ML18068A425

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Forwards Response to Violations Noted in Insp Rept 50-255/98-10.Corrective Actions:Operations Personnel Were Briefed on Equipment Control Events & Coached on Raising Performance Expectations for Equipment Status Control
ML18068A425
Person / Time
Site: Palisades Entergy icon.png
Issue date: 08/28/1998
From: Thomas J. Palmisano
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-98-10, NUDOCS 9809090177
Download: ML18068A425 (5)
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I* . eansumers Energy"">

A OMS Energy eompany Palisades Nuciear Plant Tel: 616 764 2296 27780 Blue Star Memorial Highway Fax: 616 764 2425 Covert. Ml 49043 J'1JolDn J. PtlhalAao Site Vice President j

  • i August28, 1998

.i i

U.S. Nuclear Regulatory Commission A TIN: Document Control Desk

  • PALISADES PLANT REPLY TO NOTICE OF VIOLATION FROM INSPECTION REPORT 50-255/98010 NRC Inspection Report 50-255/9801 O(DRP), dated July 30, 1998, cited one violation.

The violation involves two instances of failure to maintain plant equipment in the proper configuration during safety-related activities.

Consumers Energy agrees with the violation as written.

SUMMARY

OF COMMITMENTS This letter contains one new commitment and no revisions to existing commitments.

The new commitment is: *

1. Procedure RT-SC and RT-SD will be revised prior to their next use to. ensure .11* I appropriate test boundaries are procedurally established.

a__J_w.~

-Po r Thomas J. Palmisano

  • SiteNice President- .

CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment 9809090177 980828 PDR ADOCK 05000255 G PDR

ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION 50-255/98010-02 INADEQUATE CONFIGURATION CONTROL

  • 3 Pages

ATTACHMENT REPLY TO NOTICE OF VIOLATION 50-255198010-02 INADEQUATE CONFIGURATION CONTROL NRC NOTICE OF VIOLATION During an NRC inspection conducted from May 7 to July 1, 1998, one violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Palisades Nuclear Power Plant Technical Specification 6.4. 1.a, "Procedures,"

requires, in part, that written procedures shall be implemented covering the applicable procedures recommended in Regulatory Guide (RG) 1. 33, Revision 2, Appendix A, .uTypical Procedures for Pressurized Water Reactors and Boiling Water Reactors, " February 19 78.

RG 1. 33, Revision 2, Appendix A, states, in part, that the following are typical safety-related activities that should be covered by written procedures: .uEquipment Control" (Section 1.b).

Administrative Procedure (AP)-4. 02, Revision 15, 4/20198, "Equipment Control," a procedure required by Section 1.b of RG 1.33, at Step 4.4, required that the Shift Supervisor was responsible for maintaining proper plant configuration.

Contrary to. the above:

A. On May 16, 1998, during performance of surveillance refueling test 0

procedure (RT)-8C, Engineered Safeguards System - Left Channel," Revision 10, 5115198, a safety-related activity, the Shift Supervisor failed to maintain proper plant configuration in that the safety injection tank pressure control valves' manual isolation valves ES-3038, ES-3042, ES-3046, and ES-3047 were not closed.

8. On May 1 7, 1998, *during performance of Standard Operating Procedure (SOP)-4, "Containment Spray System," Revision 19, Section 7. 1. 2, To Fill Safety Injection Tanks T-82A, T-828, T-82C, and T-820 With Primary Coolant System Depressurized and Shutdown Cooling in Service," a safety-related activity, the Shift Supervisor failed to maintain proper plant configuration in that manual valve (MV) CRW724 in the vent path to the waste gas system was not open.

_T.bisjs_a_Se_v..erit_y_Le.vel IV violation (Supplement I). -

CONSUMERS ENERGY COMPANY RESPONSE Consumers Energy Company agrees with the violation as written .

    • 1

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  • ATTACHMENT REPLY TO NOTICE OF VIOLATION 50-255/98010-02

. INADEQUATE CONFIGURATION CONTROL BACKGROUND A. On May 16, 199S, with the plant in cold shutdown for refueling, Operations was performing Refueling Test (RT)-SC, "Engineered Safety System-Left Channel", in order to fulfill Technical Specification testing requirements for left channel safeguards and emergency power equipment. During test setup, Operations staff noted that the Primary System Drain Tank (PSDT) was overflowing to the Containment Sump. Investigation revealed that the Safety Injection T*ank (SIT) Pressure Control Valves' (PCV) manual isolation valves were open, providing a flow path.to the PSDT from the inservice Shutdown Cooling pump. This improper' configuration resulted in approximately 1,200 gallons of water being transported to the Containment Sump.

Since procedure RT-SC opened each of the SIT pressure control valves during test setup, either the manual isolation valves or the downstream header control valve would have needed to have been closed to prevent water transfer to the PSDT. However, positioning of these valves was not addressed by RT-SC.

Additionally, equipment status control was not maintained in that caution tags hung from the SIT PCV controllers located in the Control Room stated that the manual isolation valves were closed. However, the manual isolation valves had been opened during restoration of workmans' protective tagging earlier in the day. Consequently, the informatio~ on the caution tags was in error.

B. On May 17 199S, .while refilling the Safety Injection Tanks (SITs), the I

evolution was temporarily secured due to an unexpected pressure rise during the fill process. Investigation revealed that the pressure rise was the result of no vent path being established for the SITs. The vent path, which was intended to be *established by procedural direction, was isolated at a point further downstream in the vent piping due to an unrelated concurrent activity.

REASONS FOB VIOLATION

1. Technical Specification Surveillance Procedure BT-SC did not specify all of

tbe_necessar_y_e_quip_mem.t alignm~nts to ensure J_hat an appropriate test boundary was established. * -- -

2. Utilization* of administrative tools for equipment status control lacked sufficient rigor to ensure that an appropriate awareness of plant system 2

ii ATTACHMENT REPLY TO NOTiCE OF VIOLATION 50-255/98010-02 INADEQUATE CONFIGURATION CONTROL configuration was maintained. The high volume of equipment realignments and evolutions which occurred at the time, with the plant in a refueling outage, was a contributing factor.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED

1. Operations personnel were briefed on equipment control events and coached on raising performance expectations for equipment status control.
2. A comprehensive audit of principle equipment control records including Turnover Sheets, Equipment Status Control Records, Degraded Equipment List, and Caution Tag Log was performed. Several discrepancies were found and resolved. Weekly follow-up audits of the Caution Tag Log were performed for the duration of the outage. Currently, monthly caution tag log audits are being performed.
3. Management expectations for the review of surveillance procedures have been strengthened. This has resulted in more detailed operator reviews of surveillance procedures prior to performance of the tests to identify and correct deficiencies. These reviews are ongoing.

CORRECTIVE ACTIONS REMAINING TO AVOID FURTHER VIOLATIONS

1. Procedure RT-SC and RT-SD will be revised prior to their next use to ensure appropriate test boundaries are procedurally established.
2. A more robust tool for equipment control will be developed to track equipment realignments. This tool will be especially helpful during high volume periods, such as during refueling outages. Currently, an electronic database is being evaluated which would have the capability to cross-reference between the principle equipment manipulation mechanisms (eg, System Checklists, Switching and Tagging Orders). This database would be used to flag out-of-position components and conflicts among the various equipment manipulation mechanisms.

PATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Compliance was achieved upon alignment of the valves to their proper positions.

Howey~r._iti~ unqe_r~tood that in orderJo achieve full compliance, RT-BC andHT,,.80 must be revised and a more robust.tool for equipment control will need to be established, as discussed above.

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