ML18044A755
| ML18044A755 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/10/1980 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8004150398 | |
| Download: ML18044A755 (3) | |
Text
consume11 Power company General Offices: 1945 Parnell Road, Jackson, Michigan 49201 * (517) 788-1217 April 10, 1980 Mr James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Gle~ Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO NOVEMBER 9, 1979, ORDER MODIFYING LICENSE Russell B. DeWitt Vice President Nuclear Operations On November 9, 1979, Consumers Power Company received a letter from the Direc-tor, Office of Inspection and Enforcement of the Nuclear Regulatory Commission that contained a Notice of Violation, a Proposed Imposition of Civil Penalties.
and an Order Modifying Licen~e for the Palisades Plant.
The license modification requires that:
"A.
Prior to startup following the present refueling, 'the licensee shall conduct a comprehensive review of all procedures and check lists to assure that:
(1) all valves and other control.s for engineered saf~ty_featUI'.es have been identified in such procedures and check. lists;
- . (2) such procedures and check lists require that all such valves and other controls are.in
- their proper position prior to startup after any cold shutdown; and (3) such procedures and check lists require that after testing, maintenance or other activities which involve manipulating such valves and other controls, the valves and other controls have been returned.to their proper position
. for operi;i.tion.
B.
Report to the Director of the NRC's Region III office the results of at least monthly inspections during operation of all accessible valves and other controls for engineered safety systems for compliance with the Limiting Condition for Operation (LCO) requirements of the Technical Specification.
A-oc/
s 1/0
Response to November 9, 1979 Order Modifying License C.
Prior to startup following the present refueling, the licensee shall explain to the Director, NRC Office of Inspection and Enforcement, in a meeting in Bethesda, Maryland, how the above*requirements shall be implement-ed."
2 In response to this order, Consumers Power Company initiated a controlled review to upgrade plant drawings, check lists, and proce~ures associated with Engineered Safeguards Systems at the Palisades Plant.
Important steps in this process are as follows:
Screening - Criteria were developed to establish a method for determining which plant check lists and procedures required review.
Using these cri-teria, controlled lists were developed.
Check List Review - Check lists $elected in the screening step were reviewed to ensure that they all included Engineered Safeguard Systems equipment.
A physical walkdown of this equipment was con-ducted by personnel trained in nuclear plant operation.
A review procedure was developed to ensure consistent review.
The check lists were then compared with installed' equipment and plant drawings.* A second *review of the check lists was performed by a plant SRO.
Proposed changes were reviewed by senior plant staff and processed by the normal Plant Review Committee process.
Plant Drawings - As a result of walking down the selected systems to review the check lists, several. additions to the piping and instrument drawings (P&ID's) were proposed.
Independent Company personnel performed a second system walk down to verify the accuracy of the selected drawings and proposed changes.
Resultant changes to plant drawings are being processed in the normal manner.
Un-til the controlled plant drawings are formally revised, copies of the marked up (red-lined) drawings will be available to oper-ators (and other plant personnel).
Procedures - Procedures. selected in the screening step were reviewed for proper administrative controls.
The review was carried out with the use of a check list. Proposed changes are being reviewed by the plant staff and processed through the Plant Review Committee.
Additionally, oper-ating procedures receive a second technical review by Palisades Plant Senior Reactor Operators.
The majority of the foregoing reviews and revisions are complete, and have been reviewed by NRC I&E Region III inspectors.
Prior to plant startup, all revisions resulting from this review activity will be completed on check lists and operating procedures.
Revisions to plant piping and instrument drawings have been initiated with red-lined copies available on site.
Other selected procedures performed frequently, such as daily or weekly Technical Specification Surveillance Tests, will be revised prior to startup.
Infrequently used procedures will be revised prior to their next use.
Response to November 9, 1979 Order Modifying License 3
In accordance with Part B of the order, a draft procedure has been developed for monthly review of compliance with limiting conditions for operation.
The proced-ure was reviewed by NRC Region III Inspectors at a site meeting conducted.on Febru-ary 1, 1980.
The procedure will be reviewed and approved prior to use.
In accordance with Part C of the order, Consumers Power Company representatives met with Mr Victor Stello and other NRC staff members on November 30, 1979, to ex-plain how the requirements of the order would be implemented.
In sillnmary, Consumers Power Company believes it will have satisfied the require-ments of the November 9, 1979, license modification when the -required check list and procedure revisions have been completed.
The Company plans to restart the Palisades Plant at that time, and presently estimates that the plant will be ready for startup on or about May 1, 1980.
Russell B DeWitt (Signed)
Russell B DeWitt Vice President Nuclear Operations CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement