ML20101S698
| ML20101S698 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/17/1984 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20101S693 | List: |
| References | |
| NUDOCS 8502050596 | |
| Download: ML20101S698 (4) | |
Text
,
i r
b Consumersi PUiver '
Company
. General offices: 1946 West Parnali Road. Jackson. MI 49201. (5171 788-0550 December 17, 1984 James G Keppler, Administrator -
Region T.II US: Mucicar Regulatory Commission
,799 Roosevelt Road Glen Ellyn, IL 60137 DdCKET 5 255 - LICENSE DPR -PALISADES. PLANT - RESPONSE TO IE INSPECTION REPORT 84-20 Two items of noncompliance were identified'in IE Inspection Report 50-255/84-20 dated November 14, 1984. Our response to these items of noncompliance follows:
.s Noncompliance-1 (50-255/84-20-04)
. Palisades Technical Specification 4.3, " Systems Surveillance", states
>M
'that the inservice testing of pumps and valves be performed in accordance with Subsections IWP and IW of Section XI of the ASME Boiler 'and Pressure Vessel Code as required by 10CFR50.55a(g). Subsection IW-3300
.of Section XI of the Code states, " Valves with remote position indicators
+
,N shall be observed at least once every 2 years to verify that valve 9
operation is accurately indicated". Subsection IW of the Code also defines required testing as that which demonstrates "that the moving parts of a valve function satisfactprily"!and verifies valve " operational readiness".
' Contrary to the above, Thelicenseeidiledtoperformrequiredsurveillancetestinginthat s.
accessible valve exercise testing was not observed locally to assure that control' room indicating lights used for valve stroke timing were an accurate representation of valve operation.
b.
Limiting values for valve stroke times were selected that would not meet the intent of the Code in assuring that a valve is functioning satisfactorily or in requiring corrective action to assure valve operational. readiness.
8502050596 850131 PDR ADOCK 05000255 DEC 21199 O
'OC1284-0091A-NLO4 j
u-u J
~..
James G Keppler', Administrator 2
~
Palisades Plant
.IEIR 84 December 17,'1984 Response to Item 1.a:
Corrective Actions Taken and Results Achieved
~
Surveillance procedures which are affected by the ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWV-3300 have been
-identified.
-Corrective Action to be Taken to Avoid Further Noncompliance
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' Applicable surveillance procedures will be modified to require a visual.
' observation of accessible valves with remote position indicators at least onceeverytwoyears[toverifythatremotevalveindicatorsaccurately
' reflect valve operation.
In. addition, an evaluation of the most recent
. performance of each applicable procedure will be performed to determine if: additional valve stroke tests are needed. Any additional testing required will-be performed at the next regularly scheduled performance of L
,the1 applicable surveillance tests.
'Date When~ Full Compliance Will be Abhieved
.The applicable' surveillance precedures will be revised by June 30, 1985.
Full compliance will-be achieved following performance of any additional testing identified by the evaluation of prior stroke tests.
Response to Item 1.b:
[ Corrective Action Taken and Results Achieved' e
^
[The: limiting value for valve stroke time is an absolute value-that
- indicates a component or_ system cannot be_ considered capable of meeting 7
an-intended' safety function. Consequently,5the' limiting value of valve stroke times for power operated valves-is based on the required ~ system response times. These values are the " limiting value1of full. stroke-time",las stated'in. Subsection IWV-3413.
-In' addition to the' limiting values, administrative controls are provided that-identify.any.significant degradation in valve stroke time. These controls ensure'that corrective action is taken, when necessary, to.
maintainfoptimal valve performance.-
Limiting valuesifor valve stroke times'are.not to be used to indicate-
' degraded valve performance.
Changing stroke time values could create a
. potential =for many' cases of." inoperable" valves,-even though the
.capabilityfto perform a' required safety function-is'available. By Jutilizing administrative methods ~that identify' increased stroke times, corrective action is taken before a limit is exceeded and the added
~
benefit of preventing unnecessary. declarations of inoperable equipment is
.provided.
OC1284-0091A-NLO4)
James G Keppler, Administrator 3
Palisades Plant IEIR 84-20 December 17, 1984 Corrective Action to be Taken to Avoid Further Noncompliance No additional corrective action is required.
Date When Full Compliance Will be Achieved Full compliance has been achieved.
Noncompliance 2 (50-255/84-20-03):
. Criterion XII of 10CFR50, Appendix B, as implemented by Consumers Power Company " Quality Assurance Program Description for Operational Nuclear Power Plants", Section 12, requires calibrated equipment to be used in
" activities affecting quality".
Contrary to the above, inservice testing procedures MO-24, S0-9, and QO-6 prescribe the use of noncalibrated stopwatches for surveillance testing.
Other surveillance test procedures did not require use of calibrated
+
stopwatches.
Corrective Action Taken and Results Achieved Surveillance procedures that specify a time period as an acceptance criterion have been identified.
Corrective Action to be Taken to Avoid Further Noncompliance The applicable surveillance procedures will be modified to specify that a calibrated stopwatch is required. In addition, an evaluation of the most recent performance of each applicable procedure will be performed to-determine if the use of a non-calibrated stopwatch invalidated the results.
Date When Full Compliance Will be Achieved Full compliance will be achieved by February 1, 1985.
The Palisades Plant organization was recently changed to include certain capabilities that were.previously performed by an offsite support group. The additionlof an Inservice ~ Inspection staff to the onsite organization will provide more comprehensive control of surveillance practices, particularly
'OC1284-0091A-NLO4 ks
v fg James G Keppler, Administrator 4
Palisades Plant IEIR 84-20 December 17, 1984 with respect to ASME code requirements. This change in organization is considered an action that is applicable to each of the above items of non-compliance and will be an aid to avoiding further noncompliance.
m Thomas C Bordine
-Staff Licensing Engineer CC Administrator, Region III, USNRC
. Director, Office of Nuclear Reactor Regulation NRC Resident Inspector - Palisades OC1284-0091A-NLO4 u.
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