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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 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 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 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 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
[Table view] Category:UTILITY TO NRC
MONTHYEARML18057A4811990-09-17017 September 1990 Confirms 900718 Telcon Notification Re Westinghouse Agreement to Join Utils as Equity Investor in Plant ML18057A4551990-09-0606 September 1990 Forwards Proprietary Info Re Dept of Labor Decision on Discharge of Former Employee of Util,Per NRC 900809 Request. No 10CFR50.7 Violation Occurred Since Job Performance Was Reason for Discharge.Encl Withheld (Ref 10CFR2.790(a)(6)) ML18057A4521990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated IR 05000255/19900101990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated ML18057A4371990-08-31031 August 1990 Forwards Analysis Concluding That Plant Reactor Beltline Matl Upper Shelf Energy Will Remain Greater than 50ft-lbs Until Yr 2032,per 900716 Commitment ML18057A4381990-08-31031 August 1990 Forwards Info Re Contamination of South Radwaste Area,Per 10CFR20.302,in Response to NRC 900112 Request.Approval Requested to Dispose of Low Level Radwaste in Place ML20059E0001990-08-29029 August 1990 Forwards Semiannual fitness-for-duty Program Performance Rept for Jan-June 1990 ML18057A4201990-08-24024 August 1990 Forwards Revised Application for Amend to License DPR-20, Changing Tech Specs Re Incore Analysis Program.Request Revised Per NRC Comments During 900709 Meeting ML18057A4021990-08-22022 August 1990 Forwards Missing Pages from Decommissioning Funding Rept, Consisting of Pages 25 & 26 of Attachment a to Exhibit E ML18057A4241990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Spec 4.5.1 Re Statement on Integrated Leak Rate Test ML18057A4071990-08-21021 August 1990 Forwards Tech Specs Change Request to License DPR-20,to Remove Redundant Requirements & Change Basis Statements No Longer Applicable ML18057A4121990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Specs to Revise Wording for Reactor Protective Sys Trip Setting Limits for Steam Generator Low Water Level ML18057A4181990-08-21021 August 1990 Forwards Description of Changes Being Made to Plant Site Emergency Plan & Emergency Plan Changes.Change Allows Reduction in Shift Staffing During Cold Shutdown for Stated Staff ML18057A3911990-08-17017 August 1990 Forwards Replacement Pages,To Palisades Second 10-Yr Interval Inservice Insp Program. ML18057A3851990-08-17017 August 1990 Forwards Addl Info in Support of NRC Development of SER for full-term OL for Plant,Including Date of SER Providing Provisional OL to Plant & Summary of Valid Exemptions from 10CFR Regulations,Per Telcon ML18057A3841990-08-17017 August 1990 Provides Addl Info Re Transfer of Plant Ownership to Palisades Generating Co,Per NRC 900725 Ltr ML18057A3821990-08-14014 August 1990 Requests That Bechtel-KWU Rept 128901/MJS, Full Flow Testing of Motor-Operated Valve MO-1042A, Be Withheld (Ref 10CFR2.790(b)(1)) ML18057A3721990-08-0808 August 1990 Forwards Addl Info Re Util Request for Exemption from Separation Criteria of 10CFR50,App R,Section III.G.2 Re Containment Air Room ML20055J1421990-07-26026 July 1990 Responds to Commitment Oversight Issue Resulting from Insp Rept 50-255/90-08.Commitment Mgt Seminar Training Will Be Complete Prior to 901001 ML18057A3561990-07-26026 July 1990 Forwards Certification of Financial Assurance for Decommissioning ML18057A3411990-07-18018 July 1990 Forwards Revised Proposed Tech Spec Page 6-3,now Designated as Page 6-1b,adding Section 6.3.4,now Designated as Section 6.3.5 to Remove Organization Charts,Per Generic Ltr 88-06 ML18057A3381990-07-16016 July 1990 Advises That Util Does Not Foresee Need to Rely on Section V.C of App G to Remain in Compliance W/Upper Shelf Energy (Use) Requirements Re Use of Matl in Reactor Beltline ML18057A3281990-07-13013 July 1990 Responds to Request for Addl Info Re Second 10-yr Interval Insp Program,Per 900418 Telcon.Util 900329 Response Revised to Reflect That Certain Components in Class 2 Sys Should Not Be Exempted,Per IWC-1220 of 1974 ASME Code Section XI ML18057A3191990-07-0909 July 1990 Forwards Performance Indicator Trend Graphs for Jan 1989 - May 1990 ML18057A3201990-07-0606 July 1990 Discusses Reassessment of Control Room Temp Following Station Blackout Event.Results of Analysis Indicate That Control Room Temp Will Remain Below 112 F for 4 H After Onset of Blackout ML18057A3171990-07-0303 July 1990 Provides Summary of Upgrades Made to Plant Electrical Distribution Sys,Per 870714 Loss of Offsite Power Event When Inadvertent Actuation of Water Deluge Spray Sys for 1-2 Startup Transformer Resulted in Bus to Ground Fault ML20058K3771990-07-0202 July 1990 Forwards Rev 26 to Security Plan.Rev Withheld (Ref 10CFR73.21(c)) ML18057A3111990-06-25025 June 1990 Forwards Endorsements 116 & 117 to Nelia Policy NF-179 & Endorsements 102 & 103 to Maelu Policy MF-50 ML18057A3101990-06-25025 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements on Corrective Actions. ML18057A3031990-06-22022 June 1990 Provides Addl Info Re Environ Qualification of Instrument Circuit Associated W/Steam Generator Pressure Channel PT-0752D,per Insp Rept 50-255/90-05.Circuits Spliced Directly to Pigtail from Electrical Penetration Connector ML18057A3001990-06-21021 June 1990 Concurs W/Nrc Change in Terminology & Submits Revised Proposed Section 4.14 of Tech Specs ML18057A2771990-06-15015 June 1990 Forwards Corrected NRC Form 474 Re Simulation Facility Certification,Indicating Exceptions to Ansi/Ans 3.5 ML18057A2901990-06-13013 June 1990 Forwards Application for Amend to License DPR-20,revising Tech Spec 3.3.1.b Re Safety Injection Tank Min Level ML18057A2941990-06-12012 June 1990 Advises That Submittal of Second Interval Inservice Insp Program Delayed from 900615 to 900715,per 900418 Telcon ML18057A2711990-06-11011 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i in Order to Maintain Plant in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Request Based on 900608 Failure of Heater Transformer 15 ML18057A2641990-06-11011 June 1990 Provides Response to NRC Requalification Exam Rept Dtd 900410 on NRC Concerns Re Facility & Training Ctr Staffing. Adequate Staffing Will Be Maintained to Ensure Operator Requalification Program Successful ML18057A2591990-06-11011 June 1990 Forwards Palisades Simulator Certification Submittal. ML18057A2631990-06-10010 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i to Enable Plant to Be Maintained in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Waiver Requested for 900611-18 ML18057A2571990-06-0808 June 1990 Responds to NRC 900509 Ltr Re Violations Noted in Insp Rept 50-255/90-12.Corrective Actions:Continuing Training Program Will Be Developed for Supervisors That Will Discuss Fire Protection Program Implementation Topics ML20043D0601990-06-0404 June 1990 Forwards Rev 25 to Security Plan,Including Changes to Security Plan Drawings to Clarify Protected Area Boundary within Plant Security Bldg & Vital Area Boundaries in Other Specific Vital Areas of Plant.Rev Withheld (Ref 10CFR73.21) ML18057A2581990-06-0101 June 1990 Forwards Revised Response to Violations Noted in Insp Rept 50-255/89-26.Concurs That Tests Performed Using Instrumented Insp Technique During 1988 Refueling Outage Considered Invalid ML18057A2561990-05-31031 May 1990 Advises That No NPDES Notifications Required Nor Any Repts of Oil or Salt Occurred During Nov 1989 - Apr 1990 ML18057A2541990-05-30030 May 1990 Forwards Response to Technical Evaluation Rept EGG-NTA-8333 Which Evaluated Plant Compliance w/NUREG-0737,Item II.D.1 & Requested Addl Info Re New PORVs & Block Valves No Later than Jan 1990 ML18057A2511990-05-30030 May 1990 Forwards Final Response to Concerns Re Porv/Block Valve Mod, Per 900308 Meeting.Bechtel Technical Rept Withheld ML18057A2501990-05-29029 May 1990 Forwards Investigation Rept Re Unsatisfactory Performance Testing of Fitness for Duty Program Blind Performance Test Samples ML18057A2411990-05-24024 May 1990 Forwards Revised Application to Amend License DPR-20, Consisting of Revised Attachments 1 & 5 to 890227 Amend Request,Reflecting Transfer of Plant Ownership ML18057A2311990-05-17017 May 1990 Forwards Analysis of Reactor Pressure Vessel Fast Neutron Fluence & PTS Ref Temps for Palisades Nuclear Plant. Rept Concludes That PTS Screening Criteria Will Be Exceeded at Axial Welds in Sept 2001 as Opposed to Mar 2002 ML18054B5861990-05-0707 May 1990 Forwards Monthly Trend Graph Rept for Jan 1989 - Mar 1990 Covering Safety Status Performance Indicators for HPSI, Auxiliary Feedwater,Emergency Ac Power,Lpsi,Containment Spray & Svc Water Sys ML18054B5801990-04-30030 April 1990 Responds to Request for Addl Info on Proposed Administrative Changes to Tech Spec Section 3.0.4,per Generic Ltr 87-09. Licensee Will Implement Program to Assure Appropriate Level of Mgt Approval Required When Operating Conditions Changed ML18054B5741990-04-25025 April 1990 Requests That Correspondence Re 890227 Application for Amend to License DPR-20 to Permit Transfer of Ownership of Plant Be Sent to Listed Address 1990-09-06
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consumers Power David P Hoffman Vice President l'OWERIN& Nuclear Operations MICHlliAN"S l'RO&RESS .
General Offices: 1945 West Parnell Road, Jackson; Ml 49201 * (517) 788-0453 January 20, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE .DPR PALISADES PLANT -
REPLY TO NOTICE OF VIOLATION REGARDING 10CFR50 APPENDIX R COMPLIANCE.
By letter dated December 22, 1988 the NRC transmitted a Notice of Violation and Proposed Imposition of Civil Penalty regarding 10CFR50 Appendix R compliance at the Palisades Plarit. In accordan~e with tOCFR2.201, a Reply to a Notice of Vio.lation* is p~ovide*d herein.
I. NRC Description Of Violation 10CFR Part 50, Appendix B, Criterion XVI, as implemented by Consumers Power CompanY. Quality Assurance Program for Operational Nuclear Power Plants, Section 16, requires in part, that .conditions adverse to quality are promptly identified and corrected.
10CFR50.48(c)(3) and (4) require those fire protection features that require prior NRC approval shall be implemented by the end of the first refueling outage commencing 180 days after NRC approval. *By letter dated May 26, 1983, the 180 day time period was commenced when the NRC approved the licensee's proposed features assuring compliance with Section III of Appendix R to 10CFR Part 50. These features were to be completed by March 3, 1986. . .
10CFR Part 50, Appendix R, Section III.L. 7 requires that the safe shutdown equipment and systems for each fire area shall be known.to be isolated from associated non-safety circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment.
Contrary to the above, an adverse condition identified during the July 28 thiough September 30, 1986 NRC inspection had not been corrected as of the NRC inspection of May 9 through 13, 1988. The adverse condition related to the failure to isolate safety-related equipmeDt from associated non-safety circuits as required by 10CFR50* Appendix R,Section III.L.7.
Specifically, two control power cables to the VCT outlet valve (M0-2087) were identified l:iy the 1988 NRC inspection that could hot short with OC0189-0017-NL04 A OHS ENRGY COMPANi'
Nuc1.ear Regulatory Commission 2
- Palisades Plant Reply to Notice* of Violation January 20, 1989 associated non-safety circuits and cause spurious opening and compromise or.
- prevent safe shutdown by causing a l.oss. of charging pump and subsequent loss of makeup capability. No other *redundant, alternative or dedicated shutdown capability was provided *. This adverse Condit.ion was identified by the 1986 inspection which determined that the licensee had failed to do a spurious signal analysis on M0-2087 to ensure that spurious operation would not cause a loss of charging flow.
This is a Severi~y Level III violation.
Civil Penalty - $75~000.
Consumers Power acknowledges the lack of a spurious signal analysis !or
- M0-2087and concedes the Notice of Violation. However; Consumers Power maintains that no condition adverse to safety was presented.
Reason For The Violation.
IE Inspection Report 86022 dated November. r4, 1986 identified Volume Control Tank (VCT) outlet.* valve M0-2087 as *equipment necessary under 10CFR50 Appendix R and that spurious operation of this valve could lead to a loss of charging flow. This conclusion was predicated on; 1) the Plant's charging pumps being aligned for gravity feeding boric acid to the prin:tary coolant system via the boric acid storage tank, 2) a spurious signal opening M0-2087 concurrent with; 3) a high VCT overpressure. The result of this combination was hypothesized as charging pump failure due to gas binding. At this time the NRC requested that Consumers Power provide a spurious signal analysis for M0-2087.
In October 1987 a second Palisades associated circuit analysis was initiated to confirm previous conclusions that equipment associated. with plant shutdown under 10CFR50 Appendix R was adequately protected. When this effort was initiated, VCT outlet valve M0-2087 was included for analysis, however, it was subsequently deleted from the analysis scope.
This decision was based on the fact that if M0.:.2087 was to. spuriously open, plant operators through their experience and training would identify the problem, manually close the valve and de-energize its power supply to
- . prevent further opening. At that time, Plant Off-Normal Procedure (ONP) 25 .1 recognized that manual operator action may be, required, but did not direct operators to de-energize the valve. No communication was pursued with the NRC at that time.
- TM.s position was reviewed by the NRC under IE Inspection 88012 which was initiated May 9, 1988. During this inspection, the NRC determined that manual closure of M0-2087 alone would not preclude the valve from spuriously reopening unless it was de-energized. The NRC further identified that unless specifically directed by procedure, plant operators
- would not necessarily de-energize the valve. Therefore, no positive OC0189-0017-NL04
Nuclear Regulatory Commission 3 Palisades Plant Reply to Notice of Violation January 20, 1989 assurance that M0-2087 ~ould be protected from spurious signals was evident. .Prior to the conclusion of IE Inspection 88012, ONP 25.1 was changed to direct operators to open circuit breaker 52...,161.prior to manual closure of M0-2087. This action provides additional assurance that the VCT outlet valve would be in the required position and not subject to reopening via a fire-induced spurious signal. This action was deemed acceptable by the NRC in IE Inspection Report 88012 by acknowledging that "the inspectors determined that the licensee's change to procedure ONP 25 .1 wil_l isolate spurious signals that could cause spurious opening of valve M0~2087".
The failure to adequately assure that M0-2087 would not reopen following a.
fire induced spurious signal has been attributed to a weakness of programmatic management attention at the time of the NRC inspections *
. Adequate management attention to the NRC open item (86022~0~) would have resulted in communication, prior to the followup inspection in 1988. of Consumers Power's belief that no analysis was necessary due to operator experience and.training.
Corrective Action Taken and Results Achieved
- As presented above, procedural .changes *d.eemed satisfactory by the NRC were made to ONP 25.i prior to the*J~ne 30,1988-completion of IE Inspection 88012. To assure dedicated followup and resolution of all issues associated with 10CFR50 Appendix R, a plant engineer has been assigned the specific responsibility for assuring compliance with Appendix_R.
Corrective Actions To Be Taken To Avoid Fur.ther Non-Compliance To further enhance management involvement and regulatory compliance, a Technical Advisory Group is being formed under direction of the plant engineer assigned Appendix R responsibilities. This multi-disciplinary group will act as an oversight review group to re-review technical issues and provide direction to assure Palisades' continuing compliance with 10CFR50 Appendix R. The activities of this Technical Advisory group will be presented to plant management on at least a quarterly basis.
Documentation of Palisades' continuing compliance to Appendix R will be provided within a Palisades Plant Fire Protection Program Report. This report will be developed by compiling existing documentation and incorporating any future efforts into a single document that provides information and appropriate references to Palisades' compliance to Appendix R. This report will be incorporated into the in-place design control programs.
Date When*Full Compliance Will Be Achieved As recognized by IE Inspection 88012, compliance with 10CFR50 Appendix R regarding VCT outlet valve M0-2087 was achieved when ONP 25.1 was changed.
OC0189-0017-NL04
Nuclear Regulatory Commi.ssion *
- Palisades Plant Reply to Notice of Violation January-20, 1989 The formation of the Technical Advisory Group is in progress and will be formalized by March 1, 1989 with quarterly management updates beginning simultaneously. The above described Plant Fire Protection Project Program Report will be available by June 1, 1989 ..
II. A. NRC Description Of Violation lQCFR Part 50, Appendix R,Section III.L.7, requires that the safe shutdown equipment arid systems for each fire area shall be known to be isolated from associated non...;safety circuits in the fire, area so that hot shorts *. open circuits, or shorts to ground in the associated circuits w_ill not prevent operation of the safe shutdown equipment.
Contrary to the above, during the July 28 through September 30, 1986 inspection, the* safe shutdown equipment and systems for each fire area were not known to be isolated from associated non-safety circuits in the fire area so that hot shorts~ open circuits, or shorts to ground in the associated circuits would not prevent operation of the safe shutdown equipment. Specifically:
- 1. A fuse and circui.t breaker coordination analysis was inadequate in that the protection provided for fire induced associated circuit common bus failures could notbe demonstrated due to the lack of time current curves. . This inadequacy. demonstrated a failure_ to adequately show that this type of associated circuit could not have prevented operation of required safe shutdown equipment.
- 2. The licensee had not analyzed the letdown interface for spurious operations that could cause a fire-induced LOCA via the letdown high/low pressure interface. Since the licensee had not performed a letdown high/low pressure interface spurious signal analysis, the licensee's protection for a fire-induced LOCA via the letdown high/low pressure interface could not be demonstrated. The NRC also identified that as of May 13; 1988, two cables routed together were susceptible to the same fire that could have caused the simultaneous spurious opening of the letdown orifice valves.
These two examples are considered as a Severity Level IV violation.
Consumers .Power recognizes the facts presented above to be accurate and concedes the violation. However, Consumers Power Company maintains that no condition adverse to safety was presented.
Reason For The Violation
- 1. IE Inspection Report 86022 identified that the Palisades Plant breaker coordination study, as required by 10CFR50 Appendix R Sections III.G OC0189-0017-NL04
Nuclear-Regulatory Commission 5 Palisades Plant
.. Reply to Notice of Violation January 20, 1989 and L. was.incomplete in that time current curves were not available for the inspectors review. As part of the effort undertaken to assure compliance .with Appendix R pdor to the l986 NRC inspection, Consumers Power determined that a complete bus coordination study would not be required. This determination was based on:
- a. The assumpt;ion that necessary studies were- completed during original plant construction,
- b. necessary time current curves were assumed to be retained with original plant construction records, arid
- c. all bus coordination studies completed as a result of plant modifications had demon~trated the first two assumptions to be correct.
- 2. During the 1986 NRC inspection, the inspectors identified that Consumers Power had not identified or evaluated the letdown portion of the Chemical and Volume Control System and its associated equipment as
- a high/low pressure interface. The evaluation was not completed at the time of the l986 inspection as Consumers Power did not consider this system to be a high/low press~re interface requiring an analysis.
Decisions.made as to what systems would constitute high/low pressure interface$ were based on information available and engineering judgement. It was not until Generic Letter 86-10 was issued in April 1986 that clarification of the spurious signal criteria for high/low pressure system interfaces requiring analysis under Appendix R was provided. However, guidance which defines a high/low pressure interface, thus minimizing the potential for mis-interpretation occurring in the industry and at Palisades (eg, pressurizer relief path), has not been provided.
Corrective Actions Taken *~md Results Achieved
- 1. By letter dated October 14, 1986 Consumers Power committed to perform a complete circuit breaker coordination analysis by December 1, 1987.
During IE Inspection 88012 the inspectors reviewed the completed analysis and "determined that breaker coordination was now satisfactory" ..
- 2. After the 1986 inspection, analyses performed regarding the Palisades letdown high/low pressure interface concluded that although a spurious signal could occur, a simultaneous opening of CV-2001 and one of the associated-letdown orifice isolation valves, CV-2003, CV-2004 or CV-2005 would be required to bridge the high and low pressure systems.
In this scenario, the potential for primary coolant inventory imbalance is mitigated by the operation of one charging pump.
During the 1988 inspection, the NRC acknowledged the potential for a spurious signal as pointed out by Consumers Power, however, the inspectors noted that fir~-induced spurious signals could result in OC0189-0017-NL04
Nuclear Regulatory Commission 6 Palisades Plant Reply to Notice of Violation January 20, 1989
. spurious operation of CV-2001 simultaneously with the spurious opening of all three letdown orifice valves CV-2003, CV-200.4. and CV-2005. The inspectors further noted that the two cables providing power to the four valves were routed in a common enclosure and hence were susceptible to additional fire indtic~d spurious signals.
As an interim protection measure against the potential failures, compensatory fire watch patrols were implemented in areas susceptible to fire damage. Full resolution of this matter was achieved when Off-Normal Procedure (ONP) 25.2 was revised to instruct operators to remove power to the letdown orifice valves, thereby assuring the
. orifice valves would close and remain in the closed position until power was restored.
Corrective Actions To Be Taken To Avoid. Further Non-Compliance As the failure to assure compliance with Appendix R for the issues noted above centered around rule mis-interpretations and documentation inadequacies, the formation of the Technical Advisory Group and the resulting management updates discussed previously are also applicable.
These efforts will focus on technical resolution of issues relating to Appendix R and provide a forum to communicate potential mis-interpretations to both Consumers Power management and the NRC. * .
Date When Full Compliance Will Be Achieved Full compliance was achieved for the two specific items as indicated below:
The breaker coordination study was completed on September 29, 1987 and ONP 25.2 was revised on May 19, 1988.
The schedule for. implementation of the corrective actions associated with the Technical Advisory Group is as specified above for Notice of Violation I.
II. B. NRC Description Of Violation 10CFR Part 50, Appendix B, Criterion XVI, as implemented by Consumers Power Quality Assurance P,rogram for Operational Nuclear Power Plants, Section. 16, requires in part, that conditions adverse to quality, such as deficiencies of equipment are cor~ected as soon as practi~al. It further requires that the controls assuring corr.ective. action are implemented in a timely manner.
Contrary to the above, following an NRC identification of eight hour emergency lighting system deficiencies in July 1986, during a corrective action review in September 1986 the licensee identified that additional deficiencies existed with the lighting system. By letter dated December 12, 1986 they committed to correct these lighting system deficiencies by approximately November 13, 1987. However, while some corrective actions were taken, deficiencies still existed on June 30, 1988.
OC0189-0017-NL04
Nuclear Regulatory Commission 7 Palisades Plant Reply to Notice of Violation January 20,. 1~89 This is a Severity Level IV violation.
Consumers Power acknowledges the facts presented as correct and concludes that the Notice of Violation is not warranted. In addition, Consumers Power*maintains that no condition adverse to safety was presented and* that adequate compensatory action was provided.
Reason For The Violation IE Inspection Report 86022 identified that emergency lighting, as required by 10CFRSO Appendix R,Section III ,J was not available in the following areas:
. a. Volume Control Tank (VCT) Room,
- b. Boric Acid Storage Tank (BAST) Room,
- c. 590' level by air ejector (in pit) near makeup valv~, and
- d. Containment 607' level near CV-2001 By letter dated October 14, 1986, Consumers Power committed to install emergency lighting ui;iits (ELUs) in the VCT Room, BAST Room and 590' level prior to startup from the Fall 1986 Maintenance Outage. Consumers Power,
- further committed to require operators to carry portable lights as a
- compensatory measure until lighting which could withstand containment environments could be identified. By letter dated-December 12, 1986, Consumers Power informed the NRC that ELUs had been installed for three of the areas identified in the October 14, 1986 letter. This let.ter also informed the NRC the technical concerns regarding installation of an ELU*at CV-2001 had not been resolved, and that access/egress routes to other required equipment would be re-evaluated for additional ELU installation.
The actions were scheduled for completion prior to startup from the 1987 Maintenance Outage.
On October 6, 1987 Consumers Power informed the NRC of plans to defer the outstanding commitments identified in our letter of December 12, 1986 until startup from the Spring 1988 Maintenance Outage. Compensatory measures previously identified would remain in effect. By letter dated February 10, 1988 the NRC was updated as to continuing difficulties being experienced in finding qualified eight hour battery powered lights which could withstand the anticipated environmental conditions e.t CV-2001. This letter further identified that the anticipated Spring 1988 Outage would not take place and that resolution of lighting at CV-2001 would take place during the upcoming 1988 Refueling Outage. *The commitment to carry portable lighting as a compensatory measure was again reconfirmed. By letter dated December 1,
- 1988 the NRC was informed that further associated circuits analyses had been performed which disclosed that manual operation of CV-2001 was not required, hence an ELU was not required.
OC0189-0017-NL04
Nuclear Regulatory Commission 8 Palisades Plant Reply to Notice of Violation January 20, 1989 As indicated wi_thin the chronological correspondence listed, Consumers Power notified and continually updated the NRC regarding resolution of the ELU issue. The compensatory acdon of carrying portable lights was documented and perceived as an appropriate interim measure. Since no communications were received from the NRC regarding the timeliness of actions and that safety concerns were eliminated by the compensatory_
. measures, Consumers Power believed resource allocation to resolve this matter ~as appropriate.
Corrective Actions Taken and Results Achieved As stated in Consumers Power's letter to the NRC of December 12, 1986,ELUs have been installed-in the VCT Room, BAST Room and on the 590' level in the Turbine Building near the air ejector.* Therefore, compliance with Section III.J of Appendix R has been achieved. As stated in Consumers Power's December 1, 1988 submittal, an ELU at CV-2001 is no longer necessary. The
- need for an ELU at CV-2001 was eliminated when_ additional analysis determined that manual closing of CV-2001 is not necessary to meet the applicable guidelines of Generic Letter 86-10. Thus, compliance with Section III.J has also been achieved for CV-2001. In addition, Consumers Power completed an additional ElU walkdown which recommended a number of additional.ELUs as being desirable. These additional ELUs were installed during the 1988.Refueling Outage.
Corrective Act.ions To Be Taken To Avoid Further Non-Compliance The formation of the Technical Advisory Group for Appendix. R issues and the planned quarterly management updates will provide a forum for resolution of technical issues, provide a vehicle to obtain continuing management
- involvement and effective communication with the NRC.
Date When Full Compliance Will Be Achieved Full compliance has been achieve_d for the issues identified within this viol~tion. Completion of actions associated with the Technical Advisory Group will be achieved under the schedule defined within Notice of
David P Hoffman Vice President Nuclear Operations CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Plant.
OC0189-0017-NL04
CONSUMERS POWER COMPANY Pali.sades Plant Docket 50-255 - License DPR-20 RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITiON OF CIVIL PENALTIES DATED DECEMBER 22, 1988 At the request of the Commission and pursuant to the Atomic Energy Act* of 1954
- and the Energy Reorganization Act of 1974, as amended, and the Commission's Rule and Regulations thereunder, Consumers Power Company submits our response to Notice of Violation and Proposed Imposition of Civil Penalties dated December 22~ 1988. Consumers Power Company's response is dated January 20, 1989.
CONSUMERS POWER COMPANY Sworn and subscribed to before me this 20th day of January 1989.
,z~~~~
Elaine E Buehrer, ~ Public Jackson County, Michigan My cominission expires October 31, 1989 OC0189-0017-NL04