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
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7812060024
Download: ML18043A308 (2)


Text

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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 dis-covered during IE Inspection 78-22 is as follows:

Tlie -Palisades Technical Specii'icat-ion 6. 8 ."l requj.:res c-that_ ~written p:r:_oceduresc..:shall -*

be . .-established and implemented as -recommended *in *App~ndix,:.A to Regulat-qry Guide 1. 33 (November 1972-) whi*ch includes ,procedures- -for .the control .of* maintenance .'8.ctivi ties-..

Administrative *Procedure 1. 5, Sec-th)n~5 .1 .. 1. l requiresc...that prior to declaring the equipment "operable,-'~ 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 safety.-

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 rein-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 administra-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 B12 o 6 o o~'-\ NOV 2 O1978 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 cor-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 de~ine 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 .

  • {LU4f~

David P :Hoffman _

Assistant N11clear-Licensing_Administrator CC: Director, .Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement