ML18054B317

Responds to SALP 9 Rept for June 1988 - Aug 1989.Util Will Apply Appropriate Mgt Attention & Priorities to Instrument & Control Training Program,Surveillance Area & Design Control Process in Order to Provide Desired Program Improvement

ML18054B317
Person / Time
Site:	Palisades
Issue date:	12/21/1989
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8912260119
Download: ML18054B317 (4)

Text

• Power David P Hoffman Vice President POWERIN& Nuclear Operations MICHl&AN'S PRO&RESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0453 December 21, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

RESPONSE TO SALP 9 REPORT Your letter dated November 8, 1989, contained the Systematic Assessment of Licensee Performance (SALP) No. 9 Board Report for our Palisades Plant covering the period of June 1, 1988 through August 31, 1989. The letter requested that we respond within thirty days of the SALP meeting which occurred on November 27, 1989 with our written comments on the Report. This letter provides Consumers Power Company's response to the SALP 9 Report.

Consistent with the format of the SALP Report, our response is presented by functional area.

A. PLANT OPERATIONS The SALP report noted an improving trend for the second consecutive SALP.,

This improvement reflected a continued decline in personnel errors and enforcement history, combined with strong management oversight. The Palisades management team will continue to develop and implement aggres-sive objectives to assure this improving trend continues such that perform-ance will support a SALP I during SALP 10. These objectives will specifi-cally focus in the area of procedure improvement, human performance improvement, and training.

The Board specifically pointed out deficiencies in containment cleanliness and auxiliary operator training on EOPs. These deficiencies were pre-viously recognized with planned actions in place. Much effort was spent removing graffiti from painted surfaces in the containment during the 1989 Fall outage. Operations, including Operations management, has taken a much more aggressive role in assuring containment cleanliness expectations are understood and carried out prior to returning the plant to operation from outages. Auxiliary operator continuing on-the-job training upgrade was 'in progress prior to the EOP inspection report. The EOP continuing on-the-job training upgrade for Auxiliary Operators was accelerated as a result of the SALP report.

8912260119 891221 OC1289-0006-NL02 PDR ADOCK 05000255 Q PDC 1I A GW5 ENe?GY COMPANY

')

Nuclear Regulatory Commission Palisades Plant Response to SALP 9 Report

• 2 December 21, 1989 B. RADIOLOGICAL CONTROLS

-The SALP report noted some weaknesses in the Radiological Controls program primarily in control of high radiation areas, contamination control and a continuing problem with high personnel exposure relative to other plants.

Action is underway in these areas to correct th~ problems identifi~d.

Significant progress has already been made in reducing personnel contami-nations to near the industry average. A major effort is underway to reduce overall plant "source term" which will correct the root cause of the high personnel exposure relative to other plants. Proj~cts have been initiated to significantly reduce radiation exposure following the steam generator replacement outage in 1990. Our intent is to continue to make progress in SALP 10.

C. MAINTENANCE/SURVEILLANCE Palisades continues efforts toward effective maintenance, placing heavy emphasis on improvement programs such as valve improvement, instrument upgrade, preventive maintenance and boric acid leak walkdowns. The plant has embarked upon a Reliability Centered Maintenance Program, intended to reinforce the preventive maintenance program with emphasis upon components important to plant operation.

The plant acknowledges a weakness in the Instrument and Control Training Program. Efforts have been ongoing to enhance the existing program with advanced system training, providing the technicians with knowledge of system logic interfaces. The improvements already made in the training programs were sufficient to permit them to be re-accredited by INPO and further improvements are planned for 1990. A program for contractor qualification has been implemented, to ensure that individuals performing work at Palisades are adequately trained.

Strong management attention will continue in the Surveillance ~rea. The levei of involvement by the Surveillance Program Coordinator will continue to emphasize a detailed and comprehensive overview of the surveillance program. We believe that such emphasis wiil maintain the momentum of our recent achievement and lead to further surveillance program improvement.

D. EMERGENCY PREPAREDNESS Palisades appreci~tes the recognition in the SALP 9 report of the accom-plishments in Emergency Preparedness. Our intent is to continue to maintain a SALP 1 rating in this area in the future and to commit the resources needed to. maintain our current level of emergency preparedness.

E. SECURITY Consumers Power Company is very pleased that.the NRC has recognized the continued excellent performance in the security area. The active involve-ment of Plant management, the leadership provided by the Property Protec-tion department, the performance of the security officers, and our excellent OC1289-0006-NL02

Palisades Plant Response to SALP 9 Report Nuclear Regulatory Commission

• 3 December 21, 1989 relat2onship with NRC region personnel have all contributed to the. con-tinued performance level in this area. We are continuing to look for ways to improve our performance and to prepare for the upcoming Steam Generator replacement outage.

F. ENGINEERING/TECHNICAL SUPPORT Palisades management will continue an emphasis on engineering support.

Engineering involvement in operational events is essential to ensure reliable operation of the plant. Emphasis will continue to be placed on resolving issues on the Operations Concerns List which is a Operations prioritization of plant problems *

.Palisades recognizes a weakness in the design control process and has undertak~n efforts to improve it. We have recently completed a major reassessment and revision to our design control program to clarify respon-sibilities and requirement.s and are now concentrating on effective program implementation and results. Periodic design control meetings with the engineering teams are held, emphasizing attention to detail. Enhancement to the design control procedures to effect greater attention to detail and to provide further clarification regarding how to implement stated requirements are in progress. Engineering guidelines, which are subordinate to the design control procedures, are being developed to give detail steps as to how the design procedures should be met and to give a consistent interpretation and implementation of design control requirements and practices.

G. SAFETY ASSESSMENT/QUALITY VERIFICATION One important aspect of improvement in plant conditions and programs at Palisades is providing additional management time for areas such as those referenced in this section. Additional attention will be placed on thorough completion of corrective actions in a timely manner. Regarding licensing submittals, we believe the quality and other issues will be improved through a more structured approach to modifications. Implemen-tation of the design control process will be examined accordingly.

In the safety assessment area, we feel we have initiated a major improve-ment in the safety review process through the changes noted in this SALP section. We will continue to emphasize this area as one of the most important in ongoing plant operations.

OC1289-0006-NL02

___ J Nuclear Regulatory Corrnnission 4 Palisades Plant Response to SALP 9 Report December 21, 1989 In surrnnary,- the SALP 9 appraisal has acknowledged where our efforts over_the last reporting period have improved performance and has given guidance where add-itional effort on our part can result in positive results. This guidance which will help us realize our performance goals is appreciated. Palisades now has the opportunity to put forth the required effort in those areas of identified weakness to see positive results. We will apply appropriate management attention and priorities to the Instrument and Control Training Program, surveillance area, design control process and the licensing submittals in order to provide the desired program improvement. Management attention to programs that have improved performance will continue to assure they remain effectively implemented.

_David P Hoffman Vice President Nuclear Operations CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades

'I 0Cl289-0006-NL02