ML20217K582

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000.Violation Noted:On 971017,shift Supervisor Failed to Ensure That Equipment Could Be Removed from Svc,By Failing to Ensure That TS Requirements Were Met

ML20217K582
Person / Time
Site:	Palisades
Issue date:	04/02/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217K577	List: IR 05000255/1997014 ML20217K582
References
50-255-97-14, EA-97-567, EA-97-569, NUDOCS 9804070269
Download: ML20217K582 (5)

Text

1 NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CML PENALTIES - 1 Consumers Power Company Docket No. 50-255 Palisades Nuclear Generating Plant License No. DPR-20 EA 97-567 & EA 97-569 During an NRC inspection conducted from October 28 to November 19,1997, violations of NRC requirements were identified. . In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the NRC proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),

42 U.S.C. 2282 and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:

Palisades Nuclear Power Plant Technical Specification 6.4.1.s (Amendment 174), " 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, " Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," February 1978.

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: authonties and responsibilities for safe operation (Section 1.b); equipment control (Section 1.c); maintenance that can affect the performance of safety-related equipment (Section 9.a); and control of maintenance (Section 9.e).

1. Administrative Procedure 4.00 (Revision 20 - 7/18/97), " Operations Organization, Responsibilities and Conduct," a procedure required by Section 1.b of RG 1.33, at Step 4.2.3.b.6, required that the Control Room Supervisor shall keep the Shift Supervisor informed of plant and equipment status.

Contrary to the above, on October 17,1997, the Control Room Supervisor failed to property implement Administrative Procedure 4.00 in that the Shift Supervisor was not kept informed that power would be removed from all of the control rod drive motors in order to facilitate maintenance on control rod 38. (01013)

2. Administrative Procedure 4.10 (Revision 6 - 4/30/97), " Personnel Protective Tagging," a procedure required by Section 1.c of RG 1.33, at Step 7.2.2 required that the Shift Supervisor shall ensure that equipment may be removed from service by ensuring that the Technical Specification requirements, including the Limiting Conditions for Operations and Action Statements, are met.

Palisades Nuclear Power Plant Technical Specification 3.10.4.b, Amendment 169, states, in part, that a control rod is considered inoperable if it cannot be moved by its operator and if more than one control rod becomes inoperable then the reactor shall be placed in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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i 9004070269 980402 PDR ADOCK 05000255 G. PDR

' Notice of Violation Contrary to the above, on October 17,1997, the Shift Supervisor (and the Control Room Supervisor, Shift Engineer (all licensed senior reactor operators)) failed to ensure that '

equipment could be removed from service by failing to ensure that Technical Specification requirements, including the Limiting Condition for Operation and Action Statements, were met prior to removing all the control rods from service. Specifically, power was removed from all the rods and the licensed operator failed to realize that removing power from more than one control rod required entry into a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> action to shut down the plant. (01023)

3. ~ Administrative Procedure 4.02 (Revision 15 - 6/27/97) " Control of Equipment," a -

procedure required by Section 1.c of RG 1.33, at the NOTE before step 1 of Attachment 8, " Safety Assessment for Removal of Plant Equipment (SSCs) From Service," required that Attachment 8, or an equivalent risk-based assessment, be completed for maintenance activities that met all of the following conditions:

a) entry into unplanned maintenance outages ,

b) involved high safety significant systems identified in Attachment 10 i c) would rorder the system incapable of performing its Maintenance Rule function l

d) did not occur with the equipment positioned in its designed safety position prior to removing its power source.

Contrary to the above, on October 17,1997, the licensee failed to complete Administrative Procedure 4.02, Attachment 8, or perform an equivalent risk-based assessment for the maintenance on control rod 38. Specifically, this maintenance activity: (1) was an unplanned maintenance outage isecause the corrective maintenance on control rod 38 was emergent work; (2) involved the control rod drive system which was a high safety significant system identified in Attachment 10; (3) rendered the control rod drive system incapable of performing its maintenance rule function of manual operation; and (4) did not occur with control rod 38 positioned in its designed safety position of fully inserted prior to removing its power source.

(01033)

4. Maintenance Procedure CRD-E-32 (Revision 7 - 2/21/95), "CRDM [ Control Rod Drive Motor]

Control Relays Cleaning and Inspection," a procedure required by Section 9.a of RG 1.33, at Step 3.4.2.e, required during plant operation with rods withdrawn and the clutch power supply energized that only one relay set and its related fuses be removed from service at a time.

Contrary to the above, on October 17,1997, during implementation of work order 24714120, maintenance on control rod 38, licensee personnel failed to properly implement Maintenance Procedure CRD-E-32 in that more than one control rod relay set and its related fuses were simultaneously removed from service and inspected. (01043)

I Notice of Violation 5. Administrative Procedure 5.01 (Revision 21 - 5/12/97), " Processing Work Requests / Work 1 Orders," a procedure required by Section 9.e of RG 1.33, Attachment 2, " Work Order

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Scheduling, Performance, and Completion," at Step 2.3.c, required the Assigned Supervisor to review scheduled work orders to determine the work could be performed as scheduled, and if not notify the Shift Supervisor (" scheduled" includes both the time of occurrence and manner of conduct). Step 6.1 of Attachment 2, required the work order to be replanned, per the requirements of this procedure, if the Assigned Supervisor determined that the work required to correct the problem was not adequately described in the work orderjob plan.

Step 5.11.b required the repairperson to document the "as found" conditions and the repairs / adjustments made.

Contrary to the above, on October 17,1997, during implementation of work order 24714120,

. maintenance on control rod 38, licensee personnel failed to properiy implement Administrative Procedure 5.01 in that three additional control rod drive relay contactors for control rods 3,40, and an unidentified Group Ill control rod were removed, inspected, and reinstalled. This represented a condition not allowed by the work procedure and was an unplanned and undocumented expansion of the approved work scope without the required notification to the Shift Supervisor. (01053)

6. Administrative Procedure 5.19 (Revision 6 - 4/15/97), " Post Maintenance Testing," a procedure required by Section 9.e of RG 1.33, at Step 5.2.e, required the Operations Manager to ensure that Post Maintenance Testing was property performed prior to declaring the equipment operable. Step 5.4.c required the Maintenance Supervisor to ensure that the specified post maintenance testing was revised, as necessary, if the scope of maintenance performed was changed after initial planning.

Administrative Procedure 4.02 (Revision 15 - 6/27/97), " Control of Equipment," a procedure required by Section 1.c of RG 1.33, at Step 9.3.b, required operability testing to be performed on safety-related equipment following any maintenance activity which had the potential to affect the equipment's operability.

Contrary to the above, following implementation of work order 24714120, maintenance on control rod 38, on October 17,1997, licensee personnel failed to properly implement Administrative Procedures 5.19 and 4.02. Specifically, more than one control rod relay set and its related fuses were removed from service and inspected which represented a change )

in the scope of maintenance after initial planning. However, the specified post maintenance l testing was not revised as necessary. Consequently, appropriate Post Maintenance Testing was not identified or performed. (01063)

These violations represent a Severity Level lll problem (Supplement 1). Civil Penalty $55,000.

Pursuant to the provisions of 10 CFR 2.201, Consumers Power Company (Licensee) is hereby i required to submit a written statement or explanation to the Director, Office of Enforcement, U.S.  !

Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed i

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Notice of Violation -4 l

Imposition of Civil Penalties (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged q violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an i adequate reply is not received within the time specified in this Notice, an order or a Demand for j information may be issued as why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideratum may be given to extending the response time for good cause shown. Under the authority of Sechon 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, the Ucensee may pay the civil penalties by letter addressed to the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to

.the Treasurer of the United States in the cumulative amount of the civil penalties or may protest imposition of the civil penalties in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Ucensee fail to answer within the time specified, an order imposing the civil penalties will be issued. Should the Ucensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be cleariy marked as an " Answer to a Notice of Violation" and may:

(1) deny the violations listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.

in requesting mitigation of the proposed penalties, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Ucensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalties. i Upon failure to pay any civil penalties due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attomey General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act,42 U.S.C. 2282c.

The response noted above (Reply to Notice of Violation, letter with payment of civil penalties, and Answer to e Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S.

Nuclear Fsegulatory Commission, One White Flint North,11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission,

' Region lll and a copy to the NRC Resident inspector at the Palisades Plant.

Because your response will be placed in the NRC Public Document Room, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it l

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Notice of Violation can be placed in the Public Document Room without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you my11 specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at. Lisle, Illinois this 2nd day of April 1998 l

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