ML18065A814
| ML18065A814 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/03/1996 |
| From: | Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9607150034 | |
| Download: ML18065A814 (6) | |
Text
consumers Power l'OWERINli MICHlliAN'S l'ROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 July 3, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT REPLY TO NOTICE OF VIOLATION - NRC INSPECTION REPORT 50-255/96003 -
FAILURE TO UPDATE DESIGN BASIS DOCUMENTS AS REQUIRED NRC Inspection _Report 50-255/96003 dated May 24, 1996, documented the results of an inspection which found that the following violation had occurred:
10 CFR 50.Appendix B, Criterion V, "INSTRUCTION
S. PROCEDURE
S, AND ORA.WINGS", requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Procedure 3. 15, "Design Basis Document Maintenance," Revision 3, dated June 9, 1995, Step 5. 2, specifies, in part, revisions to the design basis documents (DBD) at least biennially.
Contrary to the above, as of March 29, 1996, the licensee had not performed a biennial review and revision on 14 of 36" DBDs* for over two years.
9607150034 960703.
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A CMS" ENERGY COMPANY
.* --'fhis reply is; with the concurrance of the NRC Palisades Senior Resident Inspector, being submitted within 30 days of the date (June 6, 1996) the Notice of Violation was
- received. Attachment 1 provides our reply to the Notice of Violation.
SUMMARY
OF COMMITMENTS This letter contains three new commitments and no revisions to existing commitments.
The new commitments are as follows:
- 1.
Log all existing Design Basis Document (DBD) change requests in front of the controlled copies of the DBDs.
- 2.
Complete biennial reviews and revisions of all DBDs.
- 3.
Perform a self assessment of the DBDs to verify that the design basis documents are being maintained in accordance with procedural requirements.
Richard W. Smedley Manager, Licensing
. CC Administrator, Region Ill, USN RC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment 2
CONSUMERS POWER COMPANY To the best of my knowledge, the contents of this reply to Notice of Violation 50-255/96003-02, are truthful and complete.
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Richard W. Smedley, Manager, Licensing Palisades Nuclear Plant Sworn and subscribed to before me on this 3rd day of July 1996.
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Berrien County, Michigan (Acting in Van Buren County, Michigan)
My commission expires February 16, 2000
-~
ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION - NRC INSPECTION REPORT 50-255/96003 -
FAILURE TO UPDATE DESIGN BASIS DOCUMENTS AS REQUIRED 2 Pages
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION FAILURE TO UPDATE DESIGN BASIS DOCUMENTS AS REQUIRED NRC VIOLATION 10 CFR 50 Appendix 8, Criterion V, "INSTRUCTION
S. PROCEDURE
S, AND DRAWINGS", requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Procedure 3. 15, "Design Basis Document Maintenance," Revision 3, dated June 3, 1995, Step 5.2, specifies, in part, revisions to the design basis documents (DBD) at least biennially.
1 Contrary to the above, as of March 29, 1996, the licensee had not performed a biennial review and revision on 14 of 36 DBDs for over two years.
'-.../
CONSUMERS POWER COMPANY RESPONSE
Background
The first DBD went beyond its biennial review date without being reviewed and revised in March 1995. It was inappropriately determined by Design Engineering Management that performing biennial reviews and revisions was a guideline and not a specific administrative procedure requirement.
During an inspection (March 18-April 26, 1996), the NRC noted that a DBD had become inactive. Design Engineering Management, in following up on a condition
- report written because of the NRC finding, discovered that 14 of 36 DBDs had not been reviewed and revised biennially as required by Administrative Procedure (AP) 3. 15.
Admission Consumers Power Company agrees with the violation as stated by the NRC.
Reason for Violation The reason for this violation is:
- 1.
Inadequate Design Engineering Management attention to procedure requirements.
The DBD maintenance effort was given a low priority and inadequate resources were applied.
2 Corrective Actions Taken and Results Achieved
- 1.
Design Engineering Management has acknowledged this mistake and has been held accountable. This action will ensure that procedural requirements will be followed in the future.
- 2.
All DBD owners have reviewed their respective DBDs and they have knowledge and control of all outstanding change requests. They completed their qualification cards and the last DBD owner was qualified on May 17, 1996.
- 3.
The Safety/Design Review Section assures that DBD change requests are
/------..
initiated for any changes that affect a DBD. This process ensures that prior to
'-.../1 the DBD update the DBD owner is cognizant of changes.
Corrective Action to be Taken to Avoid Further Noncompliance The following corrective actions will be taken to avoid further noncompliance:
- 1.
Log all DBD change requests in front of the controlled copies of the DBDs.
This action will ensure that all persons using the DBDs will be aware of outstanding changes. *
- 2.
Corrip-lete biennial reviews and revisions of all the DBDs.
- 3.
Perform a self assessment of the DBDs to verify that the design basis documents are being maintained in accordance with all procedural requirements.
Date when Full Compliance Will Be Achieved Palisades Nuclear Plant will be in full compliance by March 31, 1997.