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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
[Table view] |
Text
A CMS Energy Comoany Palisades Nuclear Plant Tel. 616 164 2296 21780 Blue Star Memorial H1gt1way Fax: 616 164 2425 Covert. Ml 49043
,.....J.,,,,.....
Site Vice President October 30, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT REPLY TO AN APPARENT VIOLATION IN INSPECTION REPORT NO. 50-255/98018 NRC Inspection Report 50-255/98018(DRS) dated October 1, 1998, transmits one apparent violation, which is being considered for escalated enforcement. The apparent -
violation concerns a radioactive shipment which arrived at its destination with* maximum external contact dose rates in excess of that allowed by applicable regulations.
Consumers Energy has concluded that when the shipment arrived at BWX Technologies (BWX), the maximum external contact dose rate was in excess of that allowed by applicable regulations. Based on surveys performed at the Palisades site prior to release of the shipment, and testing performed at BWX, we are confident that the shipment was in compliance with regulatory dose rate limits when it was released for transport. The root cause of this apparent violation is the result of a defective -
shipping cask coupled with the ability of the surveillance capsule to shift during transport. The details surrounding this occurrence and the basis for our conclusion are provided in Attachment 1.
. Additionally, during our investigation of this matter, we identified a number of
-- --- --- ----administrative-practices associated-with-documentation;-supervisory-oversight and- --- -- -- -------- - - -
survey verification that failed to meet our expectations.* Our findings were shared with the NRC Inspector at the time of the inspection and were subsequently documented in the Inspection Report. These issues are of concern to us, especially since we have been working to improve performance in the Radiation Protection area. Our evaluation 9811090156 981030 .,.
PDR G
ADOCK 0500025~
PDR ::(12'DI),
2 of these issues along with actions being taken to correct these problems is provided in Attachment 2.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
-:;?~~
Thomas J. Palmisano Site Vice President CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC .
NRC Resident Inspector- Palisades Attachments
3
- CONSUMERS ENERGY COMPANY To the best of my knowledge, the contents of this reply to an apparent violation in Inspection Report No. 50-255/98018, are truthful and complete.
By ~L____),.,
ThOfTISJ. Palmisano Site Vice President Sworn and subscribed to before me this 3ot11 dayof (J~ 1998.
Mary Ann Engle, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)
My commission expires February 16, 2000
-~------------------*-
ATTACHMENT 1
- REPLY TO AN APPARENT VIOLATION IN INSPECTION REPORT NO. 50-255/98018
~-------
AITACHMENT 1 REPLY TO AN APPARENT VIOLATION IN INSPECTION REPORT NO. 50-255/98018 On August 12, 1998, plant personnel removed a highly irradiated reactor vessel surveillance capsule from the spent fuel pool (SFP) and placed it into a Type A shipping cask provided by Framatome Technologies, Incorporated (FTI). A FTI representative was on site to assist in the loading evolution. Dose rate measurements of the cask as it was being removed from the SFP indicated a maximum contact dose rate of 11 O mrem/hr. This corresponded well with the expected contact dose rate of 106 mrem/hr calculated by FTI. The shipping cask was then transferred to the shipping bay and secured onto a dedicated flatbed trailer. A release-for-transport survey was perfomied on August 14, 1998 showing a single area with a maximum contact dose rate of 170 mrem/hr. This maximum reading was subsequently verified by a second survey. With the release-for-transport survey showing maximum contact dose rates within regulatory limits, the shipment was authorized to leave the site.
The shipment left the Palisades site on August 17, 1998. On August 18, 1998, receipt surveys performed at BWX Technologies (BWX) revealed an area with a contact dose rate reading of approximately 280 - 300 mrem/hr, which is in excess of that allowed by applicable regulations. BWX filed an immediate report with NRC Region. II. Palisades was notified of the results of the receipt surveys and personnel were immediately dispatched to BWX to conduct confirmatory surveys. Based on the seriousness of this occurrence, an Incident Response Team was commissioned to perform a full investigation.
At BWX, Palisades personnel conducted a blind survey of the shipping cask and identified an area of approximately 4 inches in diameter with radiation levels of 280-380 mrem/hr, which validated the location and measurements of the BWX receipt survey.
On August 20, 1998, during the removal of the basket/capsule assembly from the shipping cask, it was observed that the dose rate at the hot spot was very sensitive to rotational and/or axial position changes of the capsule and/or capsule basket. When the weight of the capsule basket was placed on the wire cable for lowering, prior to movement, the dose rate changed from 280 to 190 mrem/hr. This evolution is believed to have caused very little capsule basket axial movement, but the capsule basket may have rotated slightly. The capsule could have moved down a few inches independent of the basket movement at this time. Subsequent lowering of the capsule basket of
_ -~--- -less . than-six-inches-ft;1rther- reeueed-the-hot-spot-dose--rate-to-1 mrem/hr~-Slight ---~-- ---- -- ---- ------
rotational movement may have also occurred during this evolution.
Given the significant radiation level changes seen with little axial movement and unknown rotational movement, a local shielding weak point was expected to exist at the*
1
ATTACHMENT 1 REPLY TO AN APPARENT VIOLATION IN INSPECTION REPORT NO. 50-255/98018.
4 inch diameter hot spot. A decision was made to perform testing on the shipping cask to determine whether shielding inconsistencies were present.
- Radiography Testing of the shipping cask was performed by FTI on October 3 and 4, 1998. Results of the testing showed that the shipping cask contains a defect at the location where the elevated contact dose rate was measured. The defect manifests itself as an approximate 25-30 percent reduction in the expected shielding.
The surveys of the shipping cask. prior to its departure from the Palisades site were sufficiently comprehensive to have disclosed the subject hot spot if it had existed prior to transit. While some limited movement of the capsule and capsule basket within the shipping cask can occur during transit, this would not significantly affect the shipping cask exterior contact dose rates if uniform shielding was present. Therefore, we are confident that the shipment left the Palisades site in compliance with applicable regulations and that a defective shipping cask coupled with slight movement during transport caused the external contact dose rate at the flaw location to be in excess of that allowed by applicable regulations .
ATTACHMENT 2 EVALUATION OF SURVEY AND DOCUMENTATION PRACTICES A number of administrative practices associated with documentation, supervisory oversight and survey verification were identified related to this activity which did not meet expectations. These issues are disappointing and are of particular concern because focus has been placed on improving performance in the radiation protection area due to problems which occurred during the previous refueling outage. While improvement has been noted, we have not yet achieved consistent results. These issues were discussed with .the NRC Inspector during the ,inspection and are described in detail within the Inspection Report. The Incident Response Team evaluation determined that each issue fell within one of three root causes:
- 1. Supervisory oversight was inadequate in that the shipping supervisor performed
. the surveys, completed the documentation and performed the revie.ws of the documentation.
- 2. Lack of rigor in the documentation of certain details and in procedure adherence led to some forms not being completed or being completed incorrectly. In some instances the procedure was unclear.
- 3. Inadequate communication of a management expectation regarding survey performance led to only a partial verification survey being performed.
Actions have been taken to strengthen the radiological shipping program as follows:
- 1. All shipments were temporarily put on hold until a radioactive shipment resumption plan was completed.
- 2. All radiological shipping procedures were reviewed and revised as necessary.
- 3. Training on the procedure revisions was presented to all personnel involved in the shipment of radioactive material. . ____ _
- 4. Expectations were recommunicated regarding supervisory oversight and rigorous procedure compliance.
- 5. This incident was used as a case study during a Chemistry and Radiological Services (C&RS) Department stand down meeting on October 9, 1998. The case stuayproviaeaatnoroogh-descriptionoftne occurrence an-d-aiscussecrthlflesson*~s--
learned. Expectations which had not been clearly understood were discussed and clarified.
1
ATIACHMENT2 EVALUATION OF SURVEY AND DOCUMENTATION PRACTICES Additionally, the following actions are planned:
- 1. Criteria are being developed and proceduralized for the review and approval of Type A (non-NRC) shipping casks, which have not' previously been used at Palisades.*
- 2.
- A self-assessment of the entire Palisades radiological protection program, including the shipping program, will be performed in 1999 to verify effectiveness of not only previous corrective actions, but also corrective actions related to this event.
-~- -----------~----~-- ----- ---- --- -------- ---------- ---~----------------
2
October 1, 1998 EA 98-443 Mr. Thomas J. Palmisano Site Vice President and General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530
SUBJECT:
NRC RADIATION PROTECTION INSPECTION REPORT 50-255/98018(DRS)
Dear Mr. Palmisano:
On September 2, 1998, the NRC completed an inspection of your Palisades Nuclear Generating Plant. The enclosed report presents the results of that inspection. The inspection findings were discussed with you and members of your staff at an interim exit meeting on August 26, 1998, and a final exit meeting by telephone on September 3, 1998. The inspection examined activities conducted under your license related to radiation safety and to compliance with the Commission's rules and regulations and with the conditions of. your license..
Specifically, this inspection reviewed a transportation incident in which a Class 7 (radioactive) package, that was shipped by your facility on August 17, 1998, as an exclusive use shipment on an open transport vehicle exceeded the regulatory limits for radiation levels on the external surface of the package upon receipt. Regarding this incident, the inspection consisted of selective examinations of procedures and representative records and interviews with personnel.
Based on the results of this inspection, one apparent violation was identified and is being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.
Specifically, your facility offered for transportation a Department of Transportation Specification 7A Type A shipping cask that had been loaded with an irradiated reactor surveillance capsule.
Although radiation surveys conducted at your facility determined that the package met the -
regulatory requirements for radiation levels on the external surface prior to leaving your facility, the shipment consignee measured radiation levels that exceeded the regulatory limits. The radiation levels on the external surface of the package were subsequently verified by members of your staff.
9810060168 981001 PDR ADOCK 05000255 G . PDR
T. Palmisano 2 The root causes of the apparent violation could not be determined before the conclusion of this inspection. Our review determined that certain aspects of the preparation of this particular shipment were not conducted in accordance with your transportation procedures or with management expectations and that this shipment was conducted under reduced management oversight and staff involvement. In addition, other information regarding this event indicated the possibility that an inherent problem with the design and/or manufacture of the shipping cask may have contributed to the violation, and we understand that your facility is pursuing an analysis of the cask to determine whether this is the case.
The circumstances surrounding the apparent violation, the significance of the issues, and the need for effective and lasting corrective action were discussed at the interim and final exit meetings. In order to determine whether a predecisional enforcement conference is warranted, we request that you respond to the apparent violation, including your evaluation of your shipment preparation practices and the shipping cask, within 30 days of the date of this letter.
Your response should be clearly marked as a "Response to an Apparent Violation in Inspection Report No. 50-255/98018" and should include: (1) reason for the apparent violation, or, if contested, the basis for disputing the apparent violation, (2) the corrective steps that have. been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response should be submitted under oath or affirmation and may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate response is not received within the time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a predecisional enforcement conference.
If you have questions about this matter, please contact Raymant L. Glinski at 630/829-9725 or Gary Shear at 630/829-9876 as soon as possible.
In addition, please be advised that the characterization of the apparent violation described in the enclosed inspection report may change as a result of further NRC review. You will be advised by separate correspondence of the results of the results of our deliberations on this matter.
In accordance with 10 CFR 2. 790 of the NRC's "Rules and Practice," a copy of this letter, its enclosure, and your response. (if you choose to provide one) will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
T. Palmisano 3
- We will gladly discuss any questions you have concerning this inspection.
Sincerely, Original Signed by John A. Grobe John A Grobe, Director Division of Reactor Safety Docket No. 50-255 License No. DPR-20
Enclosure:
Inspection Report 50-255/9801 S(DRS) cc w/encl: R. Fenech, Senior Vice President, Nuclear Fossil and Hydro Operations N. Haskell, Director Licensing R. Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Department of Attorney General (Ml)
Emergency Management Division, Ml Department of State Police
CAC (E-Mail)
Project Mgr., NRR w/encl J. Caldwell, Riii w/encl
- C. Pederson, Riii w/encl SRI Palisades w/encl DRPw/encl TSSw/encl DRS (2) w/encl Rill PRR w/en_9.
PUBLIC~w/encl Docket File w/encl GREENS IEO (E-Mail)
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