ML18064A401
| ML18064A401 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/30/1994 |
| From: | Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18064A402 | List: |
| References | |
| NUDOCS 9410110006 | |
| Download: ML18064A401 (3) | |
See also: IR 05000255/1994013
Text
,,
Consumers Power Company
ATTN:
Mr. T. Palmisano
General Manager
Palisades Nuclear Generating Plant
- 27780 Blu~ Star Memorial Highway
Covert, MI * 49043-9530
September 30, 1994
.
.
.
.
.
SUBJECT:
EMERGENCY OPERATING PROCEDURES FOLLOWUP INSPECTION*
(INSPECTION REPORT NO. 50-255/94013(DRS))
Dear Mr. Palmisano:
This refers to the inspection conducted by R. A . .Langstaff and J. A. Lennartz
of this office and G. R. Bryan, Jr. of Comex Corporation on August 22-26.
1994.
The inspection included a review of authorized activities for yriur **
Palisades Nuclear Generating Plant.
At the conclusion of the inspection, the~
findings were discussed with you and your* staff on August 26, 1994.
.
.
.
.
The inspection focused on your eme-rgency *operating procedures ( EOPs) . and the
EOP program.
The enclosed copy of our inspection report identifies areas*
examined during the inspection. Within these ~reas, the inspection ~onsist~d
- of a selective examination of procedures and representative records,
observations, and interviews with personnel ..
Although EOPs* were generally acceptable, weaknesses in the EOP program were
identified durin~ this ins~ection. These weaknesses were underscored by -
difficulties operators had in locating equipment during inspection
walkthroughs.
In one case, an operator initially went to the wrong building
to locate a valve.
Such difficulties could cause significant delay and
confusion when responding to an accident.
Because of the programmatic
weaknesses, the quality of EOPs could be degraded over time by future*
r~visions.
We request that you provide a~esponse which addres~~s some ~f
these weaknesses. * Specifically, you are requested to ad~ise us of any plans
which you may have to improve the EOP Basis documents or other plant specific
technical guideline documentation to provide greater valtie to the EOP
.
-de~elopment and. revision process.
In addition, pl~ase advise us rif any ,plans
which you may have td improve the EOP writers' guide to ensure EOPs are
consistent with complete information, especially with regards tq location
- information, tdmponent identification, and other human factors considerations.
Based on the results of this inspection, certain of your activities appeared
to be in violation of NRC requirements, as specified in the enclosed Notice of
Violation (Notice).
The violation is of concern because the intent of an EOP
9410110006 940930
ADOCK 05000255
G
.PDR
T. Palmisano
2
September 30, 1994
would not have been accomplished due to an error in the procedure.
This error
should have been i dent ifi ed by your EOP veri fi cation program.
Although
- verification had been performed, it was not sufficiently r-igorous to identify .
the error. Several other discrepancies were identified during this inspection
which al~o should have been identified by ~erification efforts.
You are requi~ed to respond to this letter a~d should follow t~e instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence. Specifically, include a description
of your verification efforts to ensure similar errors do not currently exist,
and improvements.to your EOP verification program to en~ure errors ~re not
introduced by future revisions. After reviewing your response .to this Notice,
including your proposed corrective actions and .the results of future
inspections, the NRC will determine whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CF~ 2.790 of the Commission's regulations,* a copy of
this letter, the enclosure(s), and your response(s) to this letter will be
placed in the NRC Public Document Room.
- rhe r~sponses directed by this letter and the accompanying Notice are not
- subject to the clearance procedures. of the Office of Management and Buqget a*s
re qui red by the Paperwork Reduction Act of 1980, Pub. L. No. 96-Sl l. *
Wiwill *gladly discu~s any questions you have concerning this inspection.
Enclosures:
1. * Notice of Violation
2.
Inspection Report
No. 50-255/94013(DRS)
Docket No. 50-255
See Attached Addressees
- Documen~ Name:
R: /PAL94013 .DRS
OFFICE
NAME
DATE
Sincerely,
Original signed by Mark A. Ring
Mark A. Ring, Chief
Operations Branch
Riii
N
To receive a copy of this document, indicate in the boa *c* * Copy without attach/encl "E" * Copy with attach/encl
"N" * No copy
OFFICE
Rin
o9rd94.
OFFICIAL RECORD COPY
T. Palmisano
3
' *
- Addressees "
. cc w/encls: R. A. Fenech, Vice President
Nucl~ar Operations
David W. Rogers, Safety and
Lic~nsing Director
James R. Padgett, Michigan
Public Service Commission
Michigan Department of
Public Health *
Department of Attorney General (Ml}
Gordon R. Bryan, Jr., Comex Corporation
Distribution:
RI, Palisades, BRP w/epcls
G. E. Grant, Riii w/encls
LPM, NRR w/encls
.
September 30, 1994
Docket File w/encls
PUBLIC
IE~Ol w/encls
~C/LFDCB w/encls
- DRP w/encls
Jesse A. Arildsen, HHFB, NRR w/encls
Rill PRR w/encls