ML18067A642

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-255/97-05.Corrective Actions:Both Leaking Piping Plugs (One Plug Per Valve) Were Permanently Repaired by Installed New Forged Steel One Inch Pipe Plugs

ML18067A642
Person / Time
Site:	Palisades
Issue date:	07/23/1997
From:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-97-05, 50-255-97-5, NUDOCS 9707300038
Download: ML18067A642 (14)

See also: IR 05000255/1997005

Text

• Consumers

A CMS Energy Company July 23, 1997 U.S. Nuclear Regulatory

Commission

ATTN: Document Control Desk * Washington, DC 20555 Palisades

Nuclear Plant 27780 Blue Star Memorial Highway Covert. Ml 49043 DOCKET 50-255 -LICENSE DPR-20 -PALISADES

PLANT Tel. 616 764 2296 Fax: 616 764 2425 Tllomn J. Palmluao Site Vice President

REPLY TO NOTICE OF VIOLATION

FOR THREE VIOLATIONS

REPORTED IN INSPECTION

REPORT NO. 50.:.255/97005

NRC Inspection

Report No. 50-255/97005

contains three Notice of Violations (NOV). The first NOV, designated

No. 97005-01, concerns a Code violation

resulting

from unauthorized

repairs to the main steam isolation

valve stuffing box plugs. Specifically, extensive

material was removed from existing pipe plugs in the valves without verifying

that the required minimum wall thickness, in accordance

with USAS 831.1.0, was maintained.

The second NOV, designated

No. 97005-02, concerns the failure to properly submit a 10 CFR 50.73 Licensee Event Report (LER) within the required time frame. Specifically, the LER was submitted

on March 21, 1997, 70 days after the January 10, 1997, discovery

date. The required submittal

period is 30 days. \ < v \. The third-NOV, designated

No. 97005-03, concerns three examples of a failure to follow * procedures

associated

with the repair of pipe plugs for the main steam isolation

valves. ,\\ * * 9707300038

970723 PDR ADOCK 05000255 G PDR I llllll 111111111111111111111111111111111

• I I 4 I I A. *

• * 2 The Consumers

Energy Company response to the violations

is included in the attachments.

Attachment

1 contains the reply to NOV 97005-01, "Repair Not Performed

in Accordance

With Original Construction

Code". Attachment

2 contains the reply to NOV 97005-02, "Failure to Submit Licensee Event Report Within 30 Days of Discovery".

Attachment

3 contains the reply to NOV 97005-03, "Failure to Follow Procedures".

Consumers

Energy Company agrees with all of the violations

as written. SUMMARY OF COMMITMENTS

This letter contains no new commitments

and no revisions

to existing commitments.

Thomas J. Palmisano

Site Vice President

CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector-:

Palisades

3 Attachments

• ATTACHMENT

1 CONSUMERS

ENERGY COMPANY PALISADES

PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION

FOR THREE VIOLATIONS

REPORTED IN INSPECTION

REPORT NO. 50-255/97005

REPAIR NOT PERFORMED

IN ACCORDANCE

WITH ORIGINAL CONSTRUCTION

CODE 3 Pages

• ATTACHMENT

1 REPLY TO NOTICE OF VIOLATION

97005-01 REPAIR NOT PERFORMED

IN ACCORDANCE

WITH ORIGINAL CONSTRUCTION

CODE NRC NOTICE OF VIOLATION

During an NRG inspection

conducted

on March 1 through April 11, 1997, violations

of NRG requirements

were identified.

In accordance

with the "General Statement

of Policy and Procedure

for NRG Enforcement

Actions," NUREG-1600, the violations

are (sic) listed below: 1. 10 CFR 50.55a, "Codes and Standards," Paragraph (g), "lnservice

Inspection

Requirements," Paragraph

(4), states in part that components

classified

as* ASME Code Class 1, 2, and 3, must meet the requirements, except for design, set forth in Section XI of the ASME Boiler and Pressure Vessel Code. ASME Boiler and Pressure Vessel Code,Section XI, Paragraph

IWA-4210, "Repair Procedures, Rules and Requirements," states in part that repairs shall be performed

in accordance

with the original Construction

Code of the component.

The original Code of Construction

for valves CV-0501 and CV-0510 was USA Standard (USAS) B31. 1 (sic), "Power Piping." Contrary to the above, repairs made to valves CV-0501 and CV-0510, on November 17, 1996, using Work Orders WO 24512907 and'WO 24610966, respectively, were not performed

in accordance

with the original Code of Construction, USAS B31.1 (sic), in that extensive

material was removed from existing pipe plugs in the valves, without verifying

that the Code required minimum wall thickness

was met. This is a Severity Level IV violation (Supplement

I). CONSUMERS

ENERGY COMPANY RESPONSE Consumers

Energy Company agrees with this violation

as written.

__ Licensee Event Report 97-005, submitted

on March 21, 1997, provides additional

background information for

this Notice of Violation

and is incorporated

herein by reference . 1

-* * ATTACHMENT

1 REPLY TO NOTICE OF VIOLATION

97005-01 REPAIR NOT PERFORMED

IN ACCORDANCE

WITH ORIGINAL CONSTRUCTION

CODE Reasons for Violation

During planning for these repairs, Work Order specifications

were issued which would have assured code compliance

if properly implemented.

A failure to implement

the * specified

requirements

caused the violation.

The failure to properly implement

the repair resulted from a failure to follow procedures, a lack of a questioning

attitude, and a lack of single point accountability

for the job. Corrective

Action Taken and Results Achieved 1. Both leaking pipe plugs (one plug per valve) were permanently

repaired by installing

new forged steel one inch pipe plugs which met the code requirements.

2. The Operations

Manager and the Maintenance

Manager spoke to the repair workers and technicians

at a stand down meeting regarding

expectations

for high levels of performance.

The Lead Supervisors

presented

the lessons learned from the MSIV work. The presentations

focused on procedural

adherence, roles and responsibilities, work scope control, communications, use of self-checking

and conservative

decision making. 3. The Maintenance

Manager sent a memo to all Maintenance

and Planning Department

supervisory

personnel

which described

the effect that pre-job brief communication

failures had on the work that led to the MSIV steam leaks. The memo focused on the importance

of multi-discipline

briefings

in preparing

for effective

crew briefings.

The proper use of sketches within the Weld Inspection

Checklist

Process has been clarifiecf

illthe Administrative

Procedures . 2

-* * * ATTACHMENT

1 REPLY TO NOTICE OF VIOLATION

97005-01 REPAIR NOT PERFORMED

IN ACCORDANCE

WITH ORIGINAL CONSTRUCTION

CODE Corrective

Actions Remaining

to Avoid Further Violations

A pre-job brief workshop will be developed

and implemented

to establish

and communicate

pre-job brief expectations

and to improve repair worker participation.

Included within this

workshop will be: 1. The identification

of multi-discipline

tasks in the 13-Week Schedule Process. 2. The assignment

of a single point of contact. 3. The improvement

of readiness

reviews and pre-job briefs. The planned completion

date is December 31, 1997. Date Full Compliance

Will Be Achieved Full compliance

has been achieved with the proper repair to the pipe plugs on CV-0501 and CV-0510 . 3

' . * ATTACHMENT

2 CONSUMERS

ENERGY COMPANY PALISADES

PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION

FOR THREE VIOLATIONS

REPORTED IN INSPECTION

REPORT NO. 50-255/97005

FAILURE TO SUBMIT LICENSEE EVENT REPORT WITHIN 30 DAYS OF DISCOVERY

3 Pages

.. -* * ATTACHMENT

2 REPLY TO NOTICE OF VIOLATION

97005-02 FAILURE TO SUBMIT LICENSEE EVENT REPORT WITHIN 30 DAYS OF DISCOVERY

NRC NOTICE OF VIOLATION

During an NRG inspection

conducted

on March 1 through April 11, 1997, violations

of NRG requirements

were identified.

In accordance

with the "General Statement

of Policy and Procedure

for NRG Enforcement

Actions," NUREG-1600, the violations

are (sic) listed below: 2. 1 O CFR 50. 73, Licensee Event Report, states in part that the holders of an operating

license for a nuclear power plant (licensee)

shall submit a Licensee Event Report (LER) for any of the type described

in this paragraph

within 30 days after the discovery

of the event. The licensee shall report any event or condition

that resulted in the condition

of the nuclear power plant, including

its principal

safety barriers, being degraded, or that resulted in the nuclear power plant being in a.condition

that was outside the design basis of the plant. Contrary to the above, the licensee failed to submit a Licensee Event Report within 30 days after the discovery

on January 10, 1997, of an event concerning

the degraded stuffing boxes on the main steam isolation

valves. This is a Severity Level IV violation (Supplement

I). CONSUMERS

ENERGY COMPANY RESPONSE Consumers

Energy Company agrees with this violation

as written. Background

Condition

Report (CR) No. C-PAL-97-0007

was originated

on January 3, 1997, after the leaks in the main steam isolation

valves (MSIVs) were discovered

on December 20, 1996. The original reportability

determination

was made based on the information

contained

in the original CR. Since the valves had not been disassembled

at this point, this CR contained

no information

about the potential

for a piping code violation

or th_e origin of the steam leaks:-*The-*tic*ensing

personnel

classified

the condition

as a steam leak similar to those experienced

on the MSIVs during other startups and determined

it to be not reportable . 1

--* * ATTACHMENT

2 REPLY TO NOTICE OF VIOLATION

97005-02 FAILURE TO SUBMIT LICENSEE EVENT REPORT WITHIN 30 DAYS OF DISCOVERY

Temporary

repairs were attempted

on January 6, 1997 on the leaking plugs but were unsuccessful

when unexpected

leak patterns developed

during the drilling operation

on the plugs. On January 7, 1997, the evaluator

of C-PAL-97-0007

recognized

that the plug that was required to be removed on CV-0501 had not been removed. Thus information

existed at this time to recognize

that a code violation

existed. On about January 10, 1997, the evaluator

of C-PAL-97-0007

briefed the Licensing

Manager on the current status of the investigation

into the MSIV steam leak on the pipe plugs. The Licensing

Manager believed the information

he was reviewing

had been made available

to the Licensing

personnel

who would make the reportability

determination.

However, responsible

Licensing

personnel

had not been notified, and as a result no reportability

determination

was made. During a March 6, 1997, Management

Review Board (MRS) meeting, it was realized that this issue had a high potential

for reportability

to the NRC and a reportability

determination

was made. It was determined

that the condition

was reportable

and Licensee Event Report LER 97-005 was submitted

to the NRC on March 21, 1997. Reasons for Violation

The reason for this violation

was an inadequate

sensitivity

by Maintenance

and Licensing

personnel

to reportable

situations.

Also contributing

was poor communication

between Licensing

and Maintenance

personnel

and within the Licensing

Department.

The Licensing

Manager understood

that additional

information

was being obtained in the way of laboratory

test results and that the reportability

determination

could not be made until material compatability

was established

using test results. In addition, the Licensing

Manager expected that the information

being presented

to him was available

to the Licensing

personnel

who would be making the reportability

decision.

The process in place allowed a single error by a Licensing

representative

to create a late reportability

determination

which is not acceptable.

---

* --*--* ---2

ii* --* ATTACHMENT

2 REPLY TO NOTICE OF VIOLATION

97005-02 FAILURE TO SUBMIT LICENSEE EVENT REPORT WITHIN 30 DA VS OF DISCOVERY

Corrective

Action Taken and Results Achieved All Licensing

personnel

have been counseled

on the need to be sensitive

to reportable

situations.

All Management

personnel, including

those persons participating

in MRBs and Corrective

Action Review Boards, have been briefed on the conditions

which led to this violation.

In addition, the Licensing

Department

reorganized

to focus reportability

determinations

into one group under a Regulatory

Response Supervisor.

The purpose of this new Licensing

Section is to specifically

respond to immediate

and short term issues. Corrective

Actions Remaining

to Avoid Further Violations

The following

additional

action is intended to enhance the reportability

determination

process. The Reportability

Determination

process will be modified to: a. Require additional

documentation

of reportability

determinations

and reassessments.

b. Require a second level of review for initial reportability

determinations

and reassessments.

The planned completion

date is August 1, 1997. Date Full Compliance

Will Be Achieved Palisades

Nuclear Plant was in full compliance

since March 21, 1997 when LER 97-005 was submitted

and the reportability

was completed.

3

ATTACHMENT

3 CONSUMERS

ENERGY COMPANY PALISADES

PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION

FOR THREE VIOLATIONS

REPORTED IN INSPECTION

REPORT NO. 50-255/97005

FAILURE TO FOLLOW PROCEDURES . ....,... "e--* **----------3 Pages

It ATTACHMENT

3 REPLY TO NOTICE OF VIOLATION

97005-03 FAILURE TO FOLLOW PROCEDURES

NRC NOTICE OF VIOLATION

During an NRG inspection

conducted

on March 1 through April 11, 1997, violations

of NRG requirements

were identified.

In accordance

with the "General Statement

of Policy and Procedure

for NRG Enforcement

Actions," NUREG-1600, the violations

are (sic) listed below: 3. 10 CFR 50, Appendix B, Criterion

V, "Instructions, Procedures, and Drawings," requires 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.

Contrary to the above: a. On November 16, 1996, an activity affecting

quality, the seal weld on the main steam isolation

valve CV-0510-pipe

plug was not as described

in the Weld Inspection

Checklist

for Work Order No. 24610966, Procedure

No. 5.05 (sic). b. On November 16, 1996, an activity affecting

quality, the seal welded configuration

for main steam isolation

valve CV-0501 pipe plug was not . performed as described

in the Weld Inspection

Checklist

for Work Order No. 24512907.

c. On November 16, 1997 (sic), Work Order Nos. 24610966 and 24512907, were not available

at the work site for the main steam isolation

valves, CV-0501, and 0510, as required by Administrative

Procedure

5.01, Attachment

2, * "Work Order Scheduling, Performance, and Completion," Section 4. 1, which states, in part, "a working copy of the work order shall remain at the work site whenever work is in progress." This is a Severity Level IV violation (Supplement

I). 1

ATTACHMENT

3 REPLY TO NOTICE OF VIOLATION

97005-03 FAILURE TO FOLLOW PROCEDURES

CONSUMERS

ENERGY COMPANY RESPONSE Consumers

Energy Company agrees with this violation

as written. Background

Licensee Event Report 97-005, submitted

on March 21, 1997, provides additional

background

information

for this Notice of Violation

and is incorporated

herein by reference.

Reasons for Violation

The root cause for failure to implement

the plug seal welds in accordance

with the Welding Inspection

Checklists

and to maintain the Work Order at the job site was the failure to follow maintenance

procedures

requiring

such actions. A lack of single point accountability

for the job failed to identify and resolve this failure as part of the work implementation.

An inadequate

questioning

attitude contributed

to the failure to identify the problem. Corrective

Action Taken and Results Achieved 1. Both leaking pipe plugs (one plug per valve) were permanently

repaired by installing

new forged steel one inch pipe plugs which met the code requirements.

2. The Operations

Manager and the Maintenance

Manager spoke to the repair workers and technicians

at a stand down meeting regarding

expectations

for high levels of performance.

The Lead Supervisors

presented

the lessons learned from the MSIV work. presentations

focused on procedural

adherence, roles and responsibllities, work scope control, communications, use of self-checking

and conservative

decision making. The Maintenance

Manager sent a memo to all Maintenance

and Planning Department

supervisory

personnel

which described

the effect that pre-job brief communication

failures had on the work that led to the MSIV

leaks. The __ _ memo focused on the importance

of multi-discipline

briefings

in preparing

for effective

crew briefings.

3. The proper use of sketches within the Weld Inspection

Checklist

Process has been clarified

in the Administrative

Procedures.

2

.. ... . , ATTACHMENT

3 REPLY TO NOTICE OF VIOLATION

97005-03 FAILURE TO FOLLOW PROCEDURES

Corrective

Actions Remaining

to Avoid Further Violations

A pre-job brief workshop will be developed

and implemented

to establish

and communicate

pre-job brief expectations

and to improve repair worker participation.

Included within this workshop will be: 1. The identification

of multi-discipline

tasks in the 13-Week Schedule Process. 2. The assignment

of a single point of contact. 3. The improvement

of readiness

reviews and pre-job briefs. The planned completion

date is December 31, 1997. Date Full Compliance

Will Be Achieved Full compliance

has been achieved with the proper repair to the pipe plugs on CV-0501 and CV-0510 . .

3