ML18052A407
| ML18052A407 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/11/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8605050240 | |
| Download: ML18052A407 (3) | |
Text
consumers Power PDWERl~li MICHlliAN'S PRDliRESS General Offices:
1945 West Parnall Road, Jackson, Ml 49201 o (517) 788-1636 April 11, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
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DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO IEIR 85-034 Kenneth W Berry Director Nuclear Licensing Two items of violation were identified in IE Inspection Report 85-034 dated March 12, 1986.
The following is our response to those items.
Item 1:
Violation 255/85034-01 10CFR50, Appendix B, Criterion XVI, as implemented by Consumers Power Company (CPCo) "Quality Assurance Program for Operational Nuclear Power Plants" (CPC-2A), requires that measures shall be established to ensure that conditions adverse to quality are promptly identified and corrected.
- Further, CPC-2A, Section 16.2.2 requires that, for conditions noted adverse to quality, appropriate remedial action is taken and corrective action is implemented in a timely manner.
Contrary to the above:
Appropriate remedial action was not taken and corrective action not implemented in a timely manner for conditions noted adverse to quality.
In Inspection Report No. 255/85003(DRP) a Notice of Violation was issued for thirteen Administrative Procedures being overdue for biennial review because, although QA surveillances had found overdue procedures, corrective action had not been effective.
In response to this violation (255/85003-0l(DRP), the licensee committed to utilizing the Periodic Activity Control (PAC) system to provide early notification of impending biennial reviews with the capability for readily identifying overdue items.
Full compliance was to have been completed by July 15, 1985.
As of January 23, 1986, the EOPs and ONPs were not entered on the PAC system.
On January 24, 1986, seven Emergency Operating Procedures (EOPs) and eleven Off Normal Procedures (ONPs) were noted as OC0486-0068-NL04
_J
J G Keppler, Administrator Palisades Plant Response to IEIR 85-034 April 11, 1986 overdue for biennial review.
For some procedures that were entered on the system, the dates given were meaningless as to when the biennial review was required.
Response
Corrective Actions Taken and Results Achieved
'2 The omission of the EOPs and ONPs from the PAC system was caused by personnel error.
This error contributed to the fact that seven EOPs and eleven ONPs were overdue for biennial review.
However, the PAC system functions only as early notification of an impending biennial review due date.
Ensuring that a procedure is not overdue for its biennial review is ultimately the responsibility of the procedure's sponsor.
The EOPs and ONPs were subsequently entered into the PAC system.
The overdue biennial reviews were completed for the ONPs.
Three of the overdue EOP biennial reviews have also been completed.
Corrective Action To Be Taken To Avoid Further Violation The remaining overdue EOP biennial reviews will be completed by July 1, 1986.
Use of the PAC system for notification of approaching biennial review due dates will be discontinued.
An improved notification system providing appropriate procedure review due dates will be implemented by May 15, 1986, which will highlight both impending procedure review due dates and overdue procedure reviews for appropriate management attention.
In conjunction with this effort, renewed management attention will be directed toward eliminating the backlog of required biennial procedure reviews through communication of this expectation to the procedure's sponsor.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by September 1, 1986, at which time no procedures will be overdue for biennial review.
Item 2:
Violation 255/85034-04 Technical Specification 6.8.1.a requires that written procedures shall be established, implemented and maintained for applicable procedures in Appendix "A" of Regulatory Guide 1.33 as endorsed by CPC-2A which includes procedures for abnormal, offnormal and alarm conditions
- Alarm and Response Procedure 8 requires that an invalid Safety Injection Signal (SIS) be reset and that the actuated equipment be restored to normal.
OC0486-0068-NL04
J G Keppler, Administrator Palisades Plant Response to IEIR 85-034 April 11, 1986 Contrary to the above, while in cold shutdown on December 10, 1985, following a spurious SIS, the SIS was not reset properly until December 14, 1985.
Response
Corrective Action Taken and Results Achieved The occurrence was caused by personnel error on the part of the licensed operator who took action to re-block the SIS (changed three flashing alarm windows and one solidly lit alarm window to four solidly lit alarm windows);
but failed to also reset the SIS (reduce four solidly lit alarm windows to the normal three).
Consequently, an alarm window indicating a one channel SI initiation remained lit from December 10-14, 1985, at which time throuble-shooting activities by plant electricians disclosed that the circuitry had not been reset.
At the time of the occurrence, the plant was in a cold shutdown, preparing to refuel.
This plant condition along with extensive in-progress maintenance activities resulted in numerous alarm windows remaining lit in the Control Room.
Although it was significant that Control Room board reviews by the operators failed to identify that the circuitry had not been reset, the presence of an SIS, given the plant condition, did not have any safety significance.
The SIS was reset on December 14, 1985.
The proper course of action for this occurrence was communicated to the licensed operators who were on shift when the original incident occurred.
Corrective Action To Be Taken To Avoid Further Violation All licensed operators will be similarly briefed regarding the occurrence by May 1, 1986.
Additionally, the importance of being cognizant of the plant status will be emphasized to all licensed operators by May 1, 1986.
Date When Full Compliance Will Be Achieved Full compliance was achieved on December 14, 1985, when the alarm was reset.
Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades OC0486-0068-NL04