ML18066A892

Responds to NRC 970122 Ltr Re Violations Noted in Insp Rept 50-255/96-14.Corrective actions:SPS050 Revised to Use Terminology of Operating Procedure SOP 30

ML18066A892
Person / Time
Site:	Palisades
Issue date:	02/21/1997
From:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9703030519
Download: ML18066A892 (13)

See also: IR 05000255/1996014

Text

consumers . Power*.*** . l'OWERIN&

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l'IUlliRESS

Palisades

Nuclear Plant: 27780 Blue Star Memorlal Highway, Covert, Ml 49043 February 21, 1997 U.S. Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE PPR-20 -PALISADES

PLANT Thomas J. Palmisano

Plant General Manager . RESPONSE TO NOTICE OF VIOLATION

FOR TWO VIOLATIONS

IN NRC . INTEGRATED

INSPECTION

REPORT NO. 50-255/96014(DRP)

-. ---NRC Inspection

Report No. 50-255/96014(DRP)

dated January 22,_1997, identified

two Severity Level IV Violations

of NRC requirements.

The first violation

identified

two examples where the plant staff did not adhere to procedures

while performing

outage related activities.

The second violation

identified

an example where adequate installation

instructions

were not provided for a temporary

modification

to the containment

polar crane. response to these violations

is in Attachment 1 . . . . . Consumers

Power Company (CPCo) agrees to the violations

as stated. SUMMARY OF COMMITMENTS

This letter contains three new commitments

and no revisions

to existing commitments.

1. Periodic.activity, SPSOSO, will be revised to use the terminology

of operating

procedure, SOP 30, and to make the steps to align automatic

transfer switch, * YSO, an Operations

responsibility

with the appropriate

sign offs. . . . A review of all installed

modifications

will be conducted

to verify tha. t J . acceptable

standards

were used for installation. . * -r-/ 1 . .. . . __, 2. 9703030519

970221 PDR ADOCK 05000255 G PDR

Ml f HD /ID/ f MIJMI /ID A CMS ENERGY COMPANY

,. ' . 3. The Temporary

Modification

process will be reviewed to assure that adequate . guidance is provided to the design engineer for providing . . instructions, and for verifying

that the temporary

modification

was installed

as intended by the design. *

Thomas J. Palmisano

Plant General Manager CC * Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident.Inspector

-Palisades

• Attachment

• .. 2

. ATTACHMENT

1 CONSUMERS

POWER COMPANY . PALISADES

PLANT ** DOCKET 50-255 RESPONSE TO TWO VIOLATIONS

FROM NRC INSPECTION

-REPO_RT 50-255/96014 (DRP)

JANUARY 22, 1997 10 Pages

. * RESPONSE TO-NOTICE

OF VIOLATION

FROM NRC INSPECTION

REPORT NO. 5'?_,-255/96014(DRP)

NRG VIOLATION

1) 10 CFR 50, Appendix B, Criterion

V, "Instructions, Procedures, and Drawings, 11 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.

• a. * Licensee procedure

CPAL-RFM-002, Revision 0, Section 9.2.11, "Uncouple

CROMs and Raise RackExtensions, 11 required in step C.4 that all CRDMs be mechanically'

locked prior to ins*erting

a reactor trip . into the

protection

system. . b. Work Order No. 24610226 and PPAC No. SPS050, "PM Auto Transfer Switch, 11 Step 11, required that operations

return the isolation

handle to . normal position prior to performing

step .12, which required that operations

return the bypass handle to automatic.

Contrary to the above, a.* On November 7, 1996, the operations

shift did not ensure that the . control rod drive mechanisms

were mechanically

locked prior to inserting

a reactor trip signal, resulting

in the CROM racks dropping into **the reactor vessel upper guide structure.*

b. 'On November 17, 1996, the operations

shift did not return the isolation

handle to the normal position prior to returning

the bypass handle to *: automatic

position *. resulting

in a loss of power to instrument

AC bus Y-01. This is a Severity Level IV violation (Supplement

/). 1

CONSUMERS

POWER COMPANY RESPONSE *Consumers-Power

Company (CPCo) agrees with the violation

as stated. ,REASON FOR VIOLATION

Event 1a. Several factors *Contributed

to this event. First, the "C" shift Control Room Supervisor

and the Control Operator were not fully knowledgeable

about the status of the control rod drive mechanisms.

Second, the shift turnover between "B" shift and "C" shift was inadequate

in that it failed to identify the controlling

procedure

and it failed to discuss. the need to contact Refueling

Services after Electrical

maintenance

was completed

with -CRD #33. Third, the Control Room Supervisor

and the Control Operator failed.to

question the need for a-procedure

and determine

which procedure

was governing

the evolution.

• Piscussion

On November 7, 1996, preparations

were being made to remove thereactor

vessel* head. These preparations

require. * 1) The uncoupling

of the control rods from their drive mechanisms.

2) Raising the control rod drive racks 3) Mechanically

locking .the control rod drive racks . 4) De.-energizing

the control rod drive motors, clutches, and brakes by placing the reactor protection

system in the "reactor.

trip" mode. On "A" shift, the Refueling

Services personnel

began to uncouple the control rod drives. About 1300 on "B" shift, the Refueling

Ser-Vices

Supervisor

called the Control -Room to let the Control Room know the uncoupling

was completed

and Operations

was requested

to raise the control rod drive racks. At this time, Operations

discussed

the status of the uncoupling

with Refueling

Services and understood

that the Refueling

Services procedure

was controlling.

Operations

then withdrew forty-four

of the five control rod drive racks, but problems were*encountered

with CRD #33 rack. Electrical

maintenance

personnel

assistance

was requested.

While the plant electricians

were repairing

CRD #33, Operations

turnover between "B" and '!C" shifts occurred.

During this turnover, general information

concerning

the control rods was . exchanged, but it was not established.that

the Refueling

Services procedure

was controlling. "C"*shift

Operations

personnel

did not understand

that the Refueling

• Services procedure

was controlling

the evolution

and that Refueling

Services required notification

to lock the control rod drive racks after CRD#33 rack was withdrawn

.. 2

. '. * On "C" shift the electricians

finished repairing

CRD #33, withdrew the control rod drive rack and mechanically

locked itin place. The Shift Supervisor, upon being notified that CRD #33 problem had been resolved and the control rod drive rack was mechanically

locked, thought the next sequential

step to be performed

was to place the reactor protective

system in the "reactor trip" mode. The Shift Supervisor

did not verify the status of the control rod drive racks nor did he determine

which procedure

was controlling

the evolution

and verify that the prerequisites

were met. The Shift Supervisor

directed Control Room personnel

to place the reactor protection

system in the "reactor trip" mode. Control Room personnel

observed all control rod drive racks, except CRD #33 rack, reinserting

into the reactor vessel upon the reactor protection

system trip initiation.

Subsequently, it was recognized

that the control rod racks had not been mechanically

locked when control rod #33 rack problem was encountered.

The Refueling

Services procedure

allowed the control rod drive racks to be l.ocked after all the racks were withdrawn.

Event 1b. The reasons for this event included inadequate

understanding

of the work scope, inadequate

communications, inadequate

work control documents

and improper equipment

operation.

• Discussion

• On November 17, 1996, the plant was in refueling

shutdown conditions

with shutdown cooling system in operation.

The instrument

AC Bus, Y01, was being supplied from Motor Control Center 1. Y01 is critical to the operation

of the shutdown cooling system as it affects shutdown cooling heat exchanger

bypass and: discharge

valves (CV-3006 . and CV-3025).

Earlier in the day these valves were placed on their manual hand jacks to maintain their position as instrument

air was isolated and tagged for another maintenance

activity.

An electrical

preventative

maintenance

activity (PPAC) was schedul_ed

for the Y01 automatic

transfer switch, YSO. This required the YSO switch to be removed .from _ service so electrical

maintenance

personnel

could remove the switch from the cabinet and take it to the electrical

shop to perform the preventative

maintenance.

Control Room personnel

reviewed the activity but focused on the impact of this activity on the operation

of the shutdown cooling system. They determined

that the shutdown cooling heat exchanger

bypass and discharge

valves would not be affected as they were manually peing operated by the valves' hand jacks. The outage schedule stated that Operations

was to "Manually

align Y01 to'its normal supply". However, because all *the PPAC steps were assigned to Electrical

Maintenance

for completion, Operations

3

• * did not obtain a copy of the procedure

to review, and failed to establish

the full electrical

maintenance

work scope ... Subsequently, Operations

decided to implement

a portion of SOP 30 that configured

the YSO switch from automatic

to normal, but did not recognize

the need to place the isolation

handle to "open" (see attached sketch). This configuration

fulfilled

only one of two alignment

steps specified

in the PPAC. The Control Room Supervisor (CRS) directed an Auxiliary

Operator (AO) to configure

Y01 onto its normal supply using SOP 30. The AO accompanied

by the System Engineering

Test Coordinator (SETC) performed

the alignment.

The SETC explained

to the AO that not only would Y01 have to be placed on its normal power supply but, also, YSO must be isolated by moving the isolation

handle to the "open" position.

At this point the AO should have contacted

the.CRS for direction

and permission

to perform the isolation.

However, the AO did the isolation

and then communicated

the completion

of the activity and the additional

step taken to the Nuclear Control Operator (NCO). The NCO understood

this message to mean that the activity was completed

as directed by the CRS. Therefore, the CRS was not informed that YSO was isolated.

After the electrical

mainter:iance

activity was completed, the Electrician

informed the Work Control Center Lead SRO that maintenance

was completed

and that the Electrician*

needed to be present when Operations

restored the switch in order to sign. the work order steps. Also, the SETC contacted

the Work Control Center and * . reque$ted

that he be notified prior to the restoration

activity;

however, neither were contacted.

If either the Eiectrician

or the SETC had been at the work site.during

restoration, or if the work activity been written to have Operations

sign off for . . restoration, Operations

would have understood

the desired position of YSO. \ . . . Work Control Center notified the Shift Lead SRO that YSO could be restored.

The Shift Lead SRO conferred

with the CRS on restoring

YSO, and they decided to proceed. The CRS assigned a different

AO to restore YSO, informed the AO and Shift Lead SRO of the. steps he had directed the previous AO to perform, and identified

the steps of SOP 30

to restore YSO.. * * * * * * * The Shift Lead SRO and the AO went to perform the alignment

of YSO. They observed the isolation

handle, the source light indication

and the switch's physical position, but they did not recognize

their indications

were different

than expected.

The AO placed the YSO bypass handle from normal to automatic.

Because the isolation

handle had not been restored to the "close" position, YSO failed to transfer and Y01 was de-energized.

' l 4

,. CORRECTIVE

ACTIONS TAKEN AND RESULTS ACHIEVED The following

actions were taken. _ Event 1a. 1. Refueling

and Maintenance

outage activities

were temporarily

suspended

on November 18, 1996 to review and reinforce

nuclear, radiation, and industrial/personnel

safety concerns with all work groups on site. This event and several other events from the first two weeks of the outage were reviewed with all crews. A common theme running among the identified

issues is the lack communications

between work groups and alignment

among workers. * * 2. Three specific responsibilities

were reinforced

at the Operations

Department

stand down meetings.

These were: . " Shift Supervisors, are to identify Operations

activities

from the outage schedule with an understanding

of the relationship

between these . and others. It is intended that this understanding

will contribute

to well-informed decision making

the Operations

organization.

• . Work Control Center Senior Reactor Operators

are to direct work activities

• having Operations

involvement

to Control Room personnel

for authorization . . * This is to provide interfacing

work documents

physically

to the individual.s . who will be performing

the activity, better communications

between Operations

and other. work discipline*

personnel, and improve the information

flow to those individuals

who will be directing

the activity>

• Control. Room personnel

are to assure they have a complete understanding

• of activities

requested

of them and that proper alignments

have been made. . . 3. . . The control rod drive blades and racks were inspected

for damage due the trip occurring

with a reduced water level. No damage was observed on any of the control rod drive blades or racks. * * Event 1b. In addition to actions 1 and 2 from above, the following

actions were taken. 1. Shift Supervisor, CRS, Lead SRO, AO and other Operations

personnel

involved discussed

this event and the barriers that could have prevented

it. The 5

.. . . -discussion

included responsibilities

for proper communications, pre-job briefings, equipment

operation, self checking and other aspects of operator ccmduct. 2. Shift Operations

Supervisor

has briefed the Shift Supervisors

and SROs on the need to identify and conduct pre-job briefings.

The expectation

to conduct . . --. job briefings

whenever coordination

between two or more work groups is required has been re-established.

• 3. * Maintenance

and Construction

Manager reinforced

pre-job briefing expectations

with maintenance

and construction

supervision

personnel

using this event as an example where a collective

pre-job briefing may have prevented

the event. CORRECTIVE

ACTIONS REMAINING

TO BE TAKEN TO AVOID FURTHER VIOLATIONS . Periodic activity, SPS050, will be revised to use the terminology

of operating , * procedure, SOP 30, and to make the steps to align automatic

transfer switch, YSO, an Operations

responsibility

with the appropriate

sign offs. DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED * CPCo is now in full compliance.

6

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7 . . .

• . * NRC VIOLATION

.2.) 10 CFR 50, Appendix B, Criterion

Ill, Design Control, requires, in part," that . design control measures " ... shall include provisions

to assure that appropriate

quality standards

are specified

and included in design documents

... ," and that " ... design control measures shall provide for verifying

or checking the adequacy of design, such as by the performance

of .. design reviews. Design changes, including

field changes, shall be subject to design control measures commensurate

with those applied to the original design ... " Palisades

Administrative

Procedure

9.31, "Temporary

Modification

Control," Revision *12, Paragraph

7.1.8, required that a technical

review be conducted

to verify that instructions

for installation

were correct .. Contrary to the

On November 6, 1996, Temporary

Modification (TM)96-050 to the containment

polar came did not contain correct installation

instructions

for replacement

of a single solenoid with two solenoids.

The original solenoid was*hard mounted and was provided with adequate ventilation

to prevent premature

failure. As the result of inadequate

preparation

and review, TM 96-050 did not provide instructions

for mounting the second of the two replacement

solenoids.

The* second solenoid was installed

utilizing

duct tape and "tie-wtaps" in a manner which resulted in overheating

and failure of the solenoid coil, and a subsequent . * electrical

fire .. This is a Severity

IV violation (Supplement

1 ). CONSUMERS

POWER COMPANY RESPONSE Consumers

Power Company (CPCo) agrees with the violation

as stated. REASON FOR THE VIOLATION . Based on the inspection

data from the failed coils, the most likely cause of the failure on the trolley crane brake coils is the manner which the coils were mounted. This *inadequate

mounting design was caused by the failure of design personnel

to.identify

soler:ioid

heat dissipation

as critical characteristic

during the design process . 8 . -

• Discussion . A temporary

modification

was required to the containment

Polar Crane due to a failure of the existing 460VAC solenoid on the trolley brake actuator.

No replacement

460VAC solenoid was available.

When this solenoid is energized, the actuator releases the braking mechanism

on the crane trolley motor. ) The modification

involved the replacement

of the original 460VAC coil with 230VAC coils. One of the 230V coils would be installed

in the position of the original coil and the second would be used as a dummy load to provide a voltage drop across it. This would result in a voltage dividing circuit which would divide the 460 volts from the circuit supply in half thus applying 230 volts across each coil. To ensure that the impedance

w<ifs matched a spare plunger was inserted into the dummy coil and fixed in the inserted position using duct tape. The dummy coil was then tye-wrapped

to a . support bar and additional

tape was wrapped around it. The temporary

modification

to substitute

the 230VAC coils for the 460VAC was an acceptable

design. However, the dummy coil mounting design was focused on making sure the coil did not come loose and fall into the debris free zone inside containment.

• . Potential

overheating

of the dummy coil was not considered

in the design. The Polar Crane was in service with the temporary

modification

in place for approximately

60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> before failure occurred.

With high usage of the Polar Crane. and repeated starts and stops on the trolley crane motor, the additional

layers of tape on the dummy coil caused chronic overheating

of the dummy coil. The epoxy insulating

material became hot enough to melt and the dummy coil wires shorted togetheL This allowed the full 460 volts to be applied across the 230VAC working coil, causing its failure. The smoke and. arcing observed was the result of the dummy coil overheating, causing the duct tape to catch fire and burn. No evidence of arcing to the support structure

was found around either coil. CORRECTIVE

ACTIONS TAKEN AND RESULTS ACHIEVED 1. * The two 230 volt coils were replaced with a new. 460 volt coil. It has been in use *without incident since it was installed

.. 2. This event was reviewed as a lessons learned with all Design Engineering

at a department

stand down meeting. Discussions

covered conditions

leading to the event, and the need for Design Engineering

to consider all operating

characteristics

in design . 9

CORRECTIVE

ACTIONS REMAINING

TO BE TAKEN TO AVOID FURTHER VIOLATIONS

1. A review of all installed

temporary

modifications

will be conducted

to verify that acceptable

standards

were used for installation.

2.* The Temporary

Modification

process will be reviewed to assure that adequate guidance is provided to the design engineer

for providing

installation

instructions, arid for verifying

that the temporary

modification

was installed

as intended by the design. DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED CPCo is in full compliance. . * 10