ML20054F778
| ML20054F778 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/10/1982 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8206170313 | |
| Download: ML20054F778 (9) | |
Text
-
t rj y
Consumets j
Power a-" " =
l
,y'vv Nsident company
- or,,as.,
c.n.r.1 ovew.,: 194s Parnell Road. Jackson. Mschigan 49201 e (517) 7881217 June 10, 1982 kd d
5 / Y P1-R C DeYoung, Director
~
Office of Inspection and Enforcement Division of Reactor Operations Inspection US Nuclear Regulatory Commission Washington, DC 20555 3
DOCKET 50-255 - LICENSE DPR,
PALISADES PLANT - RESPONSE TO NOTICE OF VIOL 3 TION AND PROPOSED IMPOSITION OF CIVIL PENALTIES DATED MAY 12, 1982 NRC letter dated May 12,1982, (dei 6ung to Selby) transmitted a Notice of Violation and proposed imposition of civil penalties related to apparent items of noncompliance identified during an inspection conducted November 1
).
through December 18, 1981 (IE Inspection Report 50-255/81-28).
The items of noncompliance and responses thereto are as follows:
Item:
Technical Specification 3.6.1.a states that containment integrity shall not be violated unless the reactor is in cold shutdown condition.
Contrary to the above, containment integrity was violated between 1810 and 2235 hours0.0259 days <br />0.621 hours <br />0.0037 weeks <br />8.504175e-4 months <br /> on December 1h, 19BI when a manual vent path from the containment was created through the open inner personnel airlock door and open manual valve P5A-VAS. At the time of this occurrence, the facility was in a heatup and pressuri::ation phase prior to reactor startup.
3
Response
a.
Admission or Denial of the Alleged Violation.
Consumers Power Company admits the event described above did occur. This event was reported to NRC on December 28, 1981 as Licensee Event Report 50-255/81-52.
b.
Reason for Violation. The reason for establishing the vent path from containment to the auxiliary building was that containment pressure had increased (as a result of plant heatup which was in progress) to approximately 1.0 psig.
Containment pressure increases during plant heatup result from expansion of air inside containment and normally would be decreased by venting containment through the vent and purge system. However, because of problems previously identified with containment vent valves (LER 50-255/79-09), they couId not be used to vent the containment building.
To provide an alternate met.:od for reducing pressure, a vent path through a 1/2-inch line 8206170313 0
b
? :',, '
l i,
2
,RCDeYoung, Director Palisades Plant Response to Notice of Violation' and Proposed Imposition of l>
Civil Penalties Dated May 12, 1982 j
j June 10, 1982 Respo7p_e;: (Continued) e having automatic isolation capability was established. This vent path, however, had limited capacity, and was not sufficient to accommodate the buildup of pressure experienced on December 14, 1981.
In a proposed change to the Palisades Technical Specifications
)
(submitted to NRC on November 24,1980), a containment pressure limit of 1.0 psig had been proposed.
Pending NRC approval of this proposed change, an administrative limit of 1.0 psig was established. As a result, the Shift Supervisor felt compelled to reduce containment pressure. After observing that the alternate vent path was not effectively limiting containment pressure, the Shift Supervisor elected to vent containment through a three-inch manual valve.
Because primary coolant system temperature was greater than 210 F, containment integrity had to be maintained. To ensure that contain-ment integrity could be expeditiously re-established in the event of an emergency, the Shift Supervisor stationed an operator at the venting location.
In the Shift Supervisor's opinion,' having an operator stationed at the venting location satisfied containment integrity requirements of the Technical Specifications.
'i While Consumers Power Company intends to pay the civil fine levied by the NRC (a check in the amount of $16,000 is enclosed with this letter), we find it necessary to protest categorization of the containment integrity violation as Severity Level III for the
{
following reasons:
1.
The NRC's final enforcement policy (h7 FR 9987, March 9,1982) l describes a Severity Level III violation in reactor operations as significant violations involving five points.
Of these five points, two are pertinent to this event and they involve:
(1).A Technical Specification Limiting Condition for Operation (LCO) being exceeded (where the appropriate Action Statement was not satisfied) that resulted in loss of safety function or a degraded condition; and, I
sufficient information existed which should have alerted the licensee
{i that he was in an Action-Statement Condition; and, (2) A system designed to prevent or mitigate a serious safety event not being able to perform its intended function under certain conditions (e.g. safety system not operable unless offsite power is available, materials or components not environmentally qualified).
In this j
particular instance, the shift supervisor had taken a number of compensatory measures including stationing an operator at the three-e inch manual valve venting location with the ability to terminate venting upon command. Thus, while the Technical Specification in y
question was indeed violated, it is Consumers Power Company's position that the intent of the Technical Specification was met and that no loss of safety function occurred.
l
RCDeYoung, Director 3
Palisades Plant Response to Notice of Violation and Proposed Imposition of Civil Penalties Dated May 12, 1982 June 10, 1982 2.
The categorization of this violation as Severity. Level III seems.to be based in a large part on the perception.of the NRC that this violation is indicative.of a significant breakdown in management controls at the Palisades Plant. This conclusion is based upon the statement in the May 12, 1982 NRC letter that says: "Although the shift supervisor believed such actions would meet the intent of the facility techti'al specifications, l
ve are concerned that the shift supervisor aid not request guidance from either site or corporate management prior to l
unlocking the inner airlock door and opening the valve which resulted in violation of containment integrity. Also, management i
did not provide proper guidance to operating personnel on how to control pressure buildup in containment".
Consumers Power Company I
disputes the significance of these failures as evidenced by the prompt and effective actions taken by the Company in response to this violation. However, the Enforcement Policy clearly indicates that a Severity Level III citation is characterized by a loss of safety function, and while the perceived failure I
in management controls is aignicant, the Policy does not identify such failures as being of this Severity Level.
j 3
It is our opinion that the actions taken by the shift supervisor in this case could be considered as meeting the intent of the Palisades Technical Specifications.
This opinion is based on the fact that i
in a number of normal operating situations, the operator is instructed to rely on manual action for accomplishing a safety function even though i
new NRC requirements or plant Technical Specifications, if more strictly interpreted, might require automatic action. Examples of this include:
In IE Bulletin 79-06C it was stipulated that pending installation of an automatic. trip feature, an operator should be stationed in the control room in order to trip primary coolant I
pumps in the event of safety injection system initiation.
In another instance, PWR facilities were requested by NRC to station an operator in the control room to initiate auxiliary feedvater flow under emergency conditions, until installation of automatic initiation circuitry could be completed. The most >ecent example is Consumers Power Company letter of June 2, 1982 entitled " Technical Specification Clarification for Containment Isolation Valve Testing" which states, that based upon discussion with the NRC staff and Combustion-Engineering Standard Technical Specifications, unrestricted boron sampling of safety injection tanks will be performed by permitting manual containment isolation valves to be opened provided that at least one manual valve is closed within four hours.
RCDeYoung, Director h
Palisades Plant Response to Notice of Violation and Proposed Imposition of Civil Penalties dated May 12, 1982 June 10,1982 c.
Corrective Actions Taken and Results Achieved. The Shift Supervisor involved was removed from shift supervision duties pending re-evaluation of his comprehension of Technical Specificati'on' requirements. A meeting with Shift Supervisors and Shift Technical Advisors was con-ducted to provide a briefing regarding this event. The advisory role of the Shift Technical Advisor was stressed. Additional training in Technical Specification requirements has been provided to Shift Supervisors, Shift Technical Advisors, and Duty and Call Superintendents.
The containment exhaust system has been modified such that two, eight-inch vent paths, each having automatic isolation capability, are available whenever containment pressure must be reduced.
d.
Corrective Actions Which Will be Taken.
No further action with respect to this noncompliance is contemplated.
e.
Date When Full Compliance Will be Achieved.
All corrective actions have been completed.
Item:
Technical Specification 6.8.1.a requires implementation of applicable procedures in Regulatory Guide 1.33, Appendix A (November 1972).
Appendix A relates to procedures for performing maintenance which can affect the performance of safety-related equipment. Palisades Maintenance Procedure CRD-M-13, " Control Rod Drive Mechanism Seal Housing Replacement," a procedure which addresses safety-related component performance, specifies the installation of the flexitalic gasket (Step 5.h.3) before the installation of the seal housing assembly (Steps 5.h.h through 5.h.7).
Contrary to the above, during maintenance on Control Rod Drive Mechanism No. 3 on October 2h, 1981, the flexitalic gasket was installed after the seal housing assembly.
Therefore, there was no gasket at the pressure boundary between the reactor coolant system and the containment building atmosphere. This resulted in a primary coolant leak which was identified during hydrostatic i
l testing.
l
Response
a.
Admission or Denial of the Alleged Violation. The event described above did occur, and was reported to NRC on December 29, 1981 as Licensee Event Report 50-255/81 h9 b.
Reasons for the Violation. During reinstallation of seal housing components for control rod drive mechanism (CRDM) Number 3, the seal housing gasket was improperly installeu, in that it was apparently not placed in its specified location within the seal housing. As a result, an inadequate seal existed and leakage occurred through the seal housing.
l RCDeYoung, Director 5
j Palisades Plant Response to Notice.of Violation and Proposed Imposition of Civil Penalties Dated May 12, 1982 June 10, 1982 l
l
Response
(Continued)
The procedure being used specified the correct gasket location, and also required verification by the supervisor in charge of the work that the gasket had been correctly installed. The supervisor was in the area.where the work was being performed, was able to observe the repairman during the CRDM seal installation sequence, and based on the activity he was able to observe, concluded that the seal housing components had been properly installed.
However, the supervisor did not personally inspect the seal housing to verify proper assembly.
t c.
Corrective Actions Taken and Results Achieved. 7te seal housing for CRDM number 3 was reassembled in accordance with the procedure.
The crew which had performed the assembly of CRDM number 3 had also assembled another seal housing, which was subsequently opened, inspected and found to have been properly assembled.
i The repairman and the supervisor involved were disciplined.
Maintenance Supervisors have been briefed regarding this event l
(particular emphasis was placed on the significance of verification signatures as they apply to completed maintenance activities).
Procedures related to Maintenance Department Administration have i
been revised to clarify the meaning of verification signatures.
d.
Corrective Actions to be Taken.
No further action with respect I
to this item is contemplated.
e.
Date When Full Compliance Will be Achieved. The corrective actions described above have been completed.
Item:
Technical Specification 6.8.la requires implementation of applicable l'
procedures in Regulatory Guide 1.33, Appendix A (November 1972). Appendix A relates to procedures for performance of safety-related equipment. Palisades Administrative Procedure 5. " Maintenance Administration," requires that, follo, wing emergency maintenance on safety-related equipment, the Plant Review Committee (PRC) shall complete a review (Paragraph 5.1.2.1) and and Equipment Outage Report (EOR) shall be completed (Paragraph 5.2.12.2) pricr to declaring affected equipment operable.
Contrary to the above, emergency maintenance was performed on January 19, 4
1981.
A test valve on a sprinkler line in the southwest cable penetration room was replaced and the system was declared operable before the licensee
[
performed a PRC review or completed an EOR. A PRC review was conducted about three months later,
RCDeYoung, Director 6
i Palisades Plant Response to Notice of Violation and Proposed Imposition of Civil Penalties Dated May 12, 1982 June 10, 1982 j
Response
a.
Admission or Denial of the Alleged Violation.
The event described above did occur.
b.
Reasons for the Violation. Failure to obtain the required reviev j
resulted from oversight on the part of supervisory personnel.
j c.
Corrective Actions Taken and Results Achieved.
The necessary reviews related to the emergency maintenance performed on January 19, 1981 were satisfactorily completed.
i d.
Corrective Actions to Prevent Recurrence.
The requirement to obtain a PRC review. following emergency maintenance has been reevaluated and determined not to be necessary or important to safety. Accordingly, i
j this requirement has been deleted from procedures related to administration i
of maintenance activities.
The requirements related to processing of an Equipment Outage Request following emergency maintenance, but prior to declaring affected equipment operable, vill be reviewed with maintenance, but prior to declaring affected equipment operable, vill be reviewed with maintenance and operations supervisory personnel, I
e.
Date When Full Compliance Will be Achieved. Palisades is currently in full compliance with Administrative Procedures related to emergency maintenance. The reviews to be conducted with the supervisory personnel vill be completed by September 1, 1982.
gj 18 sud Russell B DeWitt Vice President Nuclear Operations CC Director, Office of Nuclear Reactor Regulation Administrator, Region III, USNRC Resident Inspector - Palisades i
CONSUMERS POWER COMPANY Palisades Plant RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES DATED MAY 12, 1982 Docket 50-255 License DPR-20 At the request of the Commission and pursuant to the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974, as amended,.and the -
1 Commission's Rules and Regulations thereunder, Consumers Power Company submits our response to Notice of Violation and Proposed Imposition of Civil Penalties Dated May 12, 1982.
1 i
CONSUMERS POWER COMPATH BY
/
M[
v R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 10th day of June 1982.
Tbd f
~bl/kY/Y Dorothy H Bartkus, Notary Public I
Jackson County, Michigan My commission expires March 26, 1983 l
I l
l I
l k --
W /
e 0
Stock Form li t4 Octoeer 196*
T. ele *ha G AO Manual BILL FOR COLLECTION Bill No.
U. S. Nuclear Regulatory Commission 6-14-82 Date.
4De E
Wa sh i ng to n, ddrimeEe o855abhshment and Bureau or Office; 0
(Address)
P.i TER:
Consumers Power Company Tai, nu s4.i,ld 6, r,ss,r,,rd by <A, Jaekson, Michigan 49201 pai,r w,43 Ai,r,mistant,.
SEE INSTRE:CTIONS BELO W.
Unit Price Date DESCRIPTION Quantity Amount Cost Per 6-14-82 In payment of the civil penalty imposed on 5-12-82 for containment integrity violation Civil Penalty of $16,000 EA 82-25
$16,000. 00 D oc e E7 S T) _2 53--
a
,.w, E
' s
, y#
%>71
- 4 fop /
N 3
3 3.-
J
=
4
%%}A (.4 N
0%-
\\e
[.Y 16,000.joo
.I.ttol *.\\T DrE 't tits niu..
S Thi, is not a receipt 13.4Tli t '(.TIO N.s l'. nil. i..I p.n im ns..I t he ala n r hill m.n he maile m..nh. I ' mini Staen inntal monn uriter, e spress m.mn oriler. hank drait, or check, te. s h..ishe r unin atral
% h temler, w brn m ans
..s her for m than. ash sh..uhl hc.iraw n t.. the oveler of ihr liepartment or Est.ibbshment a nel 'bo r.ue..i t ittu r unin.itral ab n e R e. re pu w ill h. nu..Iin all..n.s wtoir. ash" is re n e el..uwi mh op.in e r lurst w hen ernustan. r n m ans inhrr inrm if tender
..t p.u no n e
..t i h n i. ! n.n h. : than..nh.o I nue.i States p. st al m..n n
..s i b i t he t e e ript s hall n..i h....mr a n e..puitant e u ntil such trn.b h.n I n. l.....!.uul s tu a nnunu r. e en. 4 In i h.-
liep.. senn m..e 1.srahtishun nt ami Iba r..u.o t Ith. r unin ain t alan c.
- Inho, e..i...
- s... s... p s t.. a..n h p.n n u n e s h....l.1 h.
pe...npi h s e p.u :.. I t.s ihr p.n.
to t he. lurt..iminnti atis c uthter of the hu e..m.... g. n. s i n. m...... I it
.s.
..s e v
..t s n o en
....i.
CONSUMERS POWER COMPANY No.NSJ 29449:
OATE SECLENCE NO 06/09/32 TaEASU453 0F THE UMITED STATES C403C6 f
l NCTE
%C'CE 3 055 C.? VENT m x A$(CACge NET l
y
.ovea.
- Art 2veuNr auctsi
,,..m.
Avouur CK73-0733 16,0CgCO l
16,00q0C IN PAYMi:NT CF THE CIVIL PENALTY l '1 POSED CN CCB SUP ERS PC*aER COMPA fiY PALISADSS F LANT CN 5/12 /62 FOR CC NTAINMENT I AT,EGF ITY VICLATIqN CIVIL PENAL TY OF $16,0C O.00 l
l i
i PAYABLE 517i7SE l
PAYMENT I? CUIRE5 - CAL L ACCCUNT:
-0741 l
l l
l t
l i
f I
l l
l l
l l
I l
l
\\
l l
l t
l i
l l
l
(
l l
l T TAL i
16.GodOO
' "5lla','l,i :E'Mn'c'~ e..c.
5 : L".u2...TE.. '.'21~Cc
- a^rt' Ara n
.....e
...r
. 60 Cq Power Consumers
.724 company No.
294496 JACKSON, MICHIGAN CHECK CA TE SEC NO Pav TMr$ AveyN T 06/09/92 040306 516,000.C0
'f5"!
TREASURER 0F THE UNITED STATES l
" ',!'fe J4',"!!! !!".^r'e
l U S NUCLEAR REGULATCRY COMP WASHINGTCN OC 20555 CONSUMERS POWER COMPANY SPECIAL ACCOUNT o
THE Naf TON AL B ANK OF J ACMSON aacasom w.cm can TREASURER