ML18065A603
| ML18065A603 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/02/1996 |
| From: | Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9604080219 | |
| Download: ML18065A603 (3) | |
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- consumers Power POWERING MIUllGAN-S PIUIGRE5S Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 April 2, 1996 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT MANAGEMENT OVERSIGHT OF PLANT ACTIVITIES Thomas J. Palmlsano Plant General Manager NRC Integrated Inspection Report 50-255\\95014, issued on February 6, 1996, identified several examples of weak management oversight in some operations, maintenance, engineering and plant support activities at Palisades. That inspection report requested that we inform the NRC in writing, within 45 days, of the actions we have taken to ensure there is effective management oversight of plant activities. With the concurrence of the NRC Palisades Plant Senior Resident Inspector, the response time was increased to 60 days. This letter provides the requested information.
We agree that the conditions identified as examples of weak management oversight of some operations, maintenance, engineering, and plant support activities contributed to performance errors in certain cases. In a broad sense, however, the cause of the weak management oversight examples fall into two categories:
- 1.
A failure to adequately monitor and report accurate status.
The lack of wide dissemination of operator workarounds, the lack of adequate temporary modification information, and the lack of an integrated evaluation of the possible effect of the Fire Protection Plan compensatory measures fall into this category.
- 2.
A failure to ensure that expectations were clearly understood and followed.
The lack of regular safety meetings and the radworker practice issues fall into this category.
9604080219 960402 PDR ADOC~ - 0.5000255 I *.
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2 Although we have made significant progress over the last two years in the area of management oversight, the identified examples clearly show the need to continue to improve. As you know, we implemented a significant reorganization in the fall of 1995.
We anticipated this would have some effect on performance due to changing roles and responsibilities, and we believe the oversight weaknesses are a result of that effect. The organization is now stable and performance has continued to improve.
The original Palisades Performance Enhancement Plan contained significant action plans to improve the adherence to standards and expectations, the effectiveness of management monitoring, and the effectiveness of management involvement in plant operations. The PPEP is being revised to continue to drive the improvements in these areas. The specific examples of weak oversight identified by your inspectors and ourselves have been considered in the ongoing revision of the PPEP.
Specific actions which have been taken on the examples cited in the inspection report include:
- 1.
Operator workarounds are now clearly identified, communicated, and tracked by plant management on a regular basis.
- 2.
Expectations for industrial safety performance have been discussed with all employees. Significant management attention is being placed on the industrial safety program to ensure compliance with expectations.
- 3.
Radiation worker practices are receiving significant management attention.
Radiation dose and radworker practice issues are reviewed daily at the morning
- meeting.
- 4.
Temporary modifications have been reviewed and updated by engineering. The status of temporary modifications is reviewed monthly as part of the Performance Monitoring Program. The number of temporary modifications has been reduced by 50% in 1995 and 1996.
- 5.
The cumulative impact of Fire Protection Plan compensatory measures on plant operations has been assessed.
In addition, the more widely applicable and valuable lesson to be learned -
that of evaluating the cumulative effects of groups of singularly acceptable deficiencies on all phases of plant operation -
will be reviewed with all engineering personnel as part of continuing training.
3
SUMMARY
OF COMMITMENTS This letter contains one new commitment. It is that the importance of evaluating the cumulative effect of groups of singularly acceptable deficiencies as they apply to all phases of operation will be included as part of Continuing Training for Engineering Department Personnel.
Thomas J Palmisano Plant General Manager CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades