ML18065A327
| ML18065A327 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/04/1995 |
| From: | Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9512110123 | |
| Download: ML18065A327 (5) | |
Text
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consumers Power
- pawtRIN&
lllllCHl&AN"S PRO&RESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 December 4, 1 995 U S Nuclear Regulatory Commission.
Document Control Desk
- Washing.ton,* DC 20555
. DOCKET 50-255 - LICENSE DPR PALISADES PLANT REPLY TO NOTICE OF VIOLATiON - USE OF ALTERNATIVE TO ASME CODE ACCEPTANCE CRITERIA PRIOR TO NRC AUTHORIZATION NRC Inspection Report No. 50,.255/95011 contained a Notice of Violation which concerned the failure to obtain NRC authorization prior to deviating from ASME
- Code-specified vibration acceptance criteria for selected pumps. The revised vibration acceptance criteria were applied to inservice testing of the Containment Spray and Low Pressure Safety Injection Pumps.
- contains our response to the violation.
SUMMARY
OF COMMITMENTS
. This letter contains no new commitments and no revisions to existing commitments.
Richard W Smedley Manager, Li~ensirig CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment 9512110123 951204 PDR ADOCK 05000255 Q
. CONSUMERS POWER COMPANY To the best of my knowledge, the.contents of the letter dated December 4, 1995, entitled "Reply to Notice of Violation - Use of Alternative ~o ASME Code
- Acceptance Criteria Prior to NRC Authorization," are truthful and complete.
By
~>-L'>-
Tho~
J Palmisario Plant General_ Manager Sworn and subscribed to before me this "/~ day ofCb 0ou&y. 1995.
- Alora M. Davis, Notary Public*
Berrien County, Michigan.
{Acting. in Van Buren County, Michigan) * *
. My commission expires August. 26, 1999
[SEAL]
ATTACHMENT CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION USE OF ALTERNATIVE TO CODE ACCEPTANCE CRITERIA PRIOR TO NRC AUTHORIZATION.
2 Pages
REPLY TO NOTICE OF VIOLATION USE OF ALTERNATIVE TO ASME CODE ACCEPTANCE CRITERIA PRIOR TO NRC AUTHORIZATION NRC VIOLATION During an NRG inspection conducted on August 22 through October 11, 1995, a violation of NRG requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions, " NUREG-1600 (60FR34381, June 30, 1995), the violation is listed below:
10 CFR 50. 55a(a)(3), states, in part, proposed alternatives to the requirements of paragraph (f) of this section (inservice testing) may be used when authorized by the Director of the Office of Nuclear Reactor Regulation. Technical Specification 4.0.5.a states, in part, inservice testing of ASME Code Class 1, 2, and 3 pumps shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code, except where specific written relief has been granted by the Commission.
Contrary to the above, as of September 1, 1995, the licensee had implemented a proposed alternative to the Code vibration acceptance criteria for the inservice testing of the containment spray and low pressure safety injection pumps, with9ut prior NRG authorization. Relief Request number 4; submitted by the licensee on
.June 28, 1991, and revised by letter dated De~ember 29, 1992, requested Commission approval of the proposed alternative, but was denied by the Commission 'in letters date'd July 28,' i 991, and April 20, _1995.
This is a Severity Level IV violation (Supplement I).
Consumers Power Company Response Reason for Violation 1 OCFR50.55a contains two methods for authorizing deviations from ASME Boiler and Pressure Vessel Code requirements. If conformance with a Code requirement is "impractical",.1 OCFR50.55a{f)(5) requires NRC notification and submittal of justification for the deviation, but the deviation may be implemented prior to formal NRC approval.
- 1f an "alternative" is proposed to a provision of 1 OCFR50.55a, including the referenced code provisions, 1 OCFR50.55a(a)(3) specifies that approval of the Director, NRR is required prior to implementation.
Co,nsumers Power Co erroneously assumed that the proposed deviation from Code vibration limits fell under 10CFR50'.55a(f)(5), and could be implemented prior to NRC approval. This assumption continued even though*CPCo and NRC correspondence referenced 1 OCFR50.55a(a)(3) when discussing the proposed vibration acceptance criteria. Inattention to detail led to several missed opportunities to recognize that this assumption was in error.
CNrective Action Taken and Results Achieved A revised relief request which proposed alternate vibration alert limits was submitted for NRC review.on September 18, 1995. The NRC approved this request in a letter dated October 12, 1. 995.
The requirements of 1 OCFR50.55a for authorizing deviations from specified Code limits have been reviewed with the ISl/IST staff.
As part of the 10-year code update process, all relief requests for Section XI testing have been reviewed for similar code deviations which may require NRC approval prior to implementation. This review identified one relief request associated with lnservice Testing of snubbers and four relief requests assoc:iated with lnservice Testing of valves that will require NRC approval prior to
- implementation. The*se relief requests involve future te~ting plann_ed for the nex,t Palisades refueling outage, currently scheduled for late 1996. They will be.
submitted for staff approval.
Corrective Actions Remaining to Avoid Further Violations All *necessary corrective actions have been completed.
Date Full Compliance Will Be Achieved Full compliance has been achieved.
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