ML18054B004

Responds to NRC 890811 Ltr Re Violations Noted in Insp Rept 50-255/89-18.Corrective Actions:Memo Detailing Procedural Requirements Issued to All Licensed Operators & All Shift Supervisors & Engineers Counseled on Existing Requirements

ML18054B004
Person / Time
Site:	Palisades
Issue date:	09/19/1989
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8909270267
Download: ML18054B004 (3)

Text

Kenneth W Berry Director Nuclear Licensing General _Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 September _19; 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

REVISED RESPONSE TO INSPECTION REPORT 255/89018 NOTICE OF VIOLATION Nuclear Regulatory Commission Inspection Report 255/89018, dated August 11, 1989 identified an item of violation with items A and B regarding 10 CFR 50 Appendix B, Criterion III Design Control. Item B to the violation required a response. Our response dated September 11, 1989 requires a revision in the Corrective Actions To Be Taken To Avoid Further Non-Compliance Section in order to correctly explain the action taken. This revision is noted by a slash mark in the 'right hand margin. The violation and Consumers Power Company's response is as follows:

Notice Of Violation (255/89018-02A & B) 10CFR50 Appendix B, Criterion III, Design Control, requires establishment of measures to assure that the applicable regulatory requirements and the design basis of the Plant are maintained. The licensee's QA Program at Article 3.2 of CPC-2A Article 3.2 outlines controls for design changes. Administrative Procedure (AP) 9.31, "Temporary Modification Control", implements controls for design changes which are of short duration and references AP 4.03, "Equipment Control" as an example of a temporary modification where a temporary opening needs to be controlled to maintain the design basis for the system.

Contrary to the above:

A. During the period of June 21 through August 22, 1988, the Control Room ventilation boundary was breached during maintenance by the removal of several electrical penetration seals without initiation of a Temporary Modification as required for Equipment Control. This resulted in the failure of the ventilation system's ability to maintain a positiye pressure during a surveillance test. The ventilation system is described in FSAR Section 9.8 as being designed to control the flow of airborne radioactivity during an accident so as to minimize the impact on operating personnel

• This opening of the penetrations constituted an unreviewed design change.

OC0989-0194-NL04 8909270267 890919 PDR ADOCK 05000255 G PNU

Nuclear Regulatory Commission 2 Palisades Plant Response to Inspection Report 255/89018 September 19, 1989 B. On June 14 the licensee blocked open the "doghouse" entrance flood door (to the East Safeguards Room from the 590 foot elevation) to facilitate installation of a bushing/retainer ring to MV-3234 per WO 24903179 and did not implement a Temporary Modification as required for Equipment Control.

The provision of flood doors to protect safety-related equipment is described in FSAR Section 5.4. Blocking the flo~d door open constituted unreviewed design change.

This is a Severity Level IV violation.

Reason For Violation B. On June 15, 1989 Plant Maintenance personnel opened the water-tight "doghouse" hatch from the 590 foot elevation of the Component Cooling Room to the East Safeguards Room in order to facilitate passing welding cables required for completion of an in-progress work activity. The work activity, WO 24903179, involved the removal of and replacement of thrust rings, a yoke bushing and a new collar for the safety injection tank drain line isolation valve MV-3234A. Prior to opening the water-tight hatch, Maintenance personnel contacted and obtained permission from the Control Room to allow opening of the door. While personnel had been posted as a door watch with instructions to disconnect the cables-if directed by the Control Room, a Temporary Modification (TM) had not been processed as required by AP 4.03. _The Shift Supervisor had the work activity secured upon identification that a TM had not been processed.

AP 4.03 states that, "in general, the removal of floor plugs or blocking open hatches and flood doors shall be approved by the Shift Supervisor. In addition, the use of a Temporary Modification or associated controls as specified in Administrative Procedure 9.31, 'Temporary Modification Control' shall be used whenever the primary coolant system is greater than 325 degrees F *** ". AP 9.31 is designed to control TMs in a manner that ensures awareness of Operations personnel, conformance with design intent and operability requirements and preserves Plant and personnel safety.

This procedure provides requirements for controlling and documenting TMs for all safety-related and nonsafety-related systems. TMs are Plant modifications which are intended to be minor in scope, of short duration (typically less than 90 days) and be few in number such that updating drawings and other documents is not warranted.

The failure to perform a TM of inplace associated controls per AP 9.31, as required by AP 4.03, has been attributed to inadequate knowledge and review of controlling Plant procedures during both the planning and implementation phase of the work activity.

Corrective Actions Taken And Results Achieved In order to heighten Plant personnel awareness of existing procedural require-ments for water-tight door, plug and hatch control, informational statements

• were placed in the Plant Daily Status Sheet and the Weekly Plant Bulletin.

OC0989-0194-NL04

Nuclear Regulatory Commission 3 Palisades Plant Response to Inspection Report 255/89018 September 19, 1989 These documents are available to all Plant personnel and receive extensive distribution. A memorandum detailing procedural requirements was issued to all licensed operators and additionally, all Shift Supervisors and Shift Engineers were counselled on existing requirements.

Corrective Actions To Be Taken To Avoid Further Non-Compliance Procedures governing the control of water-tight doors and hatches and the compensatory measures which need to be taken when they are opened are being revised. These revisions will include placing control requirements existing in AP 4.03 and AP 9.31 into AP 4.02, "Control of Equipment St*:.:itus". This procedure d~fines requirements and operator responsibilities for identifying, maintaining and verifying proper status of Plant systems and components. In order to ensure the design intent of water-tight doors, floor.plugs and hatches currently requiring a TM be performed is maintained, an encompassing 10CFR50.59 safety evaluation was performed on the new AP 4.02. By placing I required controls into one procedure and by performing a single safety evaluation,' more consistent application and quality of controls will result.

Additionally, AP 5.01, "Processing Work Requests/Work Orders" will be revised to highlight the need for compensatory measures during the work pianning process.

• Specific training on these changes will be provided to Plant Maintenance, Operations and Radiological Decontamination personnel. Additionally, this issue will be presented to the Training Review and Tracking Committee (TRTC) for evaluation and potential inclusion into Plant-wide training.

Date When Full Compliance Will Be Achieved The revision to AP 4.02 will be in place by October 1, 1989 with AP 5.01 revised by October 15, 1989. The work group specific training will be completed by November 15, 19S9. The TRTC will evaluate this issue by October 26, 1989.

Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRG Resident Inspector - Palisades

• OC0989-0194-NL04