ML18046A573

Response to NRC 810109 Third Set of Interrogatories Re Local Leak Test of Penetration 4.a,TP Neal Actions During Replacement & Testing of HEPA Filter in Penetration 4a. Certificate of Svc Encl

ML18046A573
Person / Time
Site:	Palisades
Issue date:	04/09/1981
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-CIV, NUDOCS 8104220614
Download: ML18046A573 (9)

Text

• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter of: ) ) CONSUMERS POWER COMPANY ) DOCKET NO. 50-255 (Civil Penalty) (Palisades Nuclear Power Facility) ) CONSUMERS POWER COMPANY'S RESPONSE TO THE NRC STAFF'S THIRD ROUND OF INTERROGATORIES Consumers Power Company hereby submits its res..: ponses to the "NRC Staff's Third Round of Interrogatories To Consumers Power Company", dated January 9, 1981. All persons identified in the answers to NRC: Staff Third Round of Interrogatories to Consumers Power Company, unless otherwise indicated, are employees of Consumers Power Company with the following address and telephone number: Palisades Nuclear Plant Covert, Michigan 49403 (616) 764-8913 Interrogatory No. 1. 1. Identify each time from March 20, 1978, to September 11, 1979, a local leak test of penetration 4.a was performed.

rBt *o 4 2 2 o (Q"' c, *(a) -* Identify the person or persons who performed

• the test and the date on which the test was performed.

.. ANSWER. (b) Ideritify the procedures used to conduct the test. (c) Identify the procedures used to authorize the test, to conduct the test, and to verify pletion of the test. (d) Describe the results of each test. (e) Provide a copy of each written procedure or document identified in response to (b) and (c) above. 1. (a) March 20., 1978 -Richard Stanton

• September 11, 1979 -Douglas Till (Mr. Till is no longer employed by Consumers Power Company. Consumers has been in£ormed that Mr. Till is presently in Brazil.) (b) March 20, 1978 test -Proc. No. R0-32 21, 22 and 23, Revision 8. Signed by R. Stanton. (Attachment

1) .September 11, 1979 -Proc. No. R0-32 pages 21, 22 and 23, Revision 9 -Signed . by D. Till. (Attachment

2) (c) See Attachments 1 and 2, and Proc. No. R0-32, pages 1 and 2, Revision 9. (Attachment

3) . (d) See Attachments 1 and 2. (e) See Attachments 1 and 2. Interrogatorry No. 2. 2. Identify each attachment to RAE 75-79 (Consumers' internal memorandum) which was not included in the copy of Document E appended to "NRC Staff's Request for Admissions by Consumers Power. Company", dated November 7, 1980. Provide a copy of each document ideritif ied in response to this interrogatory.

'.

• ANSWER. In lieu of responding directly to Interrogatory 2, we enclose herein as Attachment 4 RAE 75-79 with all of its

• attachments.

No. 3. Describe Thomas P. Neal's actions during the replacement and testing of the HEPA filter in penetration 4.a between April 4 and 7, 1978. Specifically identify each phase of the replacement and testing operations during which Mr. Neal was physically present at the location of the manual containment isolation valves or the HEPA filter bank and identify the place where he was present. ANSWER.* Mr. Neal has very little specific rec6llection of the actions he took relative to the replacement and testing of the HEPA filter in penetration 4.a. In general, he recalls that the tests. failed during the first attempt and the system had to be retested.

He also recalls being present for most of the testing process and assisting Mr. Leckie in carrying some of his testing equipment.

Interrogatory No. 4. Describe the manner in which the shift supervisor was notified of the completion of HEPA filter replacement and testing in penetration 4.a on or about April 6, 1978. (a) Identify the shift supervisor who was tified and the person who notified the shift *supervisor. (b) Describe the shift supervisor.'

s *actions upon notification.

e. ANSWER. Mr. Neal does not have. specific recollectiori of how the shift supervisor was inf orrned of the completion of HEPA filter replacement or testing penetration 4.a.

• How-ever, the Equipment Outage Report (Attachment E to Consumers Response To the Staff's First Round of Interrogatories) for tagging the manual isolation valves indicates that Mr. Enos Thompson, Palisades Plant Shift Supervisor, was notified of the completion of the tests by Mr. Neal. Mr. Thompson has no specific recollection of being so notified, or his actions upon being notified, but he acknowledges that his initials on the EOR indicate he did receive notification.

Interrogatory No. 5. Describe the manner in which the plant health physicist was notified of the completion of HEPA filter replacement and testing in penetration.4.a on or about April 6, 1978. ANSWER. (a) Identify the plant health physicist who was notified and the person who notified the plant health physicist. (b) Describe the plant health physicist's actions . upon notification.

Mr. Neal does not specifically recollect the manner in which the health physicist was *notified.

We have as yet been unable to contact Mr. Vern Schockley, the Plant health physicist peri6d in question.

Mr. Schockley is no longer employed by Consumers.

(,\ *

• Interrogatory No. 6. Provide a copy of the completed forms NCS FormNo. 1, NCS Form No. 2, and NCS Form No. 3that were completed in April 1978 as part of the HEPA filter testing conducted under.Consumers' procedure H.P. 6.27.

• NCS Form Nos. 1-3 are attached to procedure NCS-375, Rev. 1 (8/22/75), which is incorporated by reference in Consumers' procedure H.P. 6.27. ANSWER. NCS Form No. 2 and No. 3 are attached as Attachments 5, and 6 respectively.

These documents were provided by Mr. Leckie. NCS Form No. 1 is as yet unavailable.

Interrogatory No. 7. Provide a copy of each of the following documents, which Consumers has stated.were attached to Mr. *Youngdahl's letter of December 6, 1979, to Mr. Stello: (a) RWS 168-79 (b) MARU 63-79 (c) JLB 74-79 While Consumers has previously indicated that it provided of these documents to the Staff, the Staff is unable to determine whether it has complete copies of these documents.

Hence, the Staff .is asking that Consumers provide copies of these documents or make them available for _copying.

AN.SWER. RWS 168-79, MARU 63-79 and JLB 74-79 are attached as Attachments 7, 8 and 9 respectively.

Interrogatory 8. -Identify all procedures-which are attached to or incorporated by reference in Consumers' procedure H.P. 6.27. Provide a copy of all such procedures.

ANSWER. The references to H.P. 6.27 are identified.on the face of H.P. 6.27. They are:

• • .; .. *

• 1. Technical Specification Table 4.2.2, Item 11 -Attachment

10. 2. QA letter of review -4/4/75 -At:tachment

11. 3. Nuclear Containment Systems certificate of qualification

-Attachment

12. 4. Nuclear Containment Systems QA Manual, NLS-Ql, Rev. O. Attachment

13. 5. Procedure for Inplace Testing of HEPA Filters and Iodine Absorbers, NCS-375, Rev. 1, 8/22/75 -Attachment

14. Interrogatory No. 9. Upon completion of HEPA filter replacement and testing in penetration 4.a. on oi about April 6, 1978, did either the shift supervisor or the plant health physicist sign off on any procedures which are attached to or porated by reference in Consumers' procedure H.P. 6.27?

• (a) Identify each such procedure which was signed. (b) Identify each person who signed off on each such procedure

.. (c) Identify the date on which the person or persons signed off on the procedure. (d) Provide a copy of each procedure and any related documentation on which the person or persons signed off. No, the_ references do not provide for .signoffs.

The following persons prepared or contributed to the pre-paration of the foregoing responses:

• * *Answer 1-9 Alan P. Bielawski, Outside Counsel Answer 3, 4, 5 Thomas P. Neal, Senior Technical Analyst, Consumers Power Company, 212 West Michigan Avenue, Michigan 492-01 (517) 788-1603 DATED: April 9, 1981. ISHAM, LINCOLN & BEALE One First National Plaza Suite 4200 Chicago, Illinois

• 60603 (312) 558-7500 Respectfully submitted, :....7_

.:: . It *

• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter of: ) ) CONSUMERS POWER COMPANY . ) (Palisades Power Facility) ) DOCKET NO. 50-255 (Civil Penalty) CERTIFICATE OF SERVICE I, Alan P. Bielawski, one of the attorneys for Consumers Power Company, certify that copies of "Consumers Power Company's Response to NRC' s Third .Round of Interro-. gatories" have been served in the above-capti6ned matter on the following by depositing*

same in United States mail, postage prepaid, this 9th day of April, 1981: Honorable Ivan Smith Administrative Law Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James P. Murray, Esq. Director and Chief Counsel Rulemaking and Enforcement Division Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James Lieberman, Esq. U.S. Nuclear Regulatory Commission Office of Executive Legal Director .Washington, D.C. 20555 Stephen G. Burns, Esq. U.S. Nuclear*Regulatory Commission Office of Executive Legal Director Washington, D.C. 20555 ; ...

DATED! *

• Docketing and Service Section Off ice of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judd L. Bacon, Esq. Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 April 9, 1981.