ML18052B448
| ML18052B448 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/15/1988 |
| From: | BERRY K W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8801210206 | |
| Download: ML18052B448 (3) | |
See also: IR 05000255/1987029
Text
I -* General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 January 15, 1988 Nuclear Regulatory
Commission
Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES
PLANT -RESPONSE TO INSPECTION
REPORT 87-029 Kenneth W Be..,Y Director Nuclear Licensing
NRC Inspection
Report 87-029 dated December 17, 1987 transmitted
and requested
a written response.
The violation
involves the failure to comply with a written procedure
governing
the performance
of containment
isolation
valve position checks. Consumers
Power Company's
reponse to this violation
is as follows: Response:
Violation
(255/87029-01) (DPR) As .a result of the inspection
conducted
on November 3 through December 1, 1987 and in accordance
with the General Policy and Procedures
for NRC Enforcement
Actions (lOCFR Part 2, Appendix C), the following
violation
was identified:
Technical
Specification
6.8.1 requires the implementation
of certain procedures
including
those governing
the operation
of the Plant systems. Included in the procedures
governing
operation
of the Plant systems is Administrative
Procedure
4.02 which requires that when a valve " *** position is found to be different
from that specified, the Shift Supervisor
shall be notified and he shall authorize
the positioning
of the valve." Contrary to the above, on November 16, 1987 valve WGS-511 was found in a position (locked closed) contrary to Procedure
M0-29 requirements (Open); seven of the nine previous valve position checks performed
during 1986 and 1987 failed to identify and document the position discrepancy
and failed to report same to the Shift Supervisor.
8801210206
880115 PDR ADOCK 05000255 Q PDR OC0188-0011-NL04
..... -J.. * * * Nuclear Regulatory
Commission
PalisaQ.es
Plant Response to Inspection
Report 87-029 January 15, 1988 Corrective
Actions Taken And Results Achieved 2 On November 16, 1987, Plant Auxiliary
Operator performing
Technical cation Surveillance
Procedure
M0-29, "Engineered
Safety System Alignment", identified
a discrepancy/typographical
error regarding
the positioning
of containment
ventilation
header test valve, MV-WGS511.
The valve was found to be in its required locked closed position, however, M0-29 specifies
that the valve should be verified to be in the open position.
This procedural
discrepancy
had also been identified
during the second performance
of M0-29 in 1986. However, due to the Plant Review Committee (PRC) rejection
of a temporary
change to the procedure
and mis-communication
between Plant personnel, the procedure
was not corrected.
This procedure
has been performed
nine times since the error was identified
in 1986. As stated in the inspection
report, Consumers
Power and the NRC Senior Resident Inspector
believe that, the one inch test line valve which was found locked closed and capped was being verified*
as locked closed and the checklist
was being initialed
erroneously.
On November 18, 1987, a technical
review of procedure
M0-29 was completed.
This review entailed verifying
all other"valve
positions
indicated
within the procedure
were correct and then physically
verifying
that actual in-plant valve positions
corresponded
to their required positions.
No additional
errors were found in the procedure
or with valve positions.
The Plant Operations
Superintendent
then reviewed the event with all on-shift Operations
personnel.
On December 1, 1987, personnel
involved with the communication
error which resulted in the failure to correct the procedural
discrepancy
were counselled
with respect to the need to properly documenting
the closure of open PRC items. Temporary
changes to procedures
that are disapproved
by the PRC will be forwarded
to the originator
and the affected department
supervisor
to assure the procedural
error is otherwise
corrected
in a timely manner. Corrective
Actions To Be Taken To Avoid Further Noncompliance
Operations
Department
checklists
are being revised to ensure the following
exists: -Standardized
formatting
-All required valve positions
are fully printed out, no abbreviations
-Valves in potentially
contaminated
areas are arranged by rooms, with no two areas on the same sheet -A comment section is present on each sheet In addition, the above revisions
are also being performed
for all surveillance
procedures
containing
valve checklists.
OC0188-0011-NL04
Nuclear Regulatory
Commission
Palisades
Plant Response to Inspection
Report 87-029 January 15, 1988 An evaluation
is being conducted, to determine
the best way to assure that no discrepancies
exist before procedure
issuance.
Auxiliary
Operators
will be to be required to utilize original checklists
or procedures
during their performance.
Guidance has been provided to the Operations
Department
by the Radiological
Services Department
to provide expeditious
copying of contaminated
original checklists
or procedures.
Date When Full Compliance
Will Be Achieved All corrective
actions described
above, with the exception
of Surveillance
Procedure
revisions, will be completed
by June 1, 1988. Completion
of the Surveillance
Procedure
revisions
will occur by December 31, 1988 due to the extensive
number of Technical-Specifications
procedure
revisions
to be.done. Kenneth W Berry Director, Nuclear Licensing
-CC Administrator, Region III, NRC NRC Resident Inspector
-Palisades
OC0188-0011-NL04
3