ML18065B208

Responds to NRC Ltr Re Violations Note in Insp Rept 50-255/97-18 on 971206-980127.Corrective Actions:Placed High Pressure Air (Hpa) Sys in Maintenance Rule Category (a) & Addl Emphasis Placed on Sys Health Repts

ML18065B208
Person / Time
Site:	Palisades
Issue date:	04/06/1998
From:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-97-18, NUDOCS 9804130319
Download: ML18065B208 (5)

Text

• * .i -A*CMS*Energy Company April 6, 1998 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555 . Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert. Ml 49043 DOCKET 50-255 -LICENSE PPR-20 -PALISADES PLANT Tel: 616 764 2296 Fax: 616 764 2425 J. l'allaluao Site Vice President REPLY TO NOTICE OF VIOLATION DESCRIBED IN INSPECTION REPORT NO. 50-255/97018, FAILURE TO TAKE ADEQUATE CORRECTIVE ACTION NRC Inspection Report No. 50-255/97018 contains a Notice of Violation (NOV) *regarding a failure to take adequate corrective action. The Consumers Energy Company reply to the violation is included in the attachment to this letter. The reply to the violation was required to be submitted within 30 days from the date of the letter transmitting the violation.

Discussion with Bruce Burgess (NRC Region Ill) on . March 9, 1998, confirmed that the 30-day requested response could be provided within 30 days of receipt of the letter, which was March 6, 1998. Consumers Energy Company accepts the violation as written.

SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments. (LJ' 4). f6..-Thomas J. Palmisano Site Vice President

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

-Palisades Attachment 9804130319 980406 PDR 05000255 G PDR

. . ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION DESCRIBED IN INSPECTION REPORT NO. 50-255/97018 FAILURE TO TAKE ADEQUATE CORRECTIVE ACTION -----------3 Pages

• REPLY TO NOTICE OF VIOLATION DESCRIBED IN INSPECTION REPORT NO. 50-255197018 FAILURE TO TAKE ADEQUATE CORRECTIVE ACTION NRC NOTICE OF VIOLATION During an NRG inspection conducted from December 6, 1997, through January 27, 1998, one violation of NRG requirements was identified.

In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions," NUREG-1600, the violation is listed below: 1 O CFR Part 50, Appendix 8, Criterion XVI, "Co"ec(ive Action," requires, in part,* that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, in 1989, the licensee identified that filter placement downstream of pressure control valves could lead to regulator failure due to air line particulate, a condition adverse to quality. As of March 1997, the licensee had failed to take adequate corrective actions in that CV-3018, Safety Injection Tank Test Line Redundant High Pressure Injection Isolation Valve, failed to reposition during a surveillance due to airline particulate that caused the failure of the valve regulator . This is a Severity Level IV Violation (Supplement 1). CONSUMERS ENERGY COMPANY REPLY Consumers Energy Company accepts the violation as written. However, the failure of CV-3018 occurred during a post-maintenance test rather than a surveillance test as stated. Background In a response dated February 20, 1989, to Generic Letter (GL) 88-14, Consumers Energy (then Consumers Power) committed to evaluate a micron filter rating discrepancy related to the High Pressure Air (HPA) filters. An evaluation of this discrepancy and the filter placement location relative to the pressure control valves concluded that the as-built design was acceptable as-is.

• In September 1996; as a result of a design basis review, a request for a re-evaluation of filter placement the HPA System was initiated.

In addition, System Health Reports-for the 3rd and 4th quarters of 1996 also discussed the filter location as-built design . 1

• REPLY TO NOTICE OF VIOLATION DESCRIBED IN INSPECTION REPORT NO. 50-255/97018 FAILURE TO TAKE ADEQUATE CORRECTIVE ACTION On March 18, 1997, CV-3018, Safety Injection Tank Test Line Redundant High Pressure Injection Isolation Valve, failed to stroke during post-maintenance testing. The failure to stroke was a result of air line particulate that caused the failure of the pressure control regulator.

This event occurred before the completion of the evaluation requested in the fall of 1996. The re-evaluation did not receive a high priority since (1) no similar failures had been observed in the past, and (2) valves that could be affected by air line particulate due to the location of the filters downstream of the pressure regulators were either passive or if active, had a nitrogen backup supply which would have assured their ability to operate in the event of failure of the HPA supply. Palisades failed to give the appropriate priority to the re-evaluation of a long standing design deficiency.

This failure constitutes inadequate corrective action. Reasons for Violation Our evaluation has identified the root cause to be an inadequate sensitivity to a longstanding design deficiency which could adversely affect safety-related equipment.

An over-reliance on past successful HPA System operation and backup design provisions resulted in less than a time!y response to the identified condition.

Corrective Action Taken a*nd Results Achieved The following corrective action has been taken: 1. This event heightened our sensitivity to the HPA System design and material condition.

To increase management visibility to the concerns with the HPA System and to assure timely corrective action, we placed the HPA System in Maintenance Rule Category (a)(1) after the failure of CV-3018. We issued an Action Plan to identify needed upgrades to improve the HPA System and to schedule their implementation.

Resources have been allocated and considerable progress has been made in implementing the actions. The HPA System pressure control valves that do not have upstream filters have been cleaned or replaced with the exception of one valve which is scheduled for replacement in 1998. 2. Additional emphasis has been placed on the System Health Reports. This event has sensitized management toward the need to address desig-rY deficiencies in a *-timely mariner. *

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• REPLY TO NOTICE OF VIOLATION DESCRIBED IN INSPECTION REPORT NO. 50-255/97018 FAILURE TO TAKE ADEQUATE CORRECTIVE ACTION Corrective Actions Remaining to Avoid Further Violations The following corrective actions are planned to avoid future violations:

1. The pressure control valve which has no filter upstream and which has not been cleaned will be replaced in 1998. This pressure control valve regulates air to CV-3213 (Shutdown Heat Exchanger E-608 Outlet Valve). 2. As described in the previous section, our HPA System Action Plan was issued. This plan calls for:

• The installation of filters upstream of pressure control valves in the HPA System prior to the completion of the 1999 refueling outage,

• Periodic air pressure readings will be recorded on selected valves (including CV-3018) until upstream filter installation is accomplished,

• Periodic cleaning, filter element changes, oil adjustments and calibrations have been initiated, and

• Low point drains will be installed in the HPA System during the 1998 refueling outage to support system Date Eull Compliance Will Be Achieved Full compliance has been achieved through the appropriate placement of the HPA System into Maintenance Rule Category (a)(1) and the subsequent development of the Action Plan for the HPA System improvement.

These actions place the appropriate . emphasis on the correction of the problems known to exist in the HPA System. 3