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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
[Table view] |
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Consumers Energy~
- A CMS Energy Company Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert. Ml 49043 Tel. 616 764 2296 Fax: 616 764 2425 Tllomn J. Palmluao Site Vice President July 23, 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk
- Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT REPLY TO NOTICE OF VIOLATION FOR THREE VIOLATIONS REPORTED IN INSPECTION REPORT NO. 50.:.255/97005 NRC Inspection Report No. 50-255/97005 contains three Notice of Violations (NOV).
The first NOV, designated No. 97005-01, concerns a Code violation resulting from unauthorized repairs to the main steam isolation valve stuffing box plugs. Specifically, extensive material was removed from existing pipe plugs in the valves without verifying that the required minimum wall thickness, in accordance with USAS 831.1.0, was maintained.
The second NOV, designated No. 97005-02, concerns the failure to properly submit a 10 CFR 50.73 Licensee Event Report (LER) within the required time frame.
Specifically, the LER was submitted on March 21, 1997, 70 days after the January 10,
<~~)v \\.
1997, discovery date. The required submittal period is 30 days.
The third- NOV, designated No. 97005-03, concerns three examples of a failure to follow * ~~
procedures associated with the repair of pipe plugs for the main steam isolation valves. ,\\ **
9707300038 970723 PDR ADOCK 05000255 G PDR Illllll
- 111111111111111111111111111111111 I I 4 I I A. *
- 2 The Consumers Energy Company response to the violations is included in the attachments. Attachment 1 contains the reply to NOV 97005-01, "Repair Not Performed in Accordance With Original Construction Code". Attachment 2 contains the reply to NOV 97005-02, "Failure to Submit Licensee Event Report Within 30 Days of Discovery". Attachment 3 contains the reply to NOV 97005-03, "Failure to Follow Procedures".
Consumers Energy Company agrees with all of the violations as written.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
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Thomas J. Palmisano Site Vice President CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector-: Palisades 3 Attachments
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ATTACHMENT 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION FOR THREE VIOLATIONS REPORTED IN INSPECTION REPORT NO. 50-255/97005 REPAIR NOT PERFORMED IN ACCORDANCE WITH ORIGINAL CONSTRUCTION CODE
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3 Pages
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REPLY TO NOTICE OF VIOLATION 97005-01 REPAIR NOT PERFORMED IN ACCORDANCE WITH ORIGINAL CONSTRUCTION CODE NRC NOTICE OF VIOLATION During an NRG inspection conducted on March 1 through April 11, 1997, violations of NRG requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions," NUREG-1600, the violations are (sic) listed below:
- 1. 10 CFR 50.55a, "Codes and Standards," Paragraph (g), "lnservice Inspection Requirements," Paragraph (4), states in part that components classified as*
ASME Code Class 1, 2, and 3, must meet the requirements, except for design, set forth in Section XI of the ASME Boiler and Pressure Vessel Code.
ASME Boiler and Pressure Vessel Code,Section XI, Paragraph IWA-4210, "Repair Procedures, Rules and Requirements," states in part that repairs shall be performed in accordance with the original Construction Code of the component.
The original Code of Construction for valves CV-0501 and CV-0510 was USA Standard (USAS) B31. 1 (sic), "Power Piping."
Contrary to the above, repairs made to valves CV-0501 and CV-0510, on November 17, 1996, using Work Orders WO 24512907 and'WO 24610966, respectively, were not performed in accordance with the original Code of Construction, USAS B31.1 (sic), in that extensive material was removed from existing pipe plugs in the valves, without verifying that the Code required minimum wall thickness was met.
This is a Severity Level IV violation (Supplement I).
CONSUMERS ENERGY COMPANY RESPONSE Consumers Energy Company agrees with this violation as written.
Backgro_~n~ __
Licensee Event Report 97-005, submitted on March 21, 1997, provides additional background information for this Notice of Violation and is incorporated herein by reference .
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 97005-01 REPAIR NOT PERFORMED IN ACCORDANCE WITH ORIGINAL CONSTRUCTION CODE Reasons for Violation During planning for these repairs, Work Order specifications were issued which would have assured code compliance if properly implemented. A failure to implement the
- specified requirements caused the violation. The failure to properly implement the repair resulted from a failure to follow procedures, a lack of a questioning attitude, and a lack of single point accountability for the job.
Corrective Action Taken and Results Achieved
- 1. Both leaking pipe plugs (one plug per valve) were permanently repaired by installing new forged steel one inch pipe plugs which met the code requirements.
- 2. The Operations Manager and the Maintenance Manager spoke to the repair workers and technicians at a stand down meeting regarding expectations for high levels of performance. The Lead Supervisors presented the lessons learned from the MSIV work. The presentations focused on procedural adherence, roles and responsibilities, work scope control, communications, use of self-checking and conservative decision making.
The Maintenance Manager sent a memo to all Maintenance and Planning Department supervisory personnel which described the effect that pre-job brief communication failures had on the work that led to the MSIV steam leaks. The memo focused on the importance of multi-discipline briefings in preparing for effective crew briefings.
- 3. The proper use of sketches within the Weld Inspection Checklist Process has been clarifiecf illthe Administrative Procedures .
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 97005-01 REPAIR NOT PERFORMED IN ACCORDANCE WITH ORIGINAL CONSTRUCTION CODE Corrective Actions Remaining to Avoid Further Violations A pre-job brief workshop will be developed and implemented to establish and communicate pre-job brief expectations and to improve repair worker participation. Included within this workshop will be:
- 1. The identification of multi-discipline tasks in the 13-Week Schedule Process.
- 2. The assignment of a single point of contact.
- 3. The improvement of readiness reviews and pre-job briefs.
The planned completion date is December 31, 1997.
Date Full Compliance Will Be Achieved Full compliance has been achieved with the proper repair to the pipe plugs on CV-0501
' .
ATTACHMENT 2 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION FOR THREE VIOLATIONS REPORTED IN
- INSPECTION REPORT NO. 50-255/97005 FAILURE TO SUBMIT LICENSEE EVENT REPORT WITHIN 30 DAYS OF DISCOVERY 3 Pages
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ATTACHMENT 2
-* REPLY TO NOTICE OF VIOLATION 97005-02 FAILURE TO SUBMIT LICENSEE EVENT REPORT NRC NOTICE OF VIOLATION WITHIN 30 DAYS OF DISCOVERY During an NRG inspection conducted on March 1 through April 11, 1997, violations of NRG requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions," NUREG-1600, the violations are (sic) listed below:
- 2. 1O CFR 50. 73, Licensee Event Report, states in part that the holders of an operating license for a nuclear power plant (licensee) shall submit a Licensee Event Report (LER) for any of the type described in this paragraph within 30 days after the discovery of the event. The licensee shall report any event or condition that resulted in the condition of the nuclear power plant, including its principal safety barriers, being degraded, or that resulted in the nuclear power plant being in a.condition that was outside the design basis of the plant.
Contrary to the above, the licensee failed to submit a Licensee Event Report within 30 days after the discovery on January 10, 1997, of an event concerning the degraded stuffing boxes on the main steam isolation valves.
This is a Severity Level IV violation (Supplement I).
CONSUMERS ENERGY COMPANY RESPONSE Consumers Energy Company agrees with this violation as written.
Background
Condition Report (CR) No. C-PAL-97-0007 was originated on January 3, 1997, after the leaks in the main steam isolation valves (MSIVs) were discovered on December 20, 1996.
The original reportability determination was made based on the information contained in the original CR. Since the valves had not been disassembled at this point, this CR contained no information about the potential for a piping code violation or th_e origin of the steam leaks:-*The-*tic*ensing personnel classified the condition as a steam leak similar to those experienced on the MSIVs during other startups and determined it to be not reportable .
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ATTACHMENT 2 REPLY TO NOTICE OF VIOLATION 97005-02 FAILURE TO SUBMIT LICENSEE EVENT REPORT WITHIN 30 DAYS OF DISCOVERY Temporary repairs were attempted on January 6, 1997 on the leaking plugs but were unsuccessful when unexpected leak patterns developed during the drilling operation on the plugs. On January 7, 1997, the evaluator of C-PAL-97-0007 recognized that the plug that was required to be removed on CV-0501 had not been removed. Thus information existed at this time to recognize that a code violation existed.
On about January 10, 1997, the evaluator of C-PAL-97-0007 briefed the Licensing Manager on the current status of the investigation into the MSIV steam leak on the pipe plugs. The Licensing Manager believed the information he was reviewing had been made available to the Licensing personnel who would make the reportability determination.
However, responsible Licensing personnel had not been notified, and as a result no reportability determination was made.
During a March 6, 1997, Management Review Board (MRS) meeting, it was realized that this issue had a high potential for reportability to the NRC and a reportability determination was made. It was determined that the condition was reportable and Licensee Event Report LER 97-005 was submitted to the NRC on March 21, 1997.
Reasons for Violation The reason for this violation was an inadequate sensitivity by Maintenance and Licensing personnel to reportable situations. Also contributing was poor communication between Licensing and Maintenance personnel and within the Licensing Department.
The Licensing Manager understood that additional information was being obtained in the way of laboratory test results and that the reportability determination could not be made until material compatability was established using test results. In addition, the Licensing Manager expected that the information being presented to him was available to the Licensing personnel who would be making the reportability decision. The process in place allowed a single error by a Licensing representative to create a late reportability determination which is not acceptable.
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ATTACHMENT 2 REPLY TO NOTICE OF VIOLATION 97005-02 FAILURE TO SUBMIT LICENSEE EVENT REPORT WITHIN 30 DA VS OF DISCOVERY Corrective Action Taken and Results Achieved All Licensing personnel have been counseled on the need to be sensitive to reportable situations. All Management personnel, including those persons participating in MRBs and Corrective Action Review Boards, have been briefed on the conditions which led to this violation. In addition, the Licensing Department reorganized to focus reportability determinations into one group under a Regulatory Response Supervisor. The purpose of this new Licensing Section is to specifically respond to immediate and short term issues.
Corrective Actions Remaining to Avoid Further Violations The following additional action is intended to enhance the reportability determination process.
The Reportability Determination process will be modified to:
- a. Require additional documentation of reportability determinations and reassessments.
- b. Require a second level of review for initial reportability determinations and reassessments.
The planned completion date is August 1, 1997.
Date Full Compliance Will Be Achieved Palisades Nuclear Plant was in full compliance since March 21, 1997 when LER 97-005 was submitted and the reportability was completed.
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ATTACHMENT 3 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION FOR THREE VIOLATIONS REPORTED IN INSPECTION REPORT NO. 50-255/97005 FAILURE TO FOLLOW PROCEDURES
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It ATTACHMENT 3 REPLY TO NOTICE OF VIOLATION 97005-03 FAILURE TO FOLLOW PROCEDURES NRC NOTICE OF VIOLATION During an NRG inspection conducted on March 1 through April 11, 1997, violations of NRG requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions," NUREG-1600, the violations are (sic) listed below:
- 3. 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above:
- a. On November 16, 1996, an activity affecting quality, the seal weld on the main steam isolation valve CV-0510-pipe plug was not as described in the Weld Inspection Checklist for Work Order No. 24610966, Procedure No. 5.05 (sic).
- b. On November 16, 1996, an activity affecting quality, the seal welded configuration for main steam isolation valve CV-0501 pipe plug was not
. performed as described in the Weld Inspection Checklist for Work Order No.
24512907.
- c. On November 16, 1997 (sic), Work Order Nos. 24610966 and 24512907, were not available at the work site for the main steam isolation valves, CV-0501, and 0510, as required by Administrative Procedure 5.01, Attachment 2,
- "Work Order Scheduling, Performance, and Completion," Section 4. 1, which states, in part, "a working copy of the work order shall remain at the work site whenever work is in progress."
This is a Severity Level IV violation (Supplement I).
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ATTACHMENT 3 REPLY TO NOTICE OF VIOLATION 97005-03 FAILURE TO FOLLOW PROCEDURES CONSUMERS ENERGY COMPANY RESPONSE Consumers Energy Company agrees with this violation as written.
Background
Licensee Event Report 97-005, submitted on March 21, 1997, provides additional background information for this Notice of Violation and is incorporated herein by reference.
Reasons for Violation The root cause for failure to implement the plug seal welds in accordance with the Welding Inspection Checklists and to maintain the Work Order at the job site was the failure to follow maintenance procedures requiring such actions. A lack of single point accountability for the job failed to identify and resolve this failure as part of the work implementation. An inadequate questioning attitude contributed to the failure to identify the problem.
Corrective Action Taken and Results Achieved
- 1. Both leaking pipe plugs (one plug per valve) were permanently repaired by installing new forged steel one inch pipe plugs which met the code requirements.
- 2. The Operations Manager and the Maintenance Manager spoke to the repair workers and technicians at a stand down meeting regarding expectations for high levels of performance. The Lead Supervisors presented the lessons learned from the MSIV work. T~e presentations focused on procedural adherence, roles and responsibllities, work scope control, communications, use of self-checking and conservative decision making.
The Maintenance Manager sent a memo to all Maintenance and Planning Department supervisory personnel which described the effect that pre-job brief communication failures had on the work that led to the MSIV st~am leaks. The __ _
memo focused on the importance of multi-discipline briefings in preparing for effective crew briefings.
- 3. The proper use of sketches within the Weld Inspection Checklist Process has been clarified in the Administrative Procedures.
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ATTACHMENT 3 REPLY TO NOTICE OF VIOLATION 97005-03 FAILURE TO FOLLOW PROCEDURES Corrective Actions Remaining to Avoid Further Violations A pre-job brief workshop will be developed and implemented to establish and communicate pre-job brief expectations and to improve repair worker participation. Included within this workshop will be:
- 1. The identification of multi-discipline tasks in the 13-Week Schedule Process.
- 2. The assignment of a single point of contact.
- 3. The improvement of readiness reviews and pre-job briefs.
The planned completion date is December 31, 1997.
Date Full Compliance Will Be Achieved Full compliance has been achieved with the proper repair to the pipe plugs on CV-0501 and CV-0510 .
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