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:	PALMISANO T J 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)

See also: IR 05000255/1997018

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

---o--:-CC--:-

---

. -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. * * 2

. ' * 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