ML19323C462
| ML19323C462 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/10/1980 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8005150562 | |
| Download: ML19323C462 (3) | |
Text
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g April 10, 1980 Mr James G Keppler Office of Inspection and Enforce =ent Region III US Nuclear Regulatory Cc==ission 799 Roosevelt Road Glen Ellyn, IL 60137 LOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPCEE TO NOVIE ER 9, 1979, ORDER MODIFYING LICENSE On November 9, 1979, Consu=ers Power Cc=pany received a letter frc= the Direc-ter, Office of Inspection and Enforce =ent of the Nuclear Regulatory Cc==ission that contained a Notice of Violation, a Proposed I= position of Civil Penalties and an Order Modifying License for the Palisades Plant.
The license modificatien requires that:
"A.
Prior to startup following the present refueling, the licensee shall conduct a ec=prehensive review of all procedures and check lists to assure that:
(1) all valves and other controls for engineered safety features have been identified in such procedures and check lists; (2) such procedures and check lists require that all such valves and other controls are in their proper position prior to startup after any cold shutdevn; and (3) such procedures and check lists require that after testing, =aintenance or other activities which involve manipulating such valves and other controls, the valves and other controls have been returned to their prcper position for operation.
3.
Report to the Director of the NRC's Fegien III offi:e the results of at least =cnthly inspecticns during operation of all accessible valves and cther centrcls for engineered safety syste=s for ec=pliance with the t'-4-4 g Ccndition for Cperation (LCC) require =ents of the Technical Specification.
..k 2
Response to Nove=ter.9, 1979 Order Modifying License C.
Prior to startup following the present refueling, the licensee shall explain to the Director, NRC Office of Inspection and Enforce =ent, in a meeting in Bethesda, Maryland, how the above require =ents shall be i=plement-ed."
In response to this order, Consu=ers Power Cc=pany initiated a controlled review to upgrade plant drawings, check lists, and procedures associated with Engineered Safeguards Syste=s at the Palisades Plant.
I=portant steps in this process are as follows:
Screening - Criteria were developed to establish a =ethod for determining which plant check lists and procedures required review. Using these cri-teria, controlled lists were developed.
Check List Review - Check lists selected in the screening step were reviewed to ensure that they all included Engineered Safeguard Syste=s equipment. A physical valkdown of this equip =ent was con-ducted by personnel trained in nuclear plant operation. A review procedure was developed to ensure consistent review, The check lists were then ec= pared with installed equip =er,
and plant drawings. A second review of the check lists vta performed by a plant SRO. Proposed changes were reviewed by senior plant staff and processed by the normal Plant Review Cen=ittee process.
Plant Drawings - As a result of walking down the selected systems to review the check lists, several additions to the piping and instru=ent drawings (P&ID's) were proposed.
Independent Cc=pany personnel performed a second syste valk down to verify the accuracy of the selected drawings and proposed changes. Resultant changes to plant drawings are being processed in the normal manner.
Un-til the controlled pisnt drawings are formally revised, copies of the =arked up (red-lined) drawings vill be available to oper-ators (and other plant personnel).
Precedures - Procedures selected in the screening step were reviewed for proper ad=inistrative controls. The review vas carried out with the use of a check list. Proposed changes are being reviewed by the plant staff and processed thror.fh the Plant Review Com=ittee. Additionally, oper-ating procedures receive a second technical review by Palisades Plant Senior Reactor Operators.
The majority of the foregoing reviews and revisions are co=plete, and have been reviewed by NRC ILE Region I!! inspectors.
Prior to plant startup, all revisions resulting fro = this review activity vill be co=pleted en check lists and operating procedures. Revisions to plant piping and instrument drawings have been initiated with red-lined copies available on site.
Other selected procedures performed frequently, such as daily or weekly Technical Specification Surveillance Tests, will be revised prior to startup.
Infrequently used procedures will be revised prior to their next use.
.k ~
3 Response to November 9, 1979 Order Modifying License In accordance with Part 3 of the order, a draft procedure has been developed for monthly review of compliance with limiting conditions for operation. The proced-ure was reviewed by NRC Region III Inspectors at a site meeting conducted on Febru-ary 1, 1980. The procedure vill be reviewed and approved prior to use.
In accordance with Part C of the order, Consumers Power Company representatives net with Mr Victor Stello and other NRC staff members on November 30, 1979, to ex-plain how the requirements of the order vould be implemented.
In su=nsry, Consuners Power Company believes it vill have satisfied the require-ments of the November 9,1979, license modification when the required check list and procedure revisions have been completed. The Company plans to restart the Palisades Plant at that time, and presently estimates that the plant will be ready for startup on or about May 1, 1980.
Russell B DeWitt (Signed)
Russell 3 DeWitt Vice President Nuclear Operations CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Inforcement L