ML20203J860

Responds to NRC 860701 Notice of Violation & Imposition of Civil Penalty Re Insp Rept 50-255/86-08 on 860115-0314. Corrective Actions:Prompt Notification of Potential Problems Involving Containment Integrity Initiated

ML20203J860
Person / Time
Site:	Palisades
Issue date:	07/31/1986
From:	Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8608060038
Download: ML20203J860 (4)

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Nwirar Operations General Offees 1945 West Parnall Road, Jackson, MI 49201 e (517) 788-1217 July 31, 1986 Richard DeYoung, Director Office of Inspection and Enforcement US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NO 50-255/86008[DRP])

NRC letter dated July 1, 1986 transmitted a Notice of Violation and Proposed Imposition of Civil Penalty related to apparent items of violation identified during a special inspection conducted during the period January 15 through March 14, 1986 at the Palisades Plant (IE Inspection Report 50-255/86008 (DRP]). The items of noncompliance and required responses thereto are provid-ed below. A check in the amount of $50,000.00 for the civil penalty imposed in connection with those violations is attached.

Violations from IE Inspection Report 50-255/86008:

A. 10 CFR Part50, Appendix B, Criterion V, as implemented by Palisades Quality Assurance Manual CPC-2A, Section 5.1, states that testing shall be performed in accordance with established procedures to demonstrate that safety related structures, systems and components will perform satisfactorily in service.

Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained for test activities of safety related equipment.

Contrary to the above, containment leak rate tests performed in May and August 1985 on Penetration 40 to investigate whether its compo-nents would perform satisfactorily in service and to resolve Deft-ciency Reports (DR) PAL-85-046 and PAL-85-092 were not performed in accordance with any established procedure.

B. Palisades Nuclear Plant Administrative Procedure (AP) No 3.03, Section 6.2.b. requires that the Corrective Action Review Board (CARB) review immediate DR corrective actions for adequacy and provide direction for additional action, if warranted.

OC0786-0123-NLO2 9600060030 060731 PDR 0

ADOCK 05000255 PDH

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Director, Office of Inspection & Enforcement 2 Palisades Plant Payment of Fine (IEIR 86-008)

July 31, 1986 AP 3.03, Section 6.4, requires that the Plant Review Committee (PRC) shall review the proposed DR corrective actions for adequacy.

Contrary to the above, the CARB and PRC did not adequately review D-PAL-85-046 and D-PAL-85-092 for immediate action and did not provide direction for warranted additional action, in that tests used in determining corrective action had erroneous valve lineups and were performed without required procedures.

Response

(1) Admission or Denial of the Alleged Violation Consumers Power Company (CPCo) admits that the violations occurred as stated.

(2) Reasons for the Violation, if Admitted:

The containment integrity problem associated with the isolation valves of Penetration 40 was the subject of an Enforcement Conference between NRC regional administrators and CPCo representatives on March 13. 1986. Subsequently, the entire chronology of the occur-rence, including evaluation of the cause of the stated violations was recounted in IE Inspection Report 50-255/86008, dated April 8, 1986.

Accordingly, the cause of Violation A was adequately depicted by Items 3(a), 3(b), 3(c), 3(e) and the second paragraph of Item 5 from the Inspection Report. Violation B was the result of insufficient depth of review by the CARB and PRC members who were responsible for reviewing the referenced deviation reports. Violation B is further described by Item 3(d) and the second paragraph of Item 5 from the Inspection Report.

(3) Corrective Steps Which Will Be Taken to Avoid Further Violations:

On March 14, 1986, the day following the Enforcement Conference, Consumers Power Company transmitted a number of commitments to the NRC Region Administrator addressing aggressive corrective action to prevent recurrence of the stated violations. These commitments were also recounted in IE Inspection Report 50-255/86008, Item 4 "Correc-tive Actions".

All of the corrective actions outlined in Item 4 of the Inspection Report (Items 4n-4h) have been accomplished as ntated. Note that item 4g, the corrective action plan for local Leak Rate Testing, was submitted by 1ctter dated June 30, 1986 and has long term commitment dates that provide both identification and correction of potential hardware problems. The plan has been put in place. We believe these actions, as stated in our March 14, 1986 letter, demonstrate an aggreonive prorrnm that takes positive steps in responne to the seriousness of this incident. The fact that the actions are now OC0786-0123-ht02

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ITirector, Office of ~nspection & Enforcement 3 Palisades Plant Payment of Fine (IEIR 86-008)

July 31, 1986 complete ensures that our objectives, as follows, will continually be accomplished:

1. Prompt notification of potential problems involving containment integrity and other Technical Specification criteria to our PRC and CARB members.

2. Prompt initiation and evaluation of corrective action records.

3. Timely and complete corrective action.

(4) Date When Full Compliance Will be Achieved:

Full compliance has been achieved.

Note: The corrective action plan on local Leak Rate Testing has completion dates out to December 31, 1987, and is carried as unresolved item 50-255/86005-02.

%OJ Frederick.W Euckman Vice President Nuclear Operations CC Administrator, Region III USNRC NRC Resident Inspector - Palisades Attachments OC0786-0123-NLO2 I

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CONSUMERS POWER COMPANY Palisades Plant Docket 50-255 - License DPR-20 RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES DATED JULY 1, 1986 At the request of the Commission and pursuant to the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974, as amended, and the Commission's Rule and Regulations thereunder, Consumers Power Company submits our response to Notice of Violation and Proposed Imposition of Civil Penalties dated July 1, 1986. Consumers Power Company's response is dated July 31, 1986.

CONSUMERS POWER COMPANY

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F 9 Buckman, Vice Presiden Nuclear Operations Sworn and subscribed to before me this 31st day of July, 1986.

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El'aine E Buehrer, Notary Public (SEAL)

Jackson County My commission expires October 31, 1989 I

, OC0786-0123-NLO2

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