ML18354A643

Response to Initial SALP II Report Covering Period 1/1/1991 - 3/31/1992 for Performance of Maintenance/Surveillance & Security

ML18354A643
Person / Time
Site:	Palisades
Issue date:	06/30/1992
From:	Slade G Consumers Power Co
To:	Office of Nuclear Reactor Regulation
References
Download: ML18354A643 (2)

Text

Enclosure 2 consumers Power GB Slade General Manager POWERING MICHlliAN"S PROliRE55 Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Coven, 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 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 perfor~ance in the areas of Maintenance/Surveillance and Security.

You noted that our performance in Operations had declined, but not enough to lower our SALP rating below a Category 1. Specifically noted were 3 events in the Operati~ns area that were of concern. We had also noted several events near th~ end 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 o~r Nuclear Performance Assessment Group was performed.

That assessment included representation from INPO as an independent observer.

A common thread found by this asses~ment was that most of the events were related 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 maintain strict, early milestones for outage related work. This will ensure adequate time .for technical reviews of ~ctivities with input from multiple disciplines. By strengthening the outage plan fewer impromptu decisions will be forced on the Shift Supervisor and direction for contracttirs will be improved, thus, reducing the chance for inadvertent errors.

We have recently made some staff changes in the Nuclear Operations Department.

Bob Rice, the former Plant Operations Manager, is taking over management of Nuclear Performance Assessment Department (NPAD). His clOse working knowledge A GHS' ENERGY COMPANY

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Enclosure 2 2

of Palisades should help provide even better asseis~ent of our performance,.'

which will help us to continue to improve our management of all functional .

areas. In replacing the 0Rerations Manager we have combined operations and outage man~gement .under Tom Palmisano. This should help us to continue to improve our focus on safety and risk during outages~

We will continue to exercise a conservative and safety-oriented philosophy, building on our strengths in operations and maintenance.

• Controls area. While our ALARA program has started to mature, we need to continue to improve our understanding and implementation of controls over processing and storage of radioactive. materials.

Radiation Controls i.~ an area where we believe we are capable of achieving SALP 1 perfbrmance in the future. We intend to continue to improve performance so we can earn that rating.

Emergency Preparedness is another area where I believe we can re-attain a SALP 1 performance level. We have changed the organization of the Site Emergency Response Teams and will demonstrate the new approach in the emergenty exercise scheduled in Sept~mbef. We are also continuing to improve our ability to call-out additional resources in a timely manner.

In the area of Engineering and Technical Support, we have made substantial*

progress, but still there are examples where continued improvement is called for. W~ have significantly altered our approach such that our Desi~n Engineering resources all report directly to the VP-NOD as you are aware, early in the SALP 11 report period our design engineering resources were relocated to the site. By consolidating the resources and slowing down the rate at which we attempt to implement change, we expect 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 ~hich we are tontin~ing to find as part of our Configuration Control Program. We have strengthened our Safety Related Pipe Reverification Program to address the concerns which you pointed out early in the SALP period.

The movement of 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 performance.

&UP~

Gerald B Slade .

• Genera 1. Manager

. CC Ad~intstrator, Region Ill, USNRC NRC Residerit Inspector - Palisades Attachment .