ML18043A308

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Responds to 781027 NRC Ltr Re Violation Noted in Inspec Rept#50-255/78-22.Check W/Personnel Showed Maint Activity Had Been Correctly Done.Admin Procedures Will Be Rev
ML18043A308
Person / Time
Site: Palisades Entergy icon.png
Issue date: 11/16/1978
From: HOFFMAN D P
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: KEPPLER J G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7812060024
Download: ML18043A308 (2)


See also: IR 05000255/1978022

Text

' ** General Offices: 212 West Michigan Avenue, Jackson, Michigan 4g201 .* Area Code 517 788-0550 November 16, 1978 Mr James G Keppler Office of Inspect_ion

and Enforcement

Region III US Nuclear Regulatory

Commission

799 Roosevelt

Road Glen Ellyn, IL 60137 DOCKET 50-255 -LICENSE DPR-20 PALISADES

PLANT -IE INSPECTION

78-22 Consumers

Power Company's

response to the apparent item of noncompliance covered during IE Inspection

78-22 is as follows: Tlie -Palisades

Technical

Specii'icat-ion

6. 8 ."l requj.:res

c-that_

p:r:_oceduresc..:shall

-* be . .-established

and implemented

as -recommended

  • in

to Regulat-qry

Guide 1. 33 (November

1972-) whi*ch includes ,procedures--for .the control .of* maintenance

.'8.ctivi

ties-.. Administrative

  • Procedure

1. 5,

.1 .. 1. l requiresc...that

prior to declaring

the equipment

a *review-of*

the maintenance*

documentation

o..Illust-.be.

performed

... an-a: that suitable _documentary.

evidence .exists -to substantiate*

acceptable

completion

and-_the .. maintenance.

Contrary to the*-above';*

the *.control

rod drive mechanisms*were

declared "o"perable" following

completion

of.the maintenance

activity -during the -last refueling

outage (January 6 through April 1, 1978) *without completion

of the administrative

review and disposition

of discrepancies.

Response Discussion

-The removal from service -*and return to operable status of related equipment

are accomplished

under administrative

controls, using a document titled the "Equipment

Outage Request (EOR)" form. The use of this document was a requirement

at Palisades

during the 1978 refueling

outage; and in fact, an EOR was used to control the removal of the CRDM seal housings and their subsequent stallation

on the reactor vessel head. However, an EOR was not used to control all the maintenance

activities

which were performed

on the CRDMs during the period that they were removed from the reactor vessel head. This situation, which after the fact obviously

represents

a serious pitfall, was permitted

by the

tive procedure

governing

the use of EORs. As a result of this shortcoming, ad.min-*strative reviews of the work packages relating to CRDM seal refurbishment

during he 1978 refueling

outage were not performed

prior to declaring

the CRDMs operable.

'l B 12 o 6 o '-\ NOV 2 O 1978 Q

  • -Corrective

Action Taken and Results Achieved r. The. supervisors

directly in charge of the CRDM repair activities

were interviewed

by the Palisades

Plant Maintenance

Superintendent

to determine

if required repair procedures

were followed, inspections

made, and sign-off sheets filled out. From these interviews, it has been determined

that.the maintenance

activities

were rectly performed

even though some sign-off sheets could not be found. Based on this determination, and because the EOR which was used to control the return to operable status of the CRDMs contained

return-to-service

testing requirements

which were applicable

to the CRDM seal refurbishment, it has been concluded

that the CRDMs are indeed operable.

Corrective

Action To Be Taken to Prevent Recurrence

The Administrative

Procedures

governing

the use of EORs will be revised to more clearly

the requirements

of using an EOR. Date When Full Compliance

Will Be Achieved The changes to the Administrative

Procedures

will be made by January 1, 1979 . *

  • David P :Hoffman _ Assistant

N11clear-Licensing_Administrator

CC: Director, .Office of Nuclear Reactor Regulation

Director, Office of Inspection

and Enforcement