ML18052B361
| ML18052B361 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/30/1987 |
| From: | Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8711020364 | |
| Download: ML18052B361 (8) | |
Text
{{#Wiki_filter:consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1217 October 30, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISAD~S PLANT - RESPONSE TO NRC SALP 7 REPORT Frederick W Buckman Vice President Nuclear Operations Your letter dated September 14, 1987 contained the Systematic Assessment of Licensee Performance (SALP) No. 7 Board Report for our Palisades Plant cover-ing the period of November 1, 1985 to April 30, 1987. The letter requested that we respond within thirty days of the SALP meeting which occurred on October 1, 1987, with our written comments of the Report. This letter provides Consumers Power Company's response to the SALP 7 Report. Consistent with the format of the SALP Report, our response is presented by functional area. A. Plant Operations The SALP 7 Report identifies that plant operators consistently responded to plant events in a thorough and professional manner throughout the assessment period. However, the NRC pointed out and we concur that a number of areas did need strengthening in the plant operations category. Increased attention was, therefore, given to these areas with positive results being achieved by the end of the period. In order to ensure that events reported to the NRC were not only accurate but complete, plant management redefined their expectations and communi-cated them to crews through meetings and formal training. The action appears to*have been effective in that recent reports, which have been closely monitored by plant management, have been acceptable to the NRC. Although the operators were excellent in their response to plant events, it was felt that improvements could be made in their attention to detail during everyday routine operations. To accomplish this a new supervisory position was added to each operating crew with the responsibility to interface more closely between management and the operators. Expectations were better defined and written into procedures, and the operators were trained to meet the new standards. Thus far the results of the changes OC1087-0187-NL04 8711020364 871030 PDR ADOCK 05000255 a.. PDR
'\\ Nuclear Regulatory Commission Palisades Plant Response to SALP 7 Report October 30, 1987 have been po_sitive. This area will continue to receive increased atten-tion. 2 Following a period of high turnover, the Operations Department has stabil-ized it's management positions. It now has a core of well qualified and competent Shift Supervisors and includes positions within the department that are designed to give training and experience to personnel qualified t-n.f-{ 11 -F.... r..,,...o nnon-{noo -r-.............. c,-* In an effort to respond to industry issues in a more timely manner, the process of review, evaluation and action was streamlined. As stated in the Board Report, responsiveness has improved but will continue to be monitored by plant management. In summary, the plant will continue to strive for improvement in the Operations area in the future. This will come through continued manage-ment involvement in the details of day to day plant operation. This involvement will continue to define high standards and management expecta-tions for meeting these standards. It will also create better "bottom up" communications such that operator concerns can be promptly addressed and folded into the existing priority of work. The plant is confident the improving trend noted in the SALP Report will continue in the future because of these actions. B. Radiological Controls The SALP 7 Report identified a number of items that warrant improved performance in this functional area. We feel that the most significant weaknesses are the procedural adherence and job coverage problems attri-buted to radiation protection technicians. The problem is being addressed by a number of actions.
- 1) We have established a single radiation protec-tion supervisor with the responsibility to supervise job coverage.
In the past the Duty Health Physicist position was rotated among the plant's radiation protection supervisors.
- 2) We have just completed a two year program to train technicians on the radiation protection procedures.
- 3) We have also developed a training course for job coverage that will be given to technicians following the current Maintenance Outage.
- 4) The technician experience level is also improving.
Twelve of 25 technicians have greater than six years of experience and overall the average experi-ence level of technicians is four years. The corrective actions and improving experience level are expected to show progress in improved coverage. Flooding of the South Radwaste Building as a result of the cooling tower overflows is being addressed in two stages. For the short term the cooling tower bypass valve is now electrically isolated during* cooling tower operation. Previous flooding has been due to instrument failures that cause the valve to open during normal operation. In addition the South Radwaste Building has been decontaminated to minimize contamination OC1087-0187-NL04
\\, Nuclear Regulatory Commission Palisades Plant Response to SALP 7 Report October 30, 1987 that could be washed away. For the longer term, alternatives are being considered for a permanent solution. The appropriate alternative will be factored into the 5-Year Plan. A request for disposition of the slightly contaminated soil that remains around the South Radwaste Building, pursu-ant to 10CFR20.302, will be submitted by December 1, 1987. 3 The Radiological Controis section of the SALP 7 Report noted several 'concerns in the area of Chemistry. In response to those concerns;
- 1) We have adopted the use of trend plots for control of analytical measure-ments.
- 2) We have added an additional supply duct to the hot lab and an exhaust duct to the counting laboratory and have added an internal cooling unit to our multi-channel analyzer to improve the laboratory ventilation.
Further improvements are being pursued. Options to increase the lab space are also being considered. Overall we have pursued a program of upgrading this functional area and expect continued improvement in the future. C. Maintenance This section of the SALP 7 Report contains several references to positive actions and programs instituted through our own initiatives which address-ed nearly all the SALP Report concerns. We recognize the difficulty in assessing the maintenance area at a plant which has been through a lengthy forced outage to upgrade material condition. Taking this into considera-tion, the following comments are provided: We constantly scrutinize our organizational effectiveness. Needed changes have been made in the organization's structure and personnel filling key positions. You have noted the creation of an Operations/Maintenance interface group. During the last two years we have replaced a number of people in key management and supervisory positions for the purpose of increasing the organization's effectiveness. Likewise, we monitor work force resource levels and during the past evaluation period, augmented our plant maintenance staff with Consumers Power Company's Field Maintenance Services as well as contractors. Our budget has received needed increased support (and significant increases have been allocated for 1988). *We are continuing to watch these areas closely and will provide the necessary changes and support. Management involvement in ensuring quality in maintenance has continued to grow. Plant management has become more extensively involved; including regularly scheduled material condition inspections. Reaching standards and goals have been established and communicated. On November 4, 1985, our total corrective work order backlog was 1,776 and by April 27, 1987, we had systematically reduced it to 769, in addition to completing over 8,000 emergent work orders of various types. Control Room Deficiencies were reduced from 63 in November, 1985 to just 14 in April 1987, including an additional 223 emergent Control Room Deficiencies which were worked OC1087-0187-NL04
Nuclear Regulatory Commission Palisades Plant Response to SALP 7 Report October 30, 1987 off. During that same time frame we instituted a comprehensive valve improvement program. Both plant and senior management have been actively involved in the development of a realistic 5-Year Plan. 4 We are committed to actions and improvements which will make the Palisades Plant a top performing facility. We also believe in the necessity of continually monitoring the effectiveness of our efforts to prevent compla-cency. Development of a Configuration Managemeut Prograw is past the organizational phase with personnel on site working on specific projects. A comprehensive preventive maintenance program and an equipment perform-ance trending program have both been implemented and are undergoing refinements on an as-needed basis. Improvement to the material condition of the plant, specifically the support facilities, has become an integral part of the 5-Year Plan. Our 1987 Goal of having less than 300 active corrective work orders in our backlog is nearing achievement. On January 5, 1987 we had 660 active corrective Work Orders and as of October 26, 1987, had worked this number down to 373, despite having gone through a series of forced outages and are currently finishing up a 45 day scheduled maintenance outage. In September of this year, we completed our fourth consecutive month of obtaining our year end goal of a greater than 35% ratio of preventive to total maintenance. Our overall goal is to improve in each of the areas of the SALP Report commented on and sustain the progress we have made during the latter part of the evaluation period. D. Surveillance It is our expectation that the Augmented Test Program will lead to improved plant performance and reliability as well as improving our SALP rating in this functional area. The initial program will be based on testing requirements identified by the System Functional Evaluation but will also allow for addition of test requirements based on plant performance and experience, The Augmented Test Program is to be established and implemented and placed under the control of the Technical Specification Surveillance Program Administrator. E. Fire Protection The Company has made progress in improving the overall fire protection program at Palisades, primarily through a major effort to upgrade plant housekeeping, and by the appointment of a full-time fire protection supervisor to administer the program.* Problems early in the assessment period with non-inspected fire extinguishers were resolved, and actions have been taken and additional actions are planned to address problems with inoperable fire doors and flow switches noted near the end of the assessment period. The inoperable fire doors generally resulted from either workmen improperly blocking doors open to support maintenance activities, or from failure of the doors to close completely due to room ventilation differences. Training and communication efforts, including OC1087-0187-NL04
\\. Nuclear Regulatory Commission Palisades Plant Response to SALP 7 Report October 30, 1987 5 the posting of more descriptive fire door signs, have been undertaken to reduce the occurrences involving improperly blocked open doors. The door closure problems have been discussed with the engineering department and resolutions are under evaluation~ Potential solutions include the instal-lation of audible and visual alarms when doors are ajar or installation of power operated door. The flow switch failures seen toward the end of the assessment period were attributed to wear-out, and a periodic replacement program has been developed to ml.nimize any future operability concerns, F. Emergency Preparedness Examples of Consumers responsiveness to issues and continued management attention can be found in the area of emergency shift augmentation capa-bilities. Three telecomputers have been purchased and testing is in progress. As a result of the April 1987 NRC inspection, licensee manage-ment committed to conducting two more drills within a six months period to demonstrate the plant's capability to achieve the minimum shift augmenta-tion. These were successfully held June 22, 1987, and September 15, 1987. Additional Health Physics Technicians have also been trained and added to the augmentation list since the NRC inspection. Since the 1986 exercise, coordination between the Technical Support Center (TSC) and Plant Security has been enhanced by adding Security to the TSC organization. Practice drills and exercises have demonstrated this improvement and will be demonstrated again during the evaluated exercise in February 1988. G. Security Consumers Power Company has been aggressive over the SALP 7 assessment period in upgrading the security program effectiveness. As noted in the report, actions have been taken to increase staff and substantially upgrade facilities. While the contract negotiations between our security contractor and the guardworkers union caused some unrest during the period, guard force performance and morale indicators showed substantial overall improvement. For example, guard force turnover dropped from 37% in 1985 to less than 6% in 1987, and while there were 9 lost time acci-dents in the guard force in 1985, there have been none in the first three quarters of 1987. In addition, there has been a 73% reduction in Security Deficiency Reports from 1986 to 1987, and recent NRG and company audits of the security program have resulted in no significant findings. Nevertheless, there remain some areas where additional performance improve-ment is necessary. One area of concern over the SALP period was control of safeguards information. Action taken to address this area includes a reduction of the number of safeguards storage locations and materials on-site, periodic surveillance of safeguards storage and use locations by the guard force, and a heightened awareness of safeguards information controls.through a communications program. OC1087-0187-NL04
' v Nuclear Regulatory Commission Palisades Plant Response to SALP 7 Report October 30, 1987 A second area of concern was an identified deficiency in the company's reporting procedures for major losses of security effectiveness. The corporate controls have been revised to clarify requirements under 10CFR73.7l(c), and affected personnel have been trained. A third area of concern has been improperly closed vital area doors. While a substantial reduction has been achieved through increased guard force surveillance and employee cowmunicatipns efforts, the solution tc the problem will require substantial engineering effort, and options are currently being evaluated. 6 The SALP Report suggested that "the present gatehouse only meets minimum standards in the operational and administrative needs of the guard force." While a larger gatehouse would be more convenient, the company has no current plans to expand the facility. The facility meets our needs at this time, and we do not feel that its limitations have a detrimental impact on security program effectiveness. H. Outages The company has focused a great deal of effort over the SALP period on improving all aspects of outage performance. In particular, planning efforts have been expanded and accelerated, and the Operations Department has been reorganized to give them a lead role in outage decision-making. In addition, a very formal, deliberate, and conservative process has been employed to define work scope for both forced and planned outages. The Company is currently planning outages approximately a year in advance in order to make best use of scheduled downtime. This planning process includes a thorough review of regulatory commitments which are all moni-tored through our licensing commitment tracking system. A special inspection of our outage planning efforts was recently conducted by the NRC, and the inspectors were very complimentary of the preparations for the upcoming 1987 Maintenance Outage, with only one open item result-ing from the inspection. It is our intention to develop restart plans for future major outages that will be comparable to the restart plan utilized in returning to power in April, 1987. Each restart plan will be developed based upon the scope and duration of the outage and specific objectives that need to be accomplish-ed during restart. I. Quality Programs/Administrative Controls We_have undertaken several programs to find and correct the types of equipment operability issues discussed in this SALP category. Equipment testing has been expanded both on a post-maintenance and periodic basis. OC1087-0187-NL04
Nuclear Regulatory Commission Palisades Plant Response to SALP 7 Report October 30, 1987 7 The importance of assuring that equipment performance meets design stand-ards has been stressed to all levels of the plant staff. This emphasis on operability and safety margin will be continued. Adequacy of corrective actions and minimizing personnel errors have also been addressed in the overall effort to raise performance standards at Palisades during the past two years. Although both of these areas have concerns included in this SALP. The Resident Inspector will be kept informed of our conclusions and any changes. One aspect that we feel will continue to help improve performance at Palisades is the growing stability and training level of staff personnel. We continue to believe that a stable, experienced, and well-trained work force is the major long-term solution to many of the past difficulties at the plant. In summary, we believe improvement in Quality Programs and Administrative Controls has occurred over the last year, but expect to make even more improvement in the future. Consumers Power Company's management recog-nizes the need to protect safety margin and to not erode that margin through analyzing and justifying decreased equipment performance. The Configuration Control Project and the nearly-complete PRA model should provide management the data needed to decide how best to allocate resources to improve plant safety. Coupled with our strong desire to continue improvement of both plant equipment and human performance stand-ards, we expect this SALP category to improve. J. Licensing Activities The SALP 7 Report summation of future licensing activities indicated the NRC'~ expectation that the backlog of licensing actions will be reduced. This will require a concerted effort by both Consumers Power Company and the NRC staff. We agree with the importance of reducing this backlog and will endeavor to provide timely and comprehensive submittals on the priority issues that we have discussed with the NRC Palisades Project Manager. K. Training and Qualification Effectiveness To improve the interface between the plant, Nuclear Training and Skills Training, Training Revision Tracking Committees (TRTC) were established in early 1987, with procedures developed and implemented to govern the committees' duties and direction. The purpose of the committees is to assure that industry and Company experience is evaluated for its effect on the content of training for new employees and existing employees. Items such as vendor bulletins, NRC bulletins and Information Notices, SOERs, Maintenance Department Requests, modifications and corrective action OC1087-0187-NL04
r Nuclear Regulatory Commission Palisades Plant Response to SALP 7 Report October 30, 1987 documents are each assigned an evaluator and due dates for completion of required revisions to training. The Skil~s Training TRTC, for example, has dealt with over 50 separate pieces of operating experience since March of 1987. Thirteen maintenance training lesson plans have been revised to reflect the lessons learned from this experience. It is believed that the TRTC function addresses on a quality level the proper incorporation of industry events along with correc~ive actions into the training programs. This is supported by Quality Assurance audits and recent INPO accreditation of the Mechanical/Electrical, Chemistry/Health Physics and Technical Programs. The SALP Report stated that the "assessment indicated that the requalifi-cation program had improved, and appeared to be more effective. Addition-a;l.ly., an assessment of the licensee's operations personnel training in preparation for restarting the plant resulted in positive findings". We agree with this assessment. In the second quarter of 1987, 92.5% (39 of
- 42) of those who took requalificatibn exams received passing grades.
All eleven taking the NRC administered requalification exam passed. We are pleased with these results and believe they indicate a positive trend in our training program. We believe other indicators of note in the training area are: Completion of INPO accreditation on September 23, 1987. Completion of 145 Simulator Problem Reports (SPR's) through September, 1987 reducing the backlog of SPR's from 222 to 119. Performance tests for simulator certification are being developed. 8 In summary, the SALP 7 appraisal has given us guidance both as to areas that need additional attention and to areas where the Nuclear Regulatory Commission is beginning to see positive results. We appreciate that guidance. The next appraisal period for Palisades will present an opportunity for the Nuclear Regulatory Commission to more properly judge the impact of these efforts to improve performance. We expect that there will be more sustained operation, good performance during planned outages, and a continuation of increasing the performance and condition of the plant and increased professionalism and competence of our staff.
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---p'.7"t.~ * !oe~~ut~ Frederick W Buckman Vice President Nuclear Operations CC Administrator, Region III, NRC NRC Resident Inspector - Palisades 0Cl087-0187-NL04}}