ML18052A256
| ML18052A256 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/27/1985 |
| From: | Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CAL-85-15, NUDOCS 8601280055 | |
| Download: ML18052A256 (8) | |
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consumers Power company General Offices: 1945 West Parnall Road, Jack~on, Ml 49201 *.1517) 76$-0550 December 27, 1985 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO INSPECTION REPORT 85-024 The letter enclosing Inspection Report 50-255/85-24 requested a description of the actions that are planned or in place to resolve the items addressed by Confirmatory Action Letter 85-15 dated October 30, 1985.
The response to the Confirmatory Action Letter and the one item of noncompliance in the inspection report are provided herein.
In addition, certain other items noted in the inspection report are discussed and clarified in this submittal.
CONFIRMATORY ACTION LETTER 85-15 RESPONSE On December 3, 1985, a meeting was conducted between Consumers Power and the NRC Region III to discuss the October 30, 1985, Confirmatory Action Letter 85-15.
As a result of this meeting, certain actions were proposed to improve the Palisades Plant performance in the areas of backlogged maintenance work orders and maintenance trending programs.
These improvements will be achieved by the actions described herein.
An overall reduction will occur in the current backlog of outstanding mainte-nance work orders.
The work orders will be prioritized to emphasize the completion of work most important to the safe operation of the plant and work that may only be completed during a plant outage.
The reduction in work orders is expected to occur according to the attached graph "Maintenance Work Order Backlog Forecast".
The work orders included in this forecast are composed of preventive maintenance, corrective maintenance and project work orders.
Following the present refueling outage, the OC1285-0010-NL02 86oi28oos5-a51227 PDR ADOCK 05000255 Gl PDR
J G Keppler, Administrator Palisades Plant Response to IR 85-024 December 27, 1985 published work order backlog number will not include the project work orders.
The forecast assumes 100 emergent work orders will occur per week.
This assumption provides additional margin in the forecast for unplanned work items.
The graph also provides our assessment of the current number of backlogged maintenance orders.
2 A reduction will occur in the number of outstanding control room deficiencies.
Control room deficiencies will be identified by a task group consisting of the Technical Engineer, Operations Superintendent, and Instrument and Controls Superintendent.
The task group will use the following criteria, that were specified in the Confirmatory Action Letter, to identify a control room deficiency:
- 1)
Deficiencies that directly affect the controls used by operators during emergency situations, off-normal situations or routine operations.
- 2)
Deficiencies that result in information, relied on by operators to take action, being inaccurate or indeterminate.
- 3)
Deficiencies that result in an annunciated control room alarm that reflects an off-normal condition
- The specific reduction in control room deficiencies is expected to occur in accordance with the attached graph "Control Room Deficiency Forecast".
During the current refueling outage a monthly report will be submitted to Region III and will describe the following data for the previous calendar month:
a)
Total work order backlog b)
Emergent work orders c)
Total Control Room deficiencies d)
Emergent Control Room deficiencies Following the refueling outage, the status report will be submitted every two months until it is agreed by Consumers Power Company and the NRC that this action is no longer necessary.
Prior to startup from the current refueling outage, a Plant Review Committee subgroup will review all outstanding maintenance work orders and Control Room deficiencies.
The subgroup will ensure that the remaining work orders and deficiencies do not represent a significant detriment to the safety of plant operation.
The conclusions of the subgroup will be reviewed by a formal Plant Review Committee.
OC1285-0010-NL02
J G Keppler, Administrator Palisades Plant Response to IR 85-024 December 27, 1985 A maintenance trending program will be developed and implemented.
The trend-ing program will address three areas.
These areas are:
- 1.
Equipment performance.
- 2.
Preventive maintenance.
- 3.
Corrective maintenance.
Equipment performance trending will provide a periodic review of system operating characteristics.
This information will then be used to monitor equipment performance and to attempt to identify degradation in performance prior to equipment failure.
Preventive maintenance trending will address frequency based on performance results, handling and recording of appropriate data obtained during perform-ance and schedule evaluation of preventive maintenance which is frequently deferred.
Corrective maintenance trending will result in a periodic review of maintenance activities.
This review will evaluate high frequency corrective maintenance associated with specific systems or components and identify appropriate resolution of any problem identified.
This review will use the capabilities of our computer-based work order system for identification of problem areas.
3 All plant equipment will be considered for inclusion in the trending program.
However, trending will be limited to certain equipment based on safety function, ability to challenge a safety system or the effect on plant perform-ance.
The trending program will utilize data obtained from existing plant programs and activities.
Consideration will be given to the implementation of additional programs that may be necessary to obtain the data necessary for proper trending of equipment performance.
At the completion of the outage the overall administrative program addressing the three phases of trending will be in place.
Active equipment performance trending and evaluation will be occurring on major equipment on a limited bases.
A preventative maintenance trend program will be active, however, implementation will take place as individual P~'s are rewritten.
Corrective maintenance trending will also be in place limited only by the scope of the computer data base.
During the current refueling outage, a one-year data base of corrective maintenance will be developed into a trending program.
This data base will be utilized to examine the frequency of corrective maintenance for plant equip-ment.
The program will be used to verify the frequency of preventive mainte-nance requirements.
Within six months following the current outage, the data base will have been expanded to include 3 years of corrective maintenance data.
OC1285-0010-NL02
) G Keppler, Administrator 4
Palisades Plant Response to IR 85-024 December 27, 1985 Consumers Power and the NRC Region III will convene a meeting prior to the conclusion of the current refueling outage.
A presentation will be made discussing the status of actions taken to address the issues of the Confirmatory Action Letter.
Progress will be reviewed for the resolution of each issue.
One item of noncompliance was identified in Inspection Report 50-255/85-024.
The following is our response to this item:
Noncompliance 50-255/85-024-01 10CFR50, Appendix B Criterion XVI, as implemented by Consumers Power Company (CPCo) "Quality Assurance Program for Operational Nuclear Power Plants" (CPC-2A), requires that measures shall be established to ensure that condi-tions adverse to quality are promptly identified and corrected.
- Further, CPC-2A, Section 16.2.2 requires that, for conditions noted adverse to quality, appropriate remedial action is taken and corrective action is implemented in a timely manner.
Contrary to the above:
- 1.
Violation 255/85003-01 identified a failure to perform Preventive Mainte-nance (PM) on magnetic and thermal overload trip devices in the 480/460 volt switchgear and motor control centers.
Interviews with plant personnel and examination of licensee documents disclosed that most of the PMs for this safety-related equipment had still not been performed.
- 2.
Violation 255/85003-03 identified a failure to perform Preventive Mainte-nance trending as required by Procedure 5.03 "Preventive Maintenance Program."
The inspectors determined that electrical PM trending and some mechanical PM trending was still not scheduled or performed.
- 3.
Violation 255/85003-03 identified a failure to perform trending of correc-tive maintenance.
The inspectors determined that this situation continued to exist.
Discussion:
The violation provides three examples of items that require further improve-ments to achieve full compliance with program requirements.
The first example concerning 480/460 volt switchgear is addressed by the following corrective actions.
The remaining two items identify deficiencies in maintenance trend-ing.
The corrective actions for corrective and preventive maintenance trending were previously addressed as part of the response to Confirmatory Action Letter 85-15 included with this submittal
- OC1285-0010-NL02
J G Keppler, Administrator Palisades Plant Res~onse to IR 85-024 December 27, 1985 Corrective Actions Taken And Results Achieved 480/460 volt safety-related switchgear and motor control centers have been incorporated into the Preventive Maintenance Program.
Corrective Actions To Be Taken To Avoid Further Noncompliance The preventive maintenance for the 480/460 volt switchgear and motor control centers will be completed.
Date When Full Compliance Will Be Achieved Full compliance will be achieved prior to startup from the current refueling outage.
ADDITIONAL ITEMS:
Our review of Inspection Report 50-255/85-024 identified certain areas that should be clarified or corrected.
The additional information is provided herein.
This information should be utilized for your future review of the concerns identified in this inspection.
In early 1985, the total number of identified control room deficiencies was found to have reached a significant level.
The reduction of these deficien-cies was considered an item that warranted serious management attention.
In response to this concern, the necessary attention was provided and continues to exist.
5 To adequately determine the magnitude of the problem, an accurate assessment of the quantity of deficiencies was needed.
Our evaluation of these deficien-cies determined that many of the items did not identify valid equipment problems.
Also, a number of deficiencies were documented by duplicate equip-ment problem identification systems.
The elimination of these types of deficiencies allowed the plant management to assess the problem and to deter-mine the proper actions to eliminate the overall concern of control room deficiencies.
Control Room deficiencies are considered a high priority maintenance area.
A serious effort was provided by the maintenance departments to reduce the number of open items.
Due to the increased management attention in this area, the number of deficiencies that could be worked while the plant operated were significantly reduced.
Our intention has been and will continue to be the reduction of the number of control room deficiencies to the lowest practicable level.
Unresolved Item 50-255/85-017-01 addressed the issue of the adequacy of corrective action trending.
The item was identified in IE Inspection Report 50-255/85-017 dated September 5, 1985.
Following the receipt of this report, a formal request was prepared and submitted on September 30, 1985 to cause the OC1285-0010-NL02
J G Keppler, Administrator Palisades Plant Response to IR 85-024 December 27, 1985 necessary improvements.
The completion of these improvements is expected in early 1986.
We feel these actions were appropriate to address the resolution of all concerns related to improvements in our current corrective action trending program.
6 Open Item 50-255/85-003-10 concerned a possible error in an instrument calibration report for Measuring and Test Equipment.
Subsequent review of this report determined that the calibration report was correct.
Since no discrepancy was identified, we do not feel that a review of all calibration reports is considered a prudent action.
Further, discussions with the responsible department do not indicate a lack of confidence in the accuracy of instrument calibration records.
Therefore, no further action will be provided with respect to this open item.
/.~
fft:;;:uemin Staff Licensing Engineer CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades Attachment OC1285-0010-NL02
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