ML18054A881

Responds to NRC 890118 Ltr Re Violations Noted in Insp Rept 50-255/88-20.Corrective Action:Verbal Interaction Will Be Encouraged Between Engineering & Maint Personnel

ML18054A881
Person / Time
Site:	Palisades
Issue date:	07/31/1989
From:	Frisch R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8908080154
Download: ML18054A881 (4)

Text

consumers Power POWERI Nii MICHlliAN'S PROliRESS General Offices: 1945 West* Parnell Road, Jackson, Ml 49201 * (517) 788-0550 July 31, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR COMPLETION OF COMMITMENT MADE IN RESPONSE TO INSPECTION REPORT 88020 Nuclear Regulatory Commission letter dated January 18, 1989 transmitted the Special Maintenance Inspection results as Inspection Report 88020. The results indicated that while communications between Maintenance and Engineer-ing personnel during maintenance activities appeared good, documentation of engineering resolution to problems noted during maintenance activities needed improvement. Consumers Power Company letter dated February 17, 1989, provided our initial response to the inspection. In Attachment II of the response, we committed to evaluate engineering documentation of directions and decisions related to maintenance activities. Subsequently, NRC letter dated March 20, 1989 requested that we provide a docketed response describing the results of decisions made within 30 days of the decision date. Consumers Power Company's revised response date~ April 14, 1989 committed to complete the engineering documentation evaluation by June 30, 1989 and to inform the NRC of decisions reached by July 30, 1989. The at.tachment to this submittal provides the evaluations and decisions made regarding documentations of engineering directions and decisions.

~o.4>hQaL Ralph R Frisch Senior Licensing Analyst CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment 99 oaoao154 890731

~DR ADOCK 05000255 PNU IEIR 88020-LI01-NL04

ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 Results of Evaluation Regarding Documentation of Engineering Directions and Decisions Associated with Maintenance Activities July 31, 1989 2 Pages IEIR 88020-LI01-NL04

1 Evaluation of Documentation of Engineering Directions And Decisions Associated with Maintenance Activities As stated in Section 3.3.3 of Inspection Report 88020; " .*. verbal communica-tions between Maintenance personnel and Engineering personnel appeared good.

Discussions with Engineering personnel indicated that Maintenance personnel usually did not hesitate to contact Engineering for assistance or resolution to problems. However, documentation of engineering resolution to problems noted on WOs during the performance of the job was usually missing or phrases similar to 'Engineering resolved problem' or 'Engineer notified of problem' was the only objective evidence that engineering was involved.

System engineers provided support of maintenance activities; further develop-ment will continue to improve their effectiveness and result in improved maintenance. Verbal communications were good; however, documentation of problem resolution and evaluation needed improvement."

In response to this concern, Consumers Power Company believes the need to document engineering involvement in a particular maintenance activity needs to be balanced with the effective completion of the activity. This philosophy is currently indicated in our Administrative Procedures.

Palisades Administrative Procedure 5.01, "Processing Work Requests/Work Orders" currently requires the Maintenance supervisor(s) to assure the Work Order (WO) package is complete per Attachment 6 of the procedure, "Work Order Review Guide". This attachment requires a review of the summary of the work performed including a clear description of the work actually performed.

Information found in this section is typically provided by Planning and Maintenance personnel, however, all Plant personnel, including Engineering personnel may provide documentation of activities associated with a particular WO.

IEIR 88020-LI01-NL04

2 Palisades Administrative Procedure 9.11, "Analyses" states the need for an Engineering Analysis (EA) is usually i~entified during the performance of the engineering design phase of the Plant modification process, ho~ever, it also recognizes the need for an EA may also be identified during the corrective action, maintenance, procurement process, etc. EAs may include reactor physics, seismic, radiation, stress, thermal, hydraulic and accident analysis, assessment of compatibility of materials, determination of accessibility for inservice inspection, environmental, personnel safety and operability, but are not limited to th~se subjects.

While no specific administrative requirement exists for WO documentation of all engineering decisions or direction, Consumers Power Company believes that in cases where the direction of a maintenance activity is significantly affected by an engineering consultation, it is appropriate that such direction be documented within the WO summary. Consumers Power Company also recognizes the need for such formal analyses to be performed and then referenced by the WO. However, we do not believe this level of detail is necessary for all

• engineering consultations and believe such a requirement would create a deterrent to the daily interaction currently being encouraged between Engineering, Maintenance and other disciplines.

In summary, verbal interaction between Engineering and Maintenance personnel will continue to be encouraged as we firmly believe this interaction results in less rework and higher quality maintenance activities. Supervisory direction has been provided to Engineering personnel, and is periodically reinforced, regarding the need to provide written documentation of engineering directions and decisions associated with maintenance activities within the WO summary. This philosophy will be reiterated at the System Engineering monthly training meeting in September 1989.

IEIR 88020-LI01-NL04