ML20248D336
| ML20248D336 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/26/1998 |
| From: | Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-255-98-02, 50-255-98-2, NUDOCS 9806020393 | |
| Download: ML20248D336 (6) | |
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A CMS Dergy Company Palisades NuclearPlant Tel:616 1:4 2296 27780 Blue StarMemonalHighway fax: 316 7642425 Cowrl Mi49043 themes.&Plshulasse Site VeePresMent May 26,1998 -
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 -
DOCKET 50-255 - LICENSE DPR PALISADES PLANT REPLY TO NOTICE OF VIOLATION 50-255/98002 FAILURE TO ENSURE WATER TIGHT DOOR WAS PROPERLY SECURED NRC Inspection Report 50-255/98002(DRP) dated April 16,1998, cited one violation for
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the failure to ensure that a water tight door was properly secured. The event is significant due to the potential for disabling both trains of the Engineered Safeguards
- System during a postulated flooding event.
The response to the violation is included in Attachment 1. The response to the violation was required to be submitted within 30 days from the date of the letter transmitting the violation. It was confirmed by the Branch 6 Chief, NRC Region lil, that the response could be provided within 30 days of receipt of the letter, which was April 23,1998.
- Consumers Energy Company agrees with the violation, as written. Consumers Energy
'also concurs that our initial focus was too narrowly directed at the LOCA response safety implications, assuming no concurrent flooding, as opposed to the safety implications
- ' associated with ensuring safe operation after a flooding event. We have utilized this
. occurrence to reinforce management expectations of our staff regarding the need to apply a broad safety focus when reviewing plant events for safety significance.
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SUMMARY
OF COMMITMENTS This letter contains one new commitment and no revisions to existing commitments:
1.
General Employee Training (GET) will be revised to align with new water tight l
door dogging requirements.
Thomas J. Palmisano Site Vice President CC
Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident inspector-Palisades Attachment l
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ATTACHMENT 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION 50-255/9800241 l
FAILURE TO ENSURE WATER TIGHT DOOR WAS PROPERLY SECURED l
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ATTACHMENT 1 i
. REPLY TO NOTICE OF VIOLATION 50-255/98002-01 i
FAILURE TO ENSURE WATER TIGHT DOOR WAS PROPERLY SECURED NRC NOTICE OF VIOLATION During an NRC inspection conducted from January 28 through March 13,1998, one violation of NRC requirements was identified. In accordance with the " General l
Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Administrative Procedure 4.02, " Control of Equipment", Section 11.1a, states, " Flood doors shall be maintained operable and reflect the position / dogging requirements as identified on Plant Flood Door Checklist CL 3.4, except as detailed below:
1.
During normalingress/ egress 2.
When a person is in a room, then the door may be closed with only one dog tight."
l Checklist CL 3.4, " Plant Flood Door System Checklist," states, in part, that watertight door Number 59, the door between east and west safeguards rooms, is required to be " Closed, Fully Dogged. "
l Contrary *o the above, on January 13,1998, an activity affecting quality was not accomplished in accordance with Palisades Administrative Procedure 4.02 and associatcd Checklist CL 3.4 in that watertight door Number 59, located between the east and west safeguards rooms, was found by the licensee without any of the dogs tightened and a person was not in either room.
This is a Severity LevelIV violation (Supplement I).
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CONSUMERS ENERGY COMPANY RESPONSE l
Consumers Energy Company agrees with this violation as written.
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A(TACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-255/98002-01 FAILURE TO ENSURE WATER TIGHT DOOR WAS PROPERLY SECURED BACKGROUND At approximately 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> on January 13,1998, a maintenance worker found water tight door number 59 between the East and West Engineered Safeguards Rooms closed, but not dogged. This event is significant because the door could not have performed as designed without being closed and dogged. In addition, there were no personnel in the area to properly dog the door. The door is part of the wall separating the East and West Engineered Safeguards Rooms and is relied upon to prevent a flooding event from disabling both trains of the Engineered Safeguards System. The door is also required to maintain the fire barrier between the rooms. Upon discovery, the door was dogged closed. Subsequent investigation confirmed that door number 59 was in the undogged condition for a period of several minutes. This event was reported to the NRC in accordance with 10 CFR 50.73(a)(2)(ii)(B) as a condition outside the design basis of the plant via Licensee Event Report (LER)98-003, which was submitted on February 11,1998.
REASON FOR VIOLATION Investigation into this incident could not determine the specific circumstances which led to door number 59 being left in an undogged condition. In that none of the door's dogs were latched, we believe that the reason for the violation was an individual human performance issue. In addition, there was a lack of information at the door to help accomplish door dogging expectations. The sign on door number 59 was worn such that the posted dogging requirements were not legible. Also, since the latch handle position corresponding to a properly dogged door was not identified on the door, it may not have been read;ly apparent to the user that the door was left undogged.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The following corrective actions have been taken:
1.
This event was discussed with personnel at individual department meetings, wherein the safety implications of this event were addressed. These discussions reiterated procedural requirements and management expectations for dogging of water tight doors. Subsequently, a bulletin was distributed to all personnel (including contractors) located on site, de cribing the event and its safety significance, and reiterating procedural requirements and management expectations for dogging of water tight doors.
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A new sign has been placed on door number 59 describing dogging requirements.
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ATTACHMENT 1
' REPLY TO NOTICE OF VIOLATION 50-255/98002-01 FAILURE TO ENSURE WATER TIGHT DOOR WAS PROPERLY SECURED 3.
Water tight door number 59 was labeled to assure that the closed position of the door closure latches is readily apparent from the side of the door not having the actual closure latches.
4.
Expectations were reiterated to Maintenance, Operations, Chemistry and Health Physics personnel regarding procedural requirements for initiating a label request when worn signs are discovered in the plant.
5.
Reinforced management expectations of our staff regarding the need to apply a l
broad safety focus when reviewing plant events for safety significance.
Subsequent to this occurrence, several additional occurrences of improperly secured water tight doors have been identified. Investigation into the causes of these occurrences revealed inadequate understanding of door dogging expectations. The following additional corrective action was taken:
6.
Specific dogging requirements for each water tight door have been posted on the door itself. Personnel have been instructed to read and adhere to the posted requirements on each door.
CORRECTIVE ACTIONS REMAINING TO AVOID FURTHER VIOLATIONS The following additional corrective actions will be taken:
1.
General Employee Training (GET) will be revised to align with new water tight door dogging requirements.
2.
Maintenance Procedure MSM-M-16, " Annual Inspection of Water Tight Barriers",
will be revised to require periodic inspection of the signs on water tight doors for legibility, and to replace the signs as necessary. This action was made a regulatory commitment as part of LER 99-003.
DATE WHEN FULL COMPLlANCE WILL BE ACHIEVED Compliance was achieved on January 13,1998 when door number 59 was properly dogged.
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