IR 05000255/1986028

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-255/86-28.Addl Info Re Listed Violations Requested within 30 Days of Ltr Date

ML20212M118
Person / Time
Site:	Palisades
Issue date:	03/05/1987
From:	Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8703110097
Download: ML20212M118 (2)

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MAR 5 1987 Docket No. 50-255 Consuners Power Company ATTN:- Dr. F. W. Buckman Vice President Nuclear Operations 212 West Michigan Avenue

. Jackson, MI 49201 Gentlemen:

Thank you for your letter dated December 12, 1986 informing us of the steps you have taken to correct the violations which we brought to your attention in Inspection Report No. 50-255/86028 forwarded by our letter dated November 12, 198 ' With regards to your proposed corrective action for Violation No. Ib involving failure to assure that the latest design drawings reflect the as-built configuration of the plant, you addressed compliance achieved with respect to the specific discrepancies identified by the NRC inspecto However, you have failed to specify a time period for completion of your program to identify and correct existing discrepancies between design drawings and the as-built condition of the plan With regards to your response to Violation Ic we disagree with your position that this violation does not appear to represent a departure from compliance with NRC regulations. Regardless of the fact that you have subsequently identified a personnel error which has contributed to .the failure to perform an adequate load analysis, 10 CFR 2, Appendix C states,

" Licensees are not ordinarily cited for violations resulting from matters not within their controls such as equipment failures.... Generally, however, licensees are held responsible for the actions of their employee Accordingly, the policy should'not be construed to excuse personnel errors."

Consequently, example c of the violation stand The statement regarding concern for drawing updates as stated in the last

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paragraph of Section 2 of the Inspection Report was based on the statement

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made by your Manager of Engineering and Maintenance during the exit inter-l vie In addition, the as-built discrepancies identified during this i inspection between the design drawings and the field installaticns reinforced this concern. Ilowever, we accept your stated clarification that drawings will be updated to an as-built status following the l discovery of deficiencies.

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p LConsumers Power Compan MAR 5 W In_ your response to this- letter, please specify a time period in which you plan to accomplish your update prcgram to identify and correct existing discrepancies between design drawings and the as-built condition of the plan Please provide your response to the concern noted above within 30 days of this lette

Sincerely,

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{0}pjihiC itr O [U. 0 DfEILOU J. J. Harrison, Chief Engineering Branch cc: Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager DCS/RSB(RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Consnission Nuclear Facilities and Environmental Monitoring Section

l RIII RIII R I RI I ,W W6 Falevits/lc Cardner urgess Harrison

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V Dwector MM Nuclear Licensing A9KJNEAN5 MioGRE55 General offeces: 1945 West Pernait Road. Jackson, MI 49201 e (517) 788-1636 December 12, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR-20 - PALISADES PLANT -

RESPONSE TO IE INSPECTION REPORT 86-028 IE Inspection Report 86-028 dated November 12, 1986, transmitted one violation p)

( which requires a response by December 12, 1986. The following is our response LJ to that ite Item 1:

l Violation (255/86028-01)

10 CFR 50, Appendix B, Criterion III, as implemented by Consumers Power Company Quality Assurance Program Requirement 3.0, requires that measures l be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures and instruction. These measures shall include provisions to assure that appropriate quality staccards are specified and included in design documents and that deviatione'from such standards are controlle Contrary to the above: The li.ensee failed to correctly translate the design requirements of Schematic Diagram E-137, Sheet 1. Revision 15, onto the applicable connection diagrams. The resulted miswiring, which was identified in two unrelated breaker control circuits, prevented the automatic closure ,

of the diesel generator feed breaker under certain condition d y 7t&M +j

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Administrator, Region III 2

< Palisades Plant  :

Response to IEIR 86-028 '

December-12, 1986

, The licensee failed to ensure that the as-built configuration of the plant conformed to the latest design drawings. For example, electrical conductors were found to be terminared on termination blocks and electrical devices; however, these terminations were net reflected on the applicable design drawings, and vice versa. Field wiring of undervoltage protective relays did not conform to the applicable design

, drawin The licensee failed to assure that applicable regulatory requirements were met by performing an adequate load analysis and cable aizing review when additional electrical loads were added to 2.4KV owitchgears ID and 1 Response:

Corrective Actions Taken and Results Achieved:

i a) Subsequently, both of the wiring errors have been corrected. Contrary to the statement in the inspection report, testing performed to verify the correctness of connections in accordance with the connection l diagram would not have detected the problem as the connection diagram was, itself, in error, and represented the cause of the wiring erro As stated, however, the root cause of the occurrence was the failure to

, correctly translate information from the schematic diagram to the

connection diagrams, and the failure of the review process to disclose i

this error, b) Appropriate drawing revisions were incorporated for each of the dis-crepancies between design drawings and the as-built condition which i were noted in Example B of this Violation #255/86028-01.

l j c) To rectify the potential overloading condition, the ampacity of the feeder cables to the ID and 1E switchgear subsequently have been epgraded through the installation of a solar shield on exposed conduit and the installation of a covered cable tray, respectivel Corrective Actions To Be Taken To Avoid Further Violation:

a) No additional corrective actions are necessary. Since the subject error occurred over six years ago during 1980, specific identification

, of the responsible individuals for potential counselling has not been l undertaken. We telieve the incident is an isolated occurrence and that adequate procedural controls are in place to prevent recurrenc OC1286-0198-NLO2

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- Administrator,' Region III 3 Palisades Plant Response to IEIR.86-028 December 12, 1986 yV b) An; electrical drawing serification and update program is being devel-

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oped and will be implemented which will systematically identify and correct wiring or drawing Jincrepancies. The verification and update efforr is included in the configuration management program described in our December 1, 1986, response to the November 20, 1986, NRC 50.54(f)

lette c) The failure to perform an adequate load analysis was the result of an i

isolated personnel error which eccurred in 1983. We believe that

, controls are in place to provide adequate load analyses prior to the addition of Icads. The subject example was, in fact, identified during such an evaluation which was being performed with regard to a planned loading additio In addition, Example C of Violation 255/86028-01 does not appear to

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represent a departure from compliance with NRC regulations or applica-

ble license conditions. The failure to have performed a thorough load analysis ultimately resulted in no past equipment operability concerns or safety implications.

Furthermore, even if the stated example was conservatively construed as a departure from regulatory requirements, the tests for self identifi-i

['~' cation, severity level, reportability and appropriate corrective action which are stated in 10 CFR 2, Appendix C, V.A. were completely satis-fled, precluding the necessity for the example to be included in a

! notice of violatio I Consequently, we request that Example C of the violation be withdrawn.

I Date When Full Compliance Will Be Achieved:

a) Full compliance has been achieve b) Full compliance has been achieved with respect to the identified

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discrepancies. Further wiring / drawing revisions will be completed as

necessary on an on-going basis.

l c) Full compliance has been achieved.

Clarification

! An incorrect statement regarding concern for drawing updates was included in the last paragraph of Section 2 of the Inspection Report (page 14). The

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statement specified our " philosophy regarding identified field deficiencies i is to make the equipment operable and not be concerned with update the

drawing." The NRC inspector apparently misunderstood the content of the

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discussion. Palisades philosophy and practice is to update drawings to an i

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Administrator, Region III 4 Palisades Plant s Response to IEIR 86-028

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-December 12, 1986 as-built status following the discovsry of deficiencies. The point we were explaining to the inspector was that we judge the seriousness of the '

drawing error based on its effect on equipment operability. We did not state that the drawing error should not be correcte !

l Kenneth W Berry (Signed)

Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades

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OC1286-0198-NLO2

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