ML18054A973

Responds to NRC 890811 Ltr Re Violations Noted in Insp Rept 50-255/89-18.Corrective Actions:Informational Statements Placed in Plant Daily Status Sheet & Weekly Plant Bulletin & All Shift Supervisors Counseled on Existing Requirements

ML18054A973
Person / Time
Site:	Palisades
Issue date:	09/11/1989
From:	BERRY K W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8909180163
Download: ML18054A973 (3)

See also: IR 05000255/1989018

Text

• * consumers

Power POWERINli

M.ICHlliAN"S

PIUlliRESS

General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 September

11, 1989 Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES

PLANT -RESPONSE TO INSPECTION

REPORT 255/89018

NOTICE OF VIOLATION

Kenneth W Berry Director Nuclear LJcensing

Nuclear Regulatory

Commission

Inspection

Report 255/89018, dated August 11, 1989 identified

an item of violation

with items A and B regarding

10 CFR 50 Appendix B, Criterion

III Design Control. Item B to the violation

required a response.

The violation

and Consumers

Power Company's

response is as follows: Notice Of Violation

(255/89018-02A

& B) 10CFR50 Appendix B, Criterion

III, Design Control, requires establishment

of measures to assure that the applicable

regulatory

requirements

and the design basis of the Plant are maintained.

The licensee's

QA Program at Article 3.2 of CPC-2A Article 3.2 outlines controls for design changes. Administrative

Procedure (AP) 9.31, "Temporary

Modification

Control", implements

controls for design changes which are of short duration and references

AP 4.03, "Equipment

Control" as an example of a temporary

modification

where a temporary

opening needs to be controlled

to maintain the design basis for the system. Contrary to the 'above: A. During the period of June 21 through August 22, 1988, the Control Room ventilation

boundary was breached during maintenance

by the removal of several electrical

penetration

seals without initiation

of a Temporary

Modification

as required for Equipment

Control. This resulted in the failure of the ventilation

system's ability to maintain a positive pressure during a surveillance

test. The ventilation

system is described

in FSAR Section 9.8 as being designed to control the flow of airborne radioactivity

during an accident so as to minimize the impact on operating

personnel.

This opening of the penetrations

constituted

an unreviewed

design change * B. On June 14 the licensee blocked open the "doghouse" entrance flood door (to the East Safeguards

Room from the 590 foot elevation)

to facilitate

installation

of a bushing/retainer

ring to MV-3234 per WO 24903179 and did not implement

a Temporary

Modification

as required for Equipment

Control. OC0989-0187-NL04

8909180163

890911 PDR ADOCK 05000255 Q PDC

Nuclear Regulatory

Commission

Palisades

Plant Response to Inspection

Report 255/89018

September

11, 1989 The provision

of flood doors to protect safety-related

equipment

is described

in FSAR

5.4. Blocking the flood door open constituted

unreviewed

design change. This is a Severity Level IV violation.

Reason For Violation

2 B. On June 15, 1989 Plant Maintenance

personnel

opened the water-tight "doghouse" hatch from the 590 foot elevation

of the Component

Cooling Room to the East Safeguards

Room in. order to facilitate

passing welding cables required for completion

of an

work activity.

The work activity, WO 24903179, involved the removal of and replacement

of thrust rings, a yoke bushing and a new collar for the safety injection

tank drain line isolation

valve MV-3234A.

Prior to opening the water-tight

hatch, Maintenance

personnel

contacted

and obtained permission

from the Control Room to allow opening of the door. While personnel

had been posted as a door watch with instructions

to disconnect

the cables if directed by the Control Room, a Temporary

Modification (TM) had not been processed

as required by AP 4.03. The Shift Supervisor

had the work activity secured upon identification

that a TM had not been processed.

AP 4.03 states that, "in general, the removal of floor plugs or blocking open hatches and flood doors shall be approved by the Shift Supervisor.

In addition, the use of a Temporary

Modification

or associated

controls as specified

in Administrative

Procedure

9.31, 'Temporary

Modification

Control' shall be used whenever the primary coolant system is greater than 325 degrees F ... ". AP 9.31 is designed to control TMs in a manner that ensures awareness

of Operations

personnel, conformance

with design intent and operability

requirements

and preserves

Plant and personnel

safety. This procedure

provides requirements

for controlling

and documenting

TMs for all safety-related

and nonsafety-related

systems. TMs are Plant modifications

which are intended to be minor in scope, of short duration (typically

less than 90 days) and be few in number such that updating drawings and other documents

is not warranted, The failure to perform a TM of inplace associated

controls per AP 9.31, as required by AP 4.03, has been attributed

to inadequate

knowledge

and review of controlling

Plant procedures

during both the planning and implementation

phase of the work activity.

Corrective

Actions Taken And Results Achieved In order to heighten Plant personnel

awareness

of existing procedural ments for water-tight

door, plug* and hatch control, informational

statements*

were placed in the Plant Daily Status Sheet and the Weekly Plant Bulletin.

These documents

are available

to all Plant personnel

and receive extensive

distribution.

A memorandum

detailing

procedural

requirements

was issued to all licensed operators

and additionally, all Shift Supervisors

and Shift Engineers

were counselled

on existing requirements.

OC0989-0187-NL04

..

• * * *Nuclear Regulat_ory

Commission

Palisades

Plant Response to Inspection

Report 255/89018

September

11, 1989 Corrective

Actions To Be Taken To Avoid Further Non-Compliance

3 Procedures

governing

the control of water-tight

doors and hatches and the compensatory

measures which need to be taken when they are opened are being revised. These revisions

will include placing control requirements

existing in AP 4.03 and AP 9.31 into AP 4.02, "Control of Equipment

Status". This procedure

defines requirements

and operator responsibilities

for identifying, .maintaining

and verifying

proper status of Plant systems and components.

In order. to ensure the design intent of water-tight

doors, floor plugs and hatches currently

requiring

a TM be performed

is maintained, an encompassing

10CFR50.59

safety evaluation

will be required by the procedure.

By placing required controls into one procedure

and by performing

a single safety evaluation, more consistent

application

and quality of controls will result. Additionally, AP 5.01, "Processing

Work Requests/Work

Orders" will be revised to highlight

the need for compensatory

measures during the work planning process. Specific training on these changes will be provided t_o Plant Maintenance, Operations

and Radiological

Decontamination

personnel.

Additionally, this issue will be presented

to the Training Review and Tracking Committee (TRTC) for evaluation

and potential

inclusion

into Plant-wide

training.

Date When Full Compliance

Will Be Achieved The revision to AP 4.02 will be inplace by October 1, 1989 with AP 5.01 revised by October 15, 1989. The work group specific training will be completed

by November 15, 1989. The TRTC will evaluate this issue by October 26, 1989.-Kenneth W Berry Director, Nuclear Licensing

CC Administrator, Region III, USNRC NRC Resident Inspector

-Palisades

OC0989-0187-NL04