ML18051A261

Forwards Regulatory Performance Improvement Program Status Rept, Supporting Util Request for Rescission of NRC 791109 & 810309 Orders.Status of Other Aspects of Orders Discussed

ML18051A261
Person / Time
Site:	Palisades
Issue date:	12/17/1982
From:	Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML18051A262	List: ML18051A261 ML18051A263
References
NUDOCS 8301110300
Download: ML18051A261 (4)

Text

.J consumers Power Russell B. DeWitt Vice President company Nuclear Operations General Offices: 1945 Parnall Road, Jackson, Michigan 49201 * (517) 788-1217 December 17, 1982 James G Keppler, Administrator Region III us* Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - STATUS OF REGULATORY PERFORMANCE IMPROVEMENT PROGRAM (RPIP)

Consumers Power Company* letter dated April 7, 1981 transmitted "Consumers Power Company Regulatory Performance Improvement Program" in response to the March 9, 1981 Confirmatory Order Modifying the Palisades Operating License.

Since that time, periodic Management level meetings have been held with you and members of your staff to discuss our progress toward meeting our RPIP com-mitments. At a September 8, 1982 Management meeting, Consumers Power Company provided a status report on the 1981 Order in general and our RPIP in partic-ular. Also discussed during the September 8, 1982 meeting was the status of our compliance with the November 9, 1979 Order Modifying the Palisades Operat-ing License. The 1979 Order was issued as a result of a containment integrity violation involving two normally closed, manual isolation valves in the containment_ purge bypass line. At the same meeting, Consumers Power Company requested that the NRC consider rescinding both the 1979 and the 1981 Orders based on the status of the two Orders, the improved regulatory performance of

• the Palisades Plant and the fact that all but a few of the RPIP activities will have been completed by December 1982. In support of this request, Consumer~ Power Company committed to provide during December 1982 a status report on the program. This report is enclosed. In addition, the following is a brief discussion of status of other aspects of the 1979 and 1981 Orders.

November 9, 1979 Order The November 9, 1979 Order required Consumers Power Company to:

"A. Prior to start-up from the present refueling, the licensee shall conduct

~comprehensive review of all procedures and checklists to assure ....

ocl282-0067a-43-48 8301-110300 821217 PDR ADOCK 05000255 G PDR

James G ~eppler~ Admi.trator 2 Palisades Plant

• Status of Regulatory Performance Improvemen~ Program (RPIP)

December 17, 1982 B. Report to the Director of the NRC's Region III office the results of at least monthly inspectipns .during operation of all accessible valves and other controls for engin,~ered safety systems for compliance with the Limiting Condition for Operation (LCO) requirements of the Technical

.specifications.

C. Prior tq s~art-up following the present refueling, the licensee shall explain to the Directpr, NRR Office of Inspection and Enforcement, in a meeting in Bethesda, Maryland,. how the above requirements shall be implemented."

Tasks A and.C were completed prior to start-up from the 1979 refueling oµtage.

Task B is currently ongoing. Consumers Power Company proposes to continue the monthly surveillance of all acc*essible valves and other controls for engi-neered safety features. However, the monthly reporting is considered unneces-sary given the*fact that any noncompliance discovered must be reported to the

• NRC in accordance with Technical Specifications.

March 9, 1981 Order The March 9, 1981 Order contained four parts as follows:

"A. The licensee shall continue to operate under the following provisions which are a clarified and revised form of the provisions of the Immediate Action Letter issued January 9, 1981:

1. The licensee shall conduct an audit of plant operations daily by a corporate IDfinagement representative.

2. A committee comprised of a member of corporate management (in

. adqition to* the corporate .representative referenced in item 1 above),

a Senior Reactor Operator and another qualified individual shall review, prior to use, all Technical Specification surveillance procedures to assure that ....

3. The licensee. shall. reinstruct all personnel who perform safety-related work or other work in vital areas of the importance of strict adherence.to procedures and the necessity for performance of all assigned duties in a disciplined and professional manner.

4. The licensee shall verify by a second qualified individual, that all activities involving the manipulation of safety-related circuits or sy~tems outside the control room have been completed as required.

Qualified individuals will be designated by the Plant General Manager for the specific tasks.

5. The licensee shall review the specific circuitry involved in the January 6, 1981 event to determine if control room indications are required to show when an abnormal lineup exists. Necessary circuit oc1282-0067a-43-48

James G **Keppler, Admin,trator 3 Palisades Plant Status of Regulatory Performance Improvement Program (RPIP)

December 17, 1982 modifications will be performed on a schedule to be agreed to by Region III of the NRC. 11 Consumers Power Company h~s continued to operate under the aforementioned provisions. .In our* letter dated July 20, 1982, we identified that the intent of the activities required by Item 1 above (ie, the independent assessment of Plant operat.ions by Corporate Management) has been incorporated into the duties and res'ponsibilities of our n:ew independent review group (Nuclear Activities Plant Organization - NAPO) which is in the process of being imple-mep.ted. Although NAPO- will not perform a daily audit as such, one of their functions will be to examine Plant operations for the purpose of identifying areas for improving Plant safety. The activities associated with Item 2 are

• complete for all existing Technical Specifications surveillance procedures, and the six (6) review criteria of this item have been incorporated into Plant administrative procedures. Should the 1981 Order be rescinded, we would in-tend to not involve a member of Corporate Management in this review. Item 3 is a continuing Management responsibility and an important aspect of our training program for nuclear power Plant personnel. Item 4 has been incor-porated into appropriate Plant administrative procedures, and finally, the modifications *involved with Item 5 were completed during the 1981 refueling outage as described to you in our letter of March 9, 1982.

"B. Extended work hours on the part of licensed operators shall be avoided by res.tricting the work hours for licensed operators consistent with the following provisions .... "

Consumers Power Company is currently complying with the requirements of G~neric Letter 82-12 ...dated June 15' 1982 which addresses "Nuclear Power Plant Staff Work;i.ng Hours." A Technical Specification change request is being prepared which will incorporate these restrictions into the Technical Specifi-cations. We expect this change request to be submitted before the end of 1982 .

11 C. A corporate review team shall p~rform independent reviews of safety-related events which are*reportable as Licensee Event Reports per Technical Specification 6.9* and which are caused by personnel errors or procedural inadequacies .... "

It was identified in our July 20, 1982 letter that the intent of this review requir:enient (ie, the independent rev:iew _of important events involving personnel error or procedural inad,equac*ies) has. been incorporated into the duties and responsibilities of NAPO. NAPO will perform a detailed review of those LERs it considers to be sufficiently important to warrant an independent assessment.

"D. The licensee shall submit to the Director of Region III of the NRC, within 30 days of this Order, a comprehensive plan of action that will ensure.sufficient controls will be implemented to prevent recurrence of valving and system misalignments and other. operational errors similar to those set forth in Sections II and III above .... 11 ocl282-0067a-43-48

. *. . James G. Keppler,* Admin,trator 4 Palisades Plant Status of Regulatory Performance Improvement Program (RPIP)

December 17, 1982 Our letter of April 7, 1982 prqvided a description of our Regulatory Per-formance Improvement Program. A current status of this program is provided in the enclosed.report.

We hope that this letter and the enclosed report provide the NRC with suffi-cient information to close out the Orders of November 9, 1979 and March 9, 1981..

• ~ )g '6-L0J;(;(,-7~ 1 Russell B DeWitt 1

Vice President of Nuclear-Operations CC Director; Office of Nuclear Reactor Regulation Dire~tor, Office of Inspection and Enforcement NRC Resident Inspector-Palisades Attachment oc1282-0067a-43-48