ML20205M169
| ML20205M169 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/27/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8604150114 | |
| Download: ML20205M169 (3) | |
Text
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Company Nxlear Ucensing General Offices: 1945 West Parnali Road, Jackson. MI 49201 e (517) 788-1636 March 27, 1986 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 86-006 IE Inspection Report 86-006 dated February 26, 1986 transmitted one item of violation requiring a response. The item of violation and Consumers Power Company's response is contained herein.
Violation 50-255/86-006-01 10 CFR Part 50, Appendix B, Criterion XI, as implemented by Consumers Power Company Quality Assurance Program Requirement 11.0, requires that testing is performed in accordance with established programs to demonstrate that struc-tures, systems and components will perform satisfactorily in service.
Contrary to the above, sufficient testing was not conducted to demonstrate that auxiliary feedwater pump P8C will perform satisfactorily in service; 1.
A 48-hour endurance run and I hour restart after cooldown was not conducted.
2.
A flow test to determine the adequacy of the Net Positive Suction Head (NPSH) when utilizing the alternate suction supply was not conducted.
Response
Corrective Actions Taken and Results Achieved (1) Failure to conduct the 48-hour endurance test was primarily the result of an oversight on the part of the cognizant plant project engineer. The error was not detected, however, due to erroneous verbal confirmation from h50h[55 OC0386-0057-NLO2 O
PDR APR 21986 i L
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James G Keppler, Administrator 2
Palisades Plant Response to IEIR 86-006 March 27, 1986 the engineer's supervisor that the commitment had been satisfied, which in turn was utilized to close this item from our in-house commitment tracking system.
While both the oversight on the part of the cognizant engineer and the communication error by his supervisor are considered isolated incidents and not further preventable through corrective actions, improvements have been implemented regarding the tracking of such commitments.
Increased involvement in monitoring the timely completion of commitments by the on-site licensing group has resulted in a more thorough interface with individuals responsible for completing commitments than was previously achieved when commitment monitoring was primarily an off-site responsi-bility.
The involved engineer is no longer employed by Consumers Powar Company; his then supervisor is no longer associated with project engineering.
This and the two year time period since the occurrence negate the appli-cability of personnel counseling.
An appropriate endurance test was successfully completed on February 7, 1986.
4 (2) While a flow test to determine the adequacy of the Net Positive Suction Head (NPSH) of the alternate suction supply (service water) was not conducted, this requirement was at the time recognized; but in light of the undesirability of tainting the Auxiliary Feedwater System with service water, this requirement was assumed to have been adequately satisfied through normal project activities including design review, use of installa-tion procedures and in-process quality inspections of the installation.
Since it remains our position that this flow test is not strictly required provided sufficient controls in lieu of the flow test are implemented and documented, we believe that the root cause of this violation was our subsequent inability to retrieve adequate records to justify our decision and confirm the completion of such alternate measures. Consequently, the corrective action descriptions which were transmitted on January 30, 1986 in response to IE Inspection Report 85-017, (Violations 50-255/85-017-03 and 04) addressing the retrievability of modification records apply generically to this violation also.
.An appropriate flow test of-the alternate suctior supply piping was successfully completed on January 31, 1986.
Corrective Action To Be Taken To Avoid Further Violations None OC0386-0057-NLO2
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James G Keppler, Administrator 3
Palisades Plant l
Response to IEIR 86-006 March 27, 1986 l
Date When Full Compliance Will Be Achieved I
i Full compliance has been achieved.
j YO l
Kenne.ch W Berry Di.ector, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades
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l OC0386-0057-NLO2
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