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)

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

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• 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

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• 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

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• 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

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• 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

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• 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.

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* --*--* ---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.

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.. ... . , 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 . .

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