ML20044D805
| ML20044D805 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/14/1993 |
| From: | Donnelly P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9305200319 | |
| Download: ML20044D805 (4) | |
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i Consumers l
POWEf r.trien u oono.i,y Plant Manager l
Pewsmass i
asumsaws eneGatEss Bq Rock Powit #4ucker Piart.102C9 US-31 North. Chartevom. MI 49720 l
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May 14, 1993 l
i Nuclear Regulatory Commission I
Document Control Desk Washington, DC 20555 l
t DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
REPLY TO A NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-155/93-003) i Enclosed is the reply to a Notice of Violation described in the Nuclear Regulatory Commission Inspection Report 50-155/93-003 dated April 23,'1993.
i The cover letter to the Inspection Report discussed three (3) additional items i
l involving LER's and requested follow-up.
In response, our letter dated l
l January 27, 1993 discusses the issue of commitment dates in LER's and our corrective actions. The recent guidance in letter from NRC to CPCo dated April 26, 1993 now requires us to re-establish the practice of using dates in LER's. With this and our corrective actions taken as described in the violation response, future problems should be avoided.
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l Patrick M Donnelly l
P1 ant Manager i
r CC: Administrator, Region III, USNRC l
NRC Resident Inspector - Big Rock Point ATTACHMENT
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ATTACHMENT CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET 50-155 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT 93003 May 14, 1992 f
2 Pages
1 REPLY TO NOTICE OF VIOLATION - NRC INSPECTION REPORT 93003 I
V10LATION 93003 10 CFR 2.201(a) requires licensees to respond in writing within twenty days or other specified time of the date of a Notice of Violation, describing the corrective actions that have been taken, corrective actions to be taken, and the date when full compliance will be achieved.
Contrary to the above, the licensee failed to respond in writing to the Commission within the time prescribed to address Violation 50-155/92017-03 (DPR).
In addition, the licensee made no request to extend the response time until the response date was exceeded by over six weeks.
DISCUSSION After discussions with the Senior Resident Inspector, we believe that the basis for this violation is in failure to notify the NRC that a commitment date needed to be re-negotiated versus 10 CFR 2.201(a) described above. On August 20, 1992, Consumers Power Company submitted a response to a Notice of Violation (NRC Inspection Report 50-155/92017). That response was made within the required days allowed and consisted of responses to three separate violations (92-017-01, 02 and 03). On November 24, 1992, Revision 1 to the Original Response to Violation was submitted to request an extension to several commitment due dates because the Operations Department had expanded the scope of the corrective action. On February 12, 1993, Big Rock Staff recognized that a due date (December 31,1992) just previously re-negotiated in the Revision 1 Response had lapsed, and that the NRC had not been notified.
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REASON FOR THE VIOLATION l
i The violation occurred as a result of a mis-communication between the evaluator of the corrective action and his supervisor.
The evaluator concluded that the assigned corrective action as proposed in the original Reply to a Notice of Violation was not appropriate, and had then proposed a different course of action. This evaluation was completed by December 16, 1992, and left with the Supervisor to concur before the due date, which was overlooked.
1 The reason that the NRC was not notified was an oversight on the part of the l
Facility. We understand that commitments made to the NRC are of prime l
importance.
Even though the safety significance of the corrective action was i
minimal, the Facility is disappointed that this oversight occurred.
l CORRECTIVE ACTION TAKEN AND RESULTS ACH'EVED l
On February 12, 1993, Big Rock Point Staff recognized (albeit about six weeks
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1 ate) that a due date (December 31,1992) just previously re-negotiated in the Revision 1 Response to a Notice of Violation had lapsed, and that the NRC had not been notified.
The Senior NRC Resident Inspector was immediately informed, and a letter discussing the updated LER 92-008 (source of the violation), the missed commitment date and a request for an extension of that date to June 1, 1993, was submitted February 17, 1993.
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REP 1Y TO NOTICE OF VIOLATION - NRC INSPECTION REPORT 93003 (Continued)
ACTIONS TAKEN TO PREVENT RECURRENCE The Nuclear Operations Department (NOD) under the auspices of the Vice President of Nuclear Operations, is sponsoring an Action Plan Strategy that for both Big Rock Point and Palisades Plant, will review the process by which commitments are made and how they are tracked until completion and closecut.
The recommendations that are generated by this review will be implemented at Big Rock Point.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The facility is currently in full compliance.
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