ML18066A887
| ML18066A887 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/20/1997 |
| From: | Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEIN-96-045, IEIN-96-45, NUDOCS 9702280032 | |
| Download: ML18066A887 (4) | |
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consumers Power l'llWUUllli llllClll&Aln l'llOlillUS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 February 20, 1997 lJ~S. Nuclear R.egulatory Commis_sion ATIN: Document.Control. Desk
- washingtoh, DC 20555
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Thomas J. Palmlsano
. Plant General Manager
- o_oc~ET so-2s:s ~~.L1cE~sE OPR-20 :*PAL1sADEs PLAN:r
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REPLY TO NOTICE OF VIOLATION 50-255/96010-03, REVISION 1 NRC Inspection Report No. 50-255/~6010-03, dated December 5, 1996, contains a Notice of Violation which concerns a failure to initiate a Condition Report upon,
. _ discovery that Palisades was potentially susceptible to the problems noted in NRC
. Information Notice 96-45. The Notice of Violation states that Palisades failed to follow the requirements of Administrative Procedure 3.03, "Corrective Action System" by not issuing a Condition. ~eport to resolve the problems identified.
On January 6, 1997, Consumers Power Company (CPCo) submitted a reply to the Notice of Violation requesting that it be withdrawn. It was believed that the Information Notice was processed within the Industry Experience Program in a timely manner and that the Condition Report which was generated later was consistent with the guidelines of Administrative Procedure 3.16, "Industry Experience Review Program" and*
Administrative Procedure 3.03, "Corrective Action System".
- Since the reply was submitted, we have discussed the subject at length with the site. ~~-/
Residen~ Inspectors. We more fully understand their concerns and acknowledge that...v some procedural improvements are appropriate to enhance and clarify the relationship between the Industry Experience Review Program and the Corrective Action Program.
9702200032 970220 PDR ADOCK 05000255 G
POR A GHS' ENERGY COMPANY
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- j We have concluded that a revision to the reply is warranted to retract the request that the Notice of Violation be withdrawn. The Attachment to this letter provides that revised reply.
SUMMARY
OF COMMITMENTS This letter contains one new commitment to revise Administrative Procedure 3.16, "Industry Experience Review Program" and Administrative Procedure 3.03, _"Corrective Action Process*," to provide clearer guidance as to when a Condition Report should be initiated as a result of an Industry Experience document.
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Thomas: J. Palmisano Plant GeneraJ Manager CC * *.Administrator, Region Ill, USN RC Project Manager, NRR, USNRC NRC *Resident Inspector - P~lisades Attachment 2
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'l NRC VIOLATION REPLY TO NOTICE OF VIOLATION 50-255/96010-03 DATED JANUARY 6, ~997 REVISION 1 FAILURE TO INITIATE CORRECTIVE ACTION During an NRG inspection conducted on September 7 through October 18, 1996, a violation of NRG requirements was identified. In accordance with the aGeneral Statement of Policy and Procedure for NRG Enfor~ment Actions," NUREG-1600, the violation is listed below:
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- 10CFR50, AppendixB, Criterion V, "Instructions, Procedures, 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..
Ucensee procedure 3. 03, "Corrective Action Process," Revision 15, Paragraph 7.1, requires that upon discovery of any condition requiring a c6ndition.report*
(CR), an indiviqual shall initiate a CR and immediately hand carry the CR to the individuats supervisor.
Ucensee procedure 3.03, Attachment 10, ucondition Report Guidelines,"*
Revision 15, requires, in part, uThat a condition report should be written
- whenever: Information from external sources (e.g., vendors, INPQ, NRCJ.that indicates a potential problem at Palisades."
- Contrary to the above:
Ucensee staff failed to initiate a CR upon discovery that Palisades was potentially susceptible to the problem described in NRG Information Notice 96-45 "Potential Common-Mode Post Accident Failure of Containment Coolers."
This is a Severity Level IV violation (Supplement I).
CONSUMERS POWER COMPANY RESPONSE Consumers Power Company (CPCo) agrees the violation occurred as stated,
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REASON FOR THE VIOLATION The reason for the violation was due to weaknesses in Administrative Procedure 3.16 (AP 3.16), "Industry Experience Review Program" and Administrative Procedure 3.03 (AP 3.03), "Corrective Action Process". Specifically, AP 3.16 lacks guidance as.to what types of information would warrant transferring an issue out of the Industry Experience Review Program into the Corrective Action System. It is also weak in the guidance provided regarding the processing of conditions discovered during the evaluation of Industry Experience information that could potentially be a safety concern for the Palisades Plant. In addition, the guidelines provided in AP 3.03 as examples of when a Condition Report should be written were excessively vague in their treatment of issues being processed under the Industry Experience Review Program.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A Condition Repo*rt was initiated when initial evaluation under the Industry Experience Review Program concluded that a* potentinl for equipment damage may exist a~
Palisades under the scenarios described in Information Notice 96-45..
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS AP 3:16 is being revised to include guidance for reporting conditions that could potentially be a safety concern.for the Palisades Plant which are discovered during the review of industry experience events. The guidance will include elevati~n to higher.
. management levels when industry experience information is reported as applicable by multiple facilities. AP 3.03 is also being revised to clarify when a Condition Report should be written for items being processed within the Industry Experience Program.
These procedure revisions will strengthen the interrelationship between the Industry Experience Review Program and the Corrective Action Program.
. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED CPCo is in full compliance.