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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] |
See also: IR 05000255/1997005
Text
A CMS Energy Company July 23, 1997 U.S. Nuclear Regulatory
Commission
ATTN: Document Control Desk * Washington, DC 20555 Palisades
Nuclear Plant 27780 Blue Star Memorial Highway Covert. Ml 49043 DOCKET 50-255 -LICENSE DPR-20 -PALISADES
PLANT Tel. 616 764 2296 Fax: 616 764 2425 Tllomn J. Palmluao Site Vice President
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, 1997, discovery
date. The required submittal
period is 30 days. \ < v \. 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 I llllll 111111111111111111111111111111111
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.
Thomas J. Palmisano
Site Vice President
CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector-:
Palisades
3 Attachments
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 3 Pages
1 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.
__ 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 . 1
-* * 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. 3. 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.
The proper use of sketches within the Weld Inspection
Checklist
Process has been clarifiecf
illthe Administrative
Procedures . 2
-* * * 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 and CV-0510 . 3
' . * 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
.. -* * ATTACHMENT
2 REPLY TO NOTICE OF VIOLATION
97005-02 FAILURE TO SUBMIT LICENSEE EVENT REPORT WITHIN 30 DAYS OF DISCOVERY
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: 2. 1 O 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 . 1
--* * 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.
* --*--* ---2
ii* --* 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.
3
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 . ....,... "e--* **----------3 Pages
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). 1
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. 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
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.
2
.. ... . , 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 . .
3