ML18058A947
| ML18058A947 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/30/1992 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9207070007 | |
| Download: ML18058A947 (2) | |
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consumers Power 11111"" PllWEIUNli MIClllliAN-S PIUllillBS Palisades Nu~lear Plant: 27780 Blue Star Memorial High~y. Covert. Ml 49043
.June 30, 1992 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO INITIAL SALP 11 REPORT G BSlada General Manager We have.reviewed your initial SALP 11 Report covering the period form January 1, 1991 through March 31, 1992 and agree*with your assessments.
We appreciate your recognition of our continued good performance in the areas of Maintenance/Surveillance and Security.
You noted that our performance in Operations had declined, but not eno~gh to lower our SALP rating below a Category 1. Specifically noted were 3 events in.
the Operations area that were of concern.
We had also noted sev~ral events near the ~nd of the SALP period (many of which are discussed in the report details) under Operations and Maintenance which are of concern to us.
Because of the number of events in a relatively short period of time, a
. special assessment by our Nuclear Performance Asse*ssment Group was performed.
That assessment included representation from INPO.as an independent observer.
A common thread found *by this assessment was that most of the everits were rel~ted to emergent work that was identified during the outage or shortly before the outage started. The recommendation from that report which I consider the most significant is to establish and maintairr strict, early milestones for otitage related work.
This will ensure adequat~ time for
- technical reviews of activ1ties with input from multiple disciplines.
By strengthening the outage pl~n fewer impromptu decisipns will be forced on the Shift Supervisor and direction for contractors will be improved, thus, reducing the chance for i nadverten.t errors..
We have recently made some staff changes in the Nuclear Operations Department.
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Bob Rice, the former Plant Operations Manager, is taking over management of
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Nuclear Performance Assessment Department (NPAD).
His close working knowledge~/ V PALISADES l\\.
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of Palisades should help provide even better assessment of our performance,.
which will help us to continue to improve our management of all functibnal areas.
In replacing the Operations Manager we have combined operations and
. outage management under Tom Palmisano. This should help us to continue to improve our focus on safety.and risk during outages.
We will continue to exetcise a conservative and safety-oriented philosophy,
- building on our strengths in operations and maintenanc~.
We are aware that there is stil.1 room for improvement in the Radi~logical Controls area.
While our ALARA program has started to mature, we need to continue to improve our understanding and implementation bf controls over processing and storage of radioactive materials...
Radiation tontrols is an area-wher~ we believe we are c~pable of achievtn~
SALP 1 performance in the future.
We intend to continue to improve performance so we can earn that rating.
2 Emergency Preparedness is another area where I believe ~e can re-attain a SALP 1 pefformance level.
We have changed the organization of the Site Emergency Response Teams and will demonstrate the new a*pproach in the emergency exercise scheduled in September.
We are also continuing to improve our ability to call-out additional resources in a timely manner.*
In th~ ar~a of Engi~e~ring and Technic~l Supp~~t, we hava made substantial progres~, but still there are examples where continued improvement is called*
for.
We have significantly altered our approach such th~t our Design Engineering resources all report directly to the VP-NOD as you ~re aware, early in the SALP 11 report period our design engineering resources were reloc~ted to the site.
By consolidating the resources and slowing down the rate at which we attempt to implement Change, we e*xpect to get closer control
- over design activities.
As you point out in your report, many of the significant issues identified during this SALP period are related to past problems which we ar~ continuing to find as part of our Configuration Control Program.
We have strengthened our Safety Related Pipe Reverification Program:
- to address the concerns whic~ you pointed out early in the SALP period.
The movement ~f the simulator to the-site has helped to improve our license training effectiveness which.was demonstrated by 100%-pass* rate during-the-*
assessment period.
We look forward to continuing to work with you and your staff to continue to find ways to improve our performarice.
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Gerald B Slade General Manager CC Administrator, Region Ill, USNRC NRC Resident Inspector. - Pa 1 i sades Attachment*