ML18066A413

Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220

ML18066A413
Person / Time
Site:	Palisades
Issue date:	03/11/1999
From:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-98-22, NUDOCS 9903250079
Download: ML18066A413 (6)

Text

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A CMS Energy Company Palisades Nuclear Plant Tel: 616 764 2296 27780 Blue Star Memorial Highway Fax: 616 764 2425 Covert, Ml 49043

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Site Vice President March 11, 1999 _

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE PPR PALISADES PLANT REPLY TO NOTICE OF VIOLATION FROM INSPECTION REPORT 50-255/98022(DRP)

NRC Inspection Report 50..255/98022(DRP), dated February 1O, 1999, cited one violati.on. The violation involves a failure to submit the results of an analytical evaluation f degraded primary coolant pump (PCP) bolts as required by the ASME Boiler and ressure Vessel Code, Section XI, Article IWB-3134(b). The reply to this notice of -

violation is attached.--Consumers Energyagreeswith-the - '

violation._---

• In addition to the cited violation, the cover letter for Inspection Report 50-255/98022(DRP) expressed a concern that this violation may have demonstrated a lack of knowledge in applying the appropriate ASME Code requirements, and that this may be indicative of a weakness in the lnservice Inspection (ISi) Program implementation. Consumers Energy has evaluated this concern and concurs that weaknesses may exist in the application of ASME Section XI requirements for issues -

found outside of formal ISl/IST Program activities. However, we have concluded that these weaknesses do not extend to implementation of the ISi Program which has clear organizational ownership and procedural guidance. The degraded bolting in this case

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• was discovered during routine activities outside the ISi program, and was dispositioned

. with consideration for Code requirements. The failure to submit the bolt evaluation resulted from personnel oversight. As discussed in the attached violation respons~.

remedial action is being taken to add procedure prompts to highlight the evaluation

_ _s_ubmi~at r~quirem~nts. Qpportunities for additional enhancements will be explored in a self assessment of the application of Section XI to non-ISl/IST activities, scheduled to be completed prior to the _1999 refueling outage. Appropriate actions*for identified weaknesses*:wm be implemented.*-._ - ::',:_: .-'.- .. : _.. - _-- - .. - -- --

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2 The Inspection Report also identified a concern that an earlier opportunity was missed to

• identify the PCP casing leak that caused the bolt degradation. The inspection that identified the boric acid degradation on the PCP bolts was performed during the 1998 refueling outage at cold shutdown conditions. The probable source of the leakage at that time was determined to be from the seal area above the bolts since a pump casing leak

• was not identifiable. The small and localized PCP casing leak was visible only when the Primary Coolant System was pressurized and heated above cold shutdown. Plant conditions ~bove cold shutdown make the vicinity around the leak a hazardous area that would normally preclude a direct.VT-2 examination. During the 1998 refueling outage, the decision to forego closer inspection was based on the hazards that exist during a pressure test at hot shutdown conditions and on the belief that the bolt degradation was caused by a leak that was no longer active in the seal area above the bolts.

SUMMARY

OF COMMITMENTS This letter contains one new commitment and no revisions to existing commitments. The commitment is:

Engineering Manual Procedure EM-26, "Boric Acid Program" will be enhanced. by highlighting the requirement to submit analyses used to accept degraded ASME Class 1, 2, or 3 components.

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Site Vice President CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector- Palisades Attachment

ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION FROM INSPECTION REPORT 50-255/98022(DRP) 3 Pages

REPLY TO NOTICE OF VIOLATION FROM INSPECTION REPORT 50-255/98022(DRP)

NRC NOTICE OF VIOLATION During an NRG inspection conducted from November 26, 1998, through January .12, 1999, 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:

Title 1O of the Code of Federal Regulations, Part 50. 55a(g)(4) required, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components which are classified as ASME Code Class 1, Class 2, anc! Class 3 must meet the requirements, except design and access provisions, set forth in Section XI of the ASME Boiler and Pressure Vessel Code.

Article IWB-3134(b) of Section XI of the ASME Code required that analytical evaluation of examination results as required by IWB-3132.4 shall be submitted to the regulatory authority having jurisdiction at the plant site. .

Contrary to the above, as of December 18, 1998, the licensee had not submitted to the NRG the analytical evaluation of examination results (EA-PAL-98-1067-01) completed on May 23, 1998, that evaluated the acceptability of continued service

• with two degraded pressure retaining Code Class 1 studs greater than 2 inches in

• diameter (pur5uant to IWB-3142.4 requirements) for reactor coolant pump P-50A This is a Severity Level IV violation (Supplement I).

CONSUMERS ENERGY COMPANY RESPONSE Consumers Energy Company agrees with the violation. It is noted, however, that American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, Article IWB-3144(b) would be applicable rather than Article IWB-3134(b) as stated in the

. citation since the degradation was found during visual examinations.

BACKGROUND The ASME Boiler and Pressure Vessel Code, Section Xl-1989, Article IWB-3144(b), states the following: *

• ~Evaluation analyses of examination results as required by IWS-3142.4 shall be _

submitted to the regulatory authority having jurisdiction at the plant site."

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• • REPLY TO NOTICE OF VIOLATION FROM INSPECTION REPORT 50-255/98022(DRP)

System Engineering personnel identified degradation of two bolts on primary coolant pump (PCP) P-SOA on May 20, 1998 while the plant was in cold shutdown. This identification was made during an investigation of boric acid residue on the bolts, and was unrelated to the ISi Program. The residue was attributed to previous leakage from the seal area of the PCP, located above the bolts. No active leakage was observed. An analytical evaluation, EA-C-PAL-98-1067-01, P-SOA Case to Cover Stud Evaluation", was performed to .

determine if the condition of the bolts was acceptable for continued service. This analytical evaluation, completed on May 23, 1998, concluded that the bolts were acceptable.

When the bolt degradation was found in May 1998, personnel with expertise in Code compliance were assigned to coordinate the examinations required to provide the input for the analytical evaluation. The assigned personnel overlooked the Code requirement to submit the evaluation to the regulatory agency.

The analytical evaluation was not submitted to the NRC until after this oversight was identified during a conference call with the NRC on December 18, 1998, during which the submittal of a relief request concerning the same bolts was being discussed. The analytical evaluation of the bolt degradation found in May 1998 was subsequently

. submitted on December 20, 1998.

REASON FOR VIOLATION The assigned personnel overlooked the Code requirement to submit the evaluation to the

• NRC. In addition, there were no procedural prompts to highlight the requirement to submit analyses used to accept ASME Class 1, 2, or 3 components with flaws that are discovered

• during* activities performed outside of the formal ISl/IST Programs.

CORRECTIVE ACTIONS TAKEN ANP RESULTS ACHIEVED

1. The analytical evaluation, EA-C-PAL-98-1067-01, "P-SOA Case to Cover Stud Evaluation", was submitted to the NRC on December 20, 1998.

2. A review was conducted to determine if there were other occasions where there were failures to submit the analysis as required. There was only one occasion (the subject of this Notice of Violation) where Palisades failed to realize that an analysis submittal was required.

CORRECTIVE-AG-TIG>NS--REMAINING TO AVOID FURTHER VIOLA!IONS

1. Engineering Manual Procedure EM-26, "Boric Acid Program" will be revised by highlighting the requirement to submit analyses used to accept degraded ASME Class 1, 2, or 3 components .

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t REPLY TO NOTICE OF VIOLATION FROM INSPECTION REPORT 50-255/98022(DRP)

2. Palisades will complete a self assessment to identify potential improvements to the application of Section XI to repair and evaluation activities. Appropriate actions for identified weaknesses will be implemented.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was 'achieved when the analytical evaluation was submitted on December*

20, 1998 .

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