ML20024E897

Responds to NRC 830720 Ltr Re Violations Noted in IE Insp Rept 50-255/83-16.Corrective Actions:Individuals Performed Major Grinding in Component Cooling Water Room W/O Fire Watch Counseled

ML20024E897
Person / Time
Site:	Palisades
Issue date:	08/19/1983
From:	Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20024E895	List: ML20024E897
References
NUDOCS 8309070183
Download: ML20024E897 (3)

Text

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Consumers Power Company oeneral offices: 1945 West Parnell Road, Jackson, MI 49201 e (517) 788 0550 August 19, 1983 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO IE INSPECTION REPORT 83-16 IE Inspection Report No 50-255/83-16 dated July 20, 1983 reported the results of a routine safety inspection conducted during June 1983. Addressed in the report were two (2) items of non-compliance to which responses are required.

The items of non-compliance and responses thereto are given below:

ITD: No 1:

" Technical Specification 6.8.1.f requires procedures be established and implemented covering site Fire Protection Program implementation. The licensee's Fire Protection Implementing Procedures, at Paragraph 5.5.3.b.

require the presence of an individual designated for fire watch when major j grinding is in progress.

l l Contrary to the above, the inspector observed a person performing major grinding in the component cooling water room on June 7, 1983, with no fire watch present."

RESPONSE TO ITEM No 1:

l Corrective Action Taken and Results Achieved:

The individuals involved in this incident were counselled regarding proper fire watch requirements.

Corrective Action to be Taken to Avoid Further Noncompliance:

! The Palisades Plant Fire Protection Implementing Procedures will be clarified with regard to fire watch requirements during all grinding operations.

8309070183 830901 PDR 0 ADOCK 05000255 PDR MUG 2 2 G83*

OC0883-0016A-NLO2

r Jamea G Kepplcr, Ad inictrctrr 2 Palisades Plant '

RESPONSE TO IEIR 83-16 -

August 19, 1983 -

Date When Full Compliance Will Be Achieved:

Full compliance has been achieved. However, the revision to the Fire Protec- ,

tion Implementing Procedures is presently in the process of being issued.-

ITEM No 2:

" Technical Specification 6.8.1.a requires procedures be established and implemented covering activities in Appendix A of Regulatory Guide 1.33 as endorsed by CFC-2A QAPD (Quality Assurance Program Description). CPC-2A endorses Appendix A of Regulatory Guide 1.33 without exception including Administrative Procedures, and specifically stipulates activities to be accomplished using procedures, including Administrative Control Frocedures.

(1) Administrative Procedure 3.03, ' Corrective Action,' requires, via Attach-ment 15, that a Deviation Report be initiated if Technical Specification test results exceed administrative limits.- 1 Contrary to the above, the administrative limit of Technical Specifica-tion Test MO-8 for delta T power was exceeded during testing'in April and Fby 1983, and no Deviation Report was initiated.

(2) Administrative Procedure 9.21, ' Technical Specifications Surveillance Procedure Development,' requires at ParaFraph 6.7 that these procedures be reviewed for continued applicability prior to exceeding a two-year interval.

Contrary to the above, Technical Specifications surveillance Proceaures MO-7A (review period expired May 21, 1983) and MO-3 (review period expired June 2, 1933) were issued and used in June 1983, without the required review having been performed in the preceding two-year interval."

RESPONSE TO ITEM No 2:

Corrective Action Taken and Results Achieved:

(1) A Deviation Report was initiated to address exceeding the administrative limit for delta T power during performance of M0-6 in April and May 1983.

(2) The subject procedures were in the process of undergoing a biennial review, when, due to oversight, they were issued for use. Subsequent to discovery by the NRC Inspector, the biennial revicw of the subject procedures was completed with no changes made to either procedure as a result of the two-year review.

OC0883-0016A-NLO2

s Jimca G Kepplcr Adminictrct:r- 3 Palisades Plant

, RESPONSE TO IEIR 83-16 August 19, 1983 Corrective Action Taken to Avoid Further Noncompliance:

(1) The Shift Supervisors and Shift Engineers have been instructed to initiate a Correctiite Action Document whenever the acceptance criteria of a Technical Specification Surveillance Test is exceeded, unless specifical-ly waived by the acceptance criteria specified in the procedure.

(2) The Plant Administrative Procedures will be revised to designate an individual (s) responsible for ensuring that a Technical Specification Surveillance Test is not issued for use prior to having been reviewed for continued applicability within the preceding two-year interval.

Date When Full Compliance Will Be Achieved:

(1) Full compliance has been achieved.

(2) Full compliance has been achieved. However, revisions to the appropriate Administrative Procedures are presently in the process of being issued.

Wll David J VandeWalle Nuclear Licensing Administrator

, CC Director, Office of Nuclear Reactor Regulation l Director, Office of Inspection and Enforcement l

NRC Resident Inspector - Palisades i

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l l

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OC0083-0016A-NLO2