ML20205H250

Responds to NRC Re Violations Noted in Insp Rept 50-255/85-17.Corrective Actions:Appropriate Documents Located,Improvements Implemented in Records Turnover Process from Const Dept to Plant & post-performance Review Provided

ML20205H250
Person / Time
Site:	Palisades
Issue date:	10/07/1985
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8511150080
Download: ML20205H250 (5)

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Consumers Power Company General offices: 1945 West Parnall Road, Jackson, MI 49201 * (517) 788-0550 October 7, 1985 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 INSPECTION REPORT 85-017 Three items of noncompliance were identified in Inspection Report 50-255/85-017 dated September 5, 1985. The following is our response to these items:

Noncompliance Item 1. (50-255/85-017-03):

10CFR50, Appendix B, Criterion XVII, as implemented by the Consumers Power Company Quality Assurance Program for Operational Nuclear Power Plants (CPC-2A), requires that quality assurance records be prepared, stored and retrieved as necessary to provide objective evidence that activities affecting quality were properly performed.

Contrary to the above, the following records providing objective evidence of satisfactory completion of Palisades Plant modifications could not be located:

a. Control Work Package No 138618-31, Revision 0, for Facility Change Package No FC-494-3.

b. Safety evaluation and Plant Review Committee review record for Control Work Package No 138618-31, Revision 0, for Facility Change Package No FC-494-3.

c. Completed Construction Work Package No FC-608.

8511150080 851007 PDR ADOCK 05000255 G PDR OCT 91985 I I 0C1085-0300-NLO4 u N/  ;

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JGKeppler, Administrator 2 Palisades Plant Response to IEIR 85-017 October 7, 1985 Discussion The item of noncompliance establishes an inability to provide objective evidence that activities affecting quality were properly performed during major modifications. As an example, the inability to produce certain specific documents was noted in the inspection. Following a review of this violation, certain clarifications were determined to be necessary.

The description of this violation provides a reference to Control Work Package 138618-31. A review of the documents and records associated with this work activity determined this to be an incorrect number. The correct item is assumed to be Control ark Package 15618-31.

As a result of a search for the identified documents, all records have been located. Therefore, the violation is considered incorrect as stated. Records providing objective evidence of the satisfactory completion of certain plant modifications were stored and retrieved as required by 10CFR50, Appendix B, Criterion XVII. However, we recognize that corrective actions should be provided to improve the ability to produce these documents in a more timely manner.

Significant improvements have been implemented in the records turnover process during major modifications. In addition, a review of the records retention inputs by the Plant will be performed to reduce the quantity of incomplete or duplicate documents in the records storage system. The retention of an excessive number of unnecessary construction documents could result in difficulties in the retrieval of records.

Corrective Actions Taken And Results Achieved All documents identified by the Violation have been located. Significant improvements have been implemented in the records turnover process from our construction department to the Plant. A post-performance review is provided for certain types of records. The records generated by the General Office, and in the field, are sorted, consolidated, and indexed prior to microfilming. If at all possible, records associated with a specific project are filmed together, to eliminate any dispersal to nonsequential film cartridges.

Corrective Action To Be Taken To Avoid Further Noncompliance A review of the records retention inputs by the Plant will be performed to reduce the quantity of incomplete or duplicate documents submitted to the records storage system Date When Full Compliance Will Be Achieved Full compliance will be achieved by July 15, 1986.

OC1085-0300-NLO4

JGKeppler, Administrator 3 Palisades Plant Response to IEIR 85-017 October 7, 1985 Noncompliance Item 2 (50-255/85-017-04):

10CFR50, Appendix B, Criterion II, as implemented by Consumers Power Company Quality Assurance Program for Operational Nuclear Power Plants (CPC-2A), requires that control be provided over activities affecting the quality of the identified structures, systems and components to an extent consistent with their importance to safety.

Contrary to the above, the design change and modification program was not properly controlled, in that the following documentation had not been completed to provide evidence that the specified work had been accomplished:

a. Nineteen of twenty-nine signoffs were not completed on process control sheet No 7545-29, Revision 0, for Facility Change Package No FC-494-3.

b. Ten of thirty-eight itens on the Project Punch List and the Contractors Exception List for Facility Change package No FC-494-3 were not completed as required by procedure No MT-11.

c. Three verification signatures were not completed on the work package for Facility package No FC-607.

Corrective Action Taken And Results Achieved For each deficiency identified by this violation, a review was performed to determine the status of the specified work. The work activities were found to have been properly completed as indicated by additional records or by physical inspection. These reviews have established that the work occurred as prescribed, although the documentation did not provide the proper administrative evidence of this status.

As a result of these types of deficiencies, corrective actions had been implemented to improve the administration of construction work activities.

Process Control Sheets failed to provide the appropriate administrative controls. Therefore, the use of Process Control Sheets was discontinued.

Project work activities are currently documented by Construction Work Packages. These packages consolidate the work activity documentation in a single record. A completion review is prescribed by the Construction Work Package, wherein the contractor and Quality Assurance provide a 4b post-performance review. This review will ensure the completion of all required work activities and appropriate documentation of the activities.

A procedure was developed to direct Project Punch List administration. The procedure describes Project Punch List development, distribution, filing, and individual item closure.

Corrective Action To Be Taken To Avoid Further Noncompliance All corrective actions are complete. No further action is required.

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JGKeppler, Administrator 4

Palisades Plant..

LResponse to;IEIR 85-017 October'7, 1985 Date When Full' Compliance Will Be Achieved Full compliance has been achieved.

Noncompliance Item 3 (50-255/85-017-05)

.10CFR50, Appendix B, Criterion XV, as implemented by Consumers Power Company' Quality Assurance Program;for Operational Nuclear Power Plants 1(CPC-2A), requires that nonconforming materials, parts and components be controlled to ensure proper identification, documentation and disposition.

Contrary to the above, 1) the actual disposition of Test Deficiency-Report No~5511-007 was different than that specified on the report, and 2) the disposition of Test Deficiency Report No 5511-12 was not appropriate, in

=that. final resolution of the deficiency was not provided for.

Discussion:

1me description of-this violation identifies two examples of improper control of nonconforming items. One example provides that the actual.

1 disposition of Test Deficiency Report 5511-007 was different than that.

specified on the report. The Inspection Report notes that the documented dispositionLdid not reflect the actual disposition, in that a lower amperage breaker was substituted as a replacement breaker. A review was perfcrmed of Test Deficiency Report 5511-007 and related documents. We conclude that no violation of requirements occurred in this example.

Test Deficiency Report 5511-007 was written to document problems associated with a breaker provided in location 52-2523. The-original breaker provided in this. location'was a 40 amp breaker. A malfunction of the original

'40 amp breaker was addressed by Test Deficiency Report 8721-021. A

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--replacement 40 amp breaker for location 52-2523 was obtained. The

replacement breaker failed trip testing. ~Therefore, an engineering evaluation was performed and documented under Test Deficiency Report 8721-021 to replace the original 40 amp breaker with a spare 30 amp breaker.

Subsequently, the replacement 30 amp breaker also failed trip testing. The malfunction and replacement-of the 30 amp breaker was identified by Test Deficiency Report 5511-007,. initiated on September 26, 1983. Therefore,

!. -Test Deficiency Report 5511-007 provided resolution of a malfunction of a 31 0 amp breaker. The replacement of the original 40 amp breaker with a

-30 amp breaker occurred under Test Deficiency Report 8721-021. The

resolution of the nonconforming items occurred properly, and no violation of requirements resulted.

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JGKeppler, Administrator- 5 Palisades Plant Response to IEIR 85-017 October.7, 1985 Corrective Action Taken And Results Achieved The current program for Test. Deficiency Report administration provides several improvements to the methods utilized during the-initiation of Test Deficiency Report 5511-12. The initial and final conditions are required documentation. Allowance is provided to specify corrective actions to prevent.a recurrence of a deficiency. A Quality Assurance review and concurrence is provided for a disposition concerning a repair or authorization to allow a use without repair.

Corrective Action To Be Taken To Avoid Further Noncompliance All corrective actions are complete. No further action is required.

Date When Full Compliance Will Be' Achieved Full compliance has been achieved.

f Kenneth W Berry Director, Nuclear _ Licensing CC. Director, Office of Nuclear Reactor-Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades OC1085-0300-NLO4

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Il0V 6 1985 Docket No. 50-255 e Consumers Power Company //

ATTN: Mr. R. B. DeWitt D Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:

Thank you for your letter dated October 7,1985, relative to the three violations which we brought to your attention in our letter dated September 5, 1985. Your written response to the items was discussed between Messrs. R. Fenech and D. Fitzgibbons of your staff, and Messrs. F. Hawkins and A. Walker of my staff on November 4, 1985. As a result, we understand that you have agreed to provide additional information concerning the actions you have taken to correct Violations No. 255/85017-03 (Criterion XVII) and No. 255/85017-04 (Criterion II).

With regard to Violation No. 255/85017-05, we have reviewed the additional information which your staff provided both in the written response and during our conversation. In light of that infonnation, we agree that the violation, presently written against Appendix B, Criterion XV, would more appropriately be classified under Criterion II.

Accordingly, we will delete Violation No. 255/85017-05 from our records and include it as part of Violation No. 255/85017-04. Your forthcoming submittal should address it as a part of your resolution of Violation No. 255/85017-04.

We appreciate your cooperation in these matters. Please contact Mr. Frank Hawkins (312-790-5555) with any questions you may have.

Sincerely, '

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Y L . A. Rey e s , Chit f l C i et i titut b e:,0 See Attacted Distribution p\ + m 4

I Consumers Power Company 2 NOV 6 1985 Distribution Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Comission Nuclear Facilities and Environmental Monitoring Section I 11 b p. Rlll Walkwr/mab Hawkir.s Hehl Re s 11/06/85 6/iI gl[6,