ML18052A409
| ML18052A409 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/28/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8605060154 | |
| Download: ML18052A409 (2) | |
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consumers Power POWERINli MICHlliAN~S PROliRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 April 28, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO IE INSPECTION REPORT 86-007 One item of violation was identified in IE Inspection Report 86-007 dated March 28, 1986.
The following is our response to that item.
Item 1:
Violation 255/86007-0l(a)(b) 10 CFR 50.73(a) requires that a licensee submit a Licensee Event Report (LER) within 30 days after the discovery of certain events specified, including: (2)(i)(b) Any operation or condition prohibited by the Plant's Technical Specifications and (2)(iv) Any event or condition that resulted in manual or automatic actuation of any Engineered Safety Feature excluding those that are part of a preplanned sequence d~ring testing or operation.
Contrary to the above, the licensee failed to submit LERs for the following:
- a. Fire doors found open on January 6 and 8, 1986, without compensatory measures established.
Technical Specification 3.22.5 requires that all fire barriers protecting safety-related areas be functional at all times or appropriate compensatory actions, such as fire watches, be taken.
- b. Containment isolations occurred on December 14 and 15, 1985, which were not part of a preplanned sequence.
,-- 8605060154 860428 PDR ADOCK 05000255 G
PDR OC0486-0073-NL02 APR 3 O 1985
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Response
Corrective Action Taken And Results Achieved a) The cause of the failure to submit an LER for the open fire doors has been attributed to an isolated personnel error in making the reportabil-ity determination.
Plant Licensing Department personnel maintain primary responsibility for reportability determinations.
In this instance, the responsible individual incorrectly assessed the occurrence with respect to Palisades Technical Specifications.
Subsequently, an LER was submitted on March 19, 1986, addressing the open fire doors.
All Plant Licensing Department personnel have been apprised of the incident and its consequences.
b) The failure to submit LERs for the containment isolation events is attributed to a communication error between the Technical Engineer and individuals cognizant of the occurrences.
While it was clearly recog-nized that the containment isolation events would be reportable if they were unplanned, the Technical Engineer construed from discussion regard-ing the events that the containment isolations were preplanned evolu-tions, and therefore not reportable.
Subsequently, an LER addressing the containment isolation events was submitted on April 17, 1986.
To avoid potential communication problems of this nature, the Plant Licens-ing Department has instituted a policy wherein all future Engineered Safety Feature (ESF) actuations are to be considered unplanned, and therefore reportable, unless written documentation is presented to substantiate that the actuation was indeed preplanned.
Corrective Action To Be Taken To Avoid Further Violation No further actions are planned.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRG Resident Inspector - Palisades OC0486-0073-NL02