ML18067A699

Ack Comments in NRC Insp Rept 50-255/97-06 on 970709. Improvement in Areas of Procedural Deficiencies & Plant Material Condition Are Underway

ML18067A699
Person / Time
Site:	Palisades
Issue date:	10/01/1997
From:	Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-97-06, 50-255-97-6, NUDOCS 9710060451
Download: ML18067A699 (2)

Text

A CMS Energy Company no-r.r....a..

Manager Licensing October 1, 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255- LICENS~ PPR PALISADES PLANT ACKNOWLEDGMENT OF NRC COMMENTS IN NRC INSPECTION REPORT 50-255/97006(DRP)

NRC Inspection Report 50-255/97006(DRP) dated July 9, 1997, contained cover letter comments that continued attention was needed in the areas of procedural deficiencies and plant materiel condition. We concur with your comments and have actions underway to improve in both of these areas.

With respect to procedural deficiencies, we believe that we have made significant improvements over the last several years and that continued improvement will be maintained. As discussed between Mr. Burgess (NRC) and Mr. Rogers (Consumers Energy), we believe the examples used to develop the conclusion conveyed in the aforementioned inspection report are dated and are not indicative of our current procedures. One significant improvement made in the procedure change process is the development of the Palisades Procedure Change Request System. This system allows us to track and status information about requested procedure changes. These changes can be linked to milestone events, corrective action documents, or modifications to ensure they are completed in a timely manner. In addition, the initiator of the changes can access the system to determine the status of their requested changes. However, we recognize that our procedures are not at the level-of-exeelleAee---~----- -

we de-sTre and plan to continue our efforts to improve them further.

In regards to the materiel condition of the plant, we concur that the materiel condition has not yet been raised to our current standards and are instituting a program to promote continued improvements. Our Maintenance Department has assumed the

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Now (FIN) Team Supervisor has been designated as the leader of this effort. The FIN Team has been redesignated as the Materiel Condition Fix It Now (McFIN) Team to clearly identify its new responsibility as the lead organization. A supervisory position

• has been added to the McFIN Team to align with its added responsibilities.

The initial focus of the McFIN Team will be in the safety related areas. Therefore, we have chosen the Diesel Generator rooms as our starting point. We are also exploring other industry applications through INPO and EPRI to learn new ways to improve and maintain materiel condition. We are reviewing EPRl's Nuclear Maintenance Application Center programs to learn more about leak reduction techniques and how we can minimize the number of leaks at the plant.

In the body of the inspection report, two specific example areas were cited which reflect on the plant materiel condition. These two areas were the number of catch containers used to collect component leakage and the number of hot spots throughout the plant.

We are targeting specific improvements in these two areas. First, a new monthly tracking and trending report, "Auxiliary Building Catch Container Report", has been developed to enable us to status, trend and track catch containers. Presently, all leaks which have catch containers installed have been scheduled for permanent repairs.

Secondly, the Palisades Hot Spot Program reviews, statuses and tracks the hot spots in the plant. Hot spots are evaluated for opportunities for removal through planned system outages and maintenance activities. However, in some cases, hot spot removal would require more dose than is presently estimated to be received with the hot spot in place. Therefore, these hot spots will be monitored until removal techniques are available which would be more dose effective.

In summary, our program for improving procedural deficiencies has been underway for several years and is having a positive impact on our procedures. Our program for improving the materiel condition of the plant has received focused management support and is expected to make a positive impact within the next few months.

SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

CC

• Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades