in order for the NRC to make

an enforcement decision. In addition, a civil penalty may not be warranted in accordance with

Section Vl.B.2 of the Enforcement Policy since your staff identified the apparent violation and

proposed adequate correct actions.

9811170207 981112

PDR

ADOCK 05000255

G

P.DR

T. Palmisano

-2-

Before the NRC makes its enforcement decision, we are providing you an opportunity to

( 1) respond to the apparent violation addressed in the inspection report within 30 days of the

date of this letter or, (2) request a predecisional enforcement conference. If you request a

conference, it will be open for public observation and the NRC will issue a press release to

announce the conference. However, if you choose to accept the apparent violation discussed in

this report and the description of your corrective actions that are already docketed, then a written

reply to this letter or a predecisional enforcement conference is not required. Please contact

Bruce Burgess at (630) 829-9629 within 7 days of the date of the letter to notify the NRC of your

intended response.

If you Choose to respond, then your response should be clearly marked as a "Response to An

Apparent Violation in Inspection Report No. 50-255/98007" and should include for each apparent

violation: (1) the reason for the apparent violation, or, if contested, the basis for disputing the

apparent violation, (2) the corrective steps that have been taken and the results achieved,

(3) the corrective steps that will be taken to avoid further violations, and (4) the date when full

compliance will be achieved. Your response should be submitted under oath and affirmation

and may reference or include previous docketed correspondence, if the correspondence

adequately addresses the required response. If a response is not received within the time

specified or an extension of time has not been granted by the NRC, the NRC will proceed with its

enforcement decision or schedule a predecisional enforcement conference.

In addition, please be advised that the number and characterization of the apparent violations

described in the enclosed inspection report may change as a result of further NRC review. You

will be advised by separate correspondence of the results of our deliberations on this ma~er.

In accordance with 10 CFR 2. 790 of the NRC's "Rules of Practice," a copy of this letter and the

enclosure will be placed in the NRC Public Document Room (PDR). To the extent possible, your

response should not include any personal privacy, proprietary, or safeguards information' so that

it can be placed in the PDR without redaction.

Docket No.: 50-255

License No.: DPR-20

Sincerely,

/s~eoffrey E. Grant

Geoffrey E. Grant, Director

Division of Reactor Projects

Enclosure: Inspection Report 50-255/98007(DRP)

See Attached Distribution

DOCUMENT NAME:-G:\\PALl\\PAL98007.DRP

To receive a co

with attachmenVenclosure "N" = No co y

OFFICE

Riii

NAME

DATE

11/ /98

OFFICIAL RECORD COPY

T. Palmisano *

-3-

cc w/encl:

Robert A. Fenech, Senior Vice

Distribution:

President, Nuclear, Fossil

and Hydro Operations

Nathan L. Haskell, Director

Licensing

Richard Whale, Michigan

Public Service Commission

Michigan Department of

Environmental Quality

Department of Attorney General (Ml)

Emergency Management

Division, Ml Department

of State Police

CAC (E-Mail)

Project Mgr., NRR w/entl

J. Caldwell w/encl

B. Clayton w/encl

SRI Palisades w/encl

DRP w/encl

TSS w/encl

DRS (2) w/encl

/

RI 11 PRR w/encl

PUBLIC IE-01 w/encl

.

Docket File w/encl

GREENS

IEO (E-Mail)

DOCDESK (E-Mail) .

J. Goldberg, OGC

J. Lieberman, OE

B. Boger, NRR

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