IR 05000222/2004012

Insp Rept 50-255/95-04 on 950222-0412.Violations Noted.Major Areas Inspected:Cr Habitability,Esfs,Onsite Event Followup, Fuel Loading of multi-assembly Sealed Basket,Audits of Fire Protection,Security Self Assessment,Afs & Maint Activities

ML18064A792
Person / Time
Site:	Palisades, 05000222
Issue date:	05/19/1995
From:	Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18064A790	List: IR 05000222/2004012 ML18064A789 ML18064A791
References
50-255-95-04, 50-255-95-4, NUDOCS 9506050097
Download: ML18064A792 (29)

Text

.,.

~...*

U.S. NUCLEAR REGULATORY COMMISSION REGION I II Report No. 50-255/95004(DRP)

Docket No. 50-255 License No. DPR-20 Licensee:

Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:

Pal-isades Nuclear Generating Facility Inspection At:

Palisades Site, Covert, Michigan Inspection Conducted:

February 22 through April 12, 1995 Inspectors:

M. E. Parker T. J. Madeda E. W. Cobey Approved By:

w. Reactor Inspection Summary D. G. Passehl R. M. Lerch F. A. Maura 2A Inspection from February 22 through April 12, 1995 (Report No. 50-255/95004CDRPll Date r, Areas Inspected: Routine, unannounced safety inspection by res*i dent and regional inspectors on control room habitability, engineered safety feature systems, onsite event followup, fuel loading of multi-assembly sealed basket, current material condition, housekeeping and plant cleanliness, independent safety review committee, audits of fire protection, security self assessment, condition reports, maintenance activities, preventive maintenance for oil changes, surveillance activities, engineering management, engineering support, auxiliary feedwater system, packing configuration control, *Rosemount transmitters, 10 CFR 50.59 Safety Evaluations, Alloy 600 Project, fire protection program, radiological controls, security, report review, and of action on previous inspection finding Results: Within the 24 areas inspected, no deviations or inspection followup items were identified in 22 areas. Three violations were identified that pertained to:

inadequate control of combustible material in a stairwell (paragraph 5.1.1.1) and the failure to test some fire extinguishers as required (paragraph 5.1.4); an inadequate technical analysis and review of a modification package for establishing a setpoint in the auxiliary feedwater system (paragraph 4.3.1); and the failure to report a physical altercation 9506050097 950519 PDR ADOCK 05000255 Q

PDR

that was witnessed by numerous security personnel (paragraph 5.3.1). Three inspection followup items were identified that pertained to: surveillance acceptance criteria (paragraph 3.3); packing configurations (paragraph 4.4);

and cylinder leakage testing (paragraph 8.0).

One unresolved item was identified that pertained to fire walls (paragraph 5.1.1.2). The following is a summary of the licensee's performance during this inspection period:

Plant Operations The licensee's performance in this area was adequate. Overall material condition of the plant was considered adequat The plant operated at full power throughout most of the inspection perio The inspectors identified several concerns with communication First, a system engineer, aware of lost Tygon sample tubing in a charging pump, did not take the necessary steps to notify the operating authority nor plant managemen Also, there was ineffective communication between shift personnel that contributed to a breach of containment. A previous operators requalification inspection (50-255/95006) also identified an issue with operations crew communications..

Housekeeping and cleanliness was considered adequat The inspectors identified a housekeeping concern with the condition of the containment tendon galler The inspectors found s~veral inches of standing water in the galler However, there were no radiological or material concerns identified.

Safety Assessment/Quality Verification The licensee's performance in this area was adequate.

. The inspectors identified that there appeared to be a disparity in the quality of self assessments/audits between department Engineering self assessments were thorough and identified good issues that need to be addressed by engineering.. However, recent self assessments/audits in the security and tire protection areas appeared to lack the same rigor as the engineering self

~

as~essmen The inspectors revi~wed the licensee's corrective action process and identified the following concerns:

The ability of security management to correct weaknesses was mixed.

Corrective action for a previous NRC violation was thorough and comprehensiv However, in the area of implementing effective search activities, managements' action was not totally effective. There were also isolated examples of untimely licensee actions in resolving issues with agility testing and alarm performanc Several condition report evaluations were incomplete and in some cases inaccurate.

Documentation for operability determinations associated with two condition reports lacked a clear and logical justification with a sound engineering basis to support the conclusio There was one instance identified where a condition report (CR) was not issued for a potential equipment problem (oil sample tubing in charging pump) until maintenance found the tubing and initiated the C Maintenance and Surveillance The licensee's performance in this area was adequat The inspectors noted that plant operators had not initiated steps to update the preventive maintenance document*for oil changes on the containment spray pump Also, the inspectors noted that system engineers do not review completed preventive maintenance performed by plant operator The licensee discovered Tygon tubing pieces in charging pump P-55 Maintenance brought this condition to the fmmediate attention of managemen This was indicative of good communications between maintenance and other department Engineering and Technical Support The licensee's performance in this area was adequate. A number of management actions were taken in the last year which improved performance in engineerin These have been effective in clarifying lines of communication, responsibilities, and expectation However, there were concerns identified with several modifications including a violation that identified an inadequate engineering analysis and technical review Another concern was identified when proper admiriist~ative controls were not used for a modification to a vacuum drying skid for dry fuel.storag *A previous inspection report al~o identified a concern with a temporary

modificatio The inspectors were concerned with the quality of ongoing modification activitie *

Plant Support The licensee's performance in the area of security, fire protection, and radiological protection was adequat Overall, security performance was adequate and the program provided the necessary level of protection to the facility. Security support for maintenance and dry cask fuel storage activities was identified as program strength *

However, a violation was issued for failing to report a physical altercatio A weakness in the licensee's training program regarding the identification of an example of atypical behavior contributed to the cause of this violation.

-*

The violation was a concern because numerous security personnel witnessed and failed to report the altercatio Fire protection was adequate with good training for the fire brigad One violation was identified for inadequate storage control of combustible material in a stairwell and the failure to test some fire extinguishers as require The inspectors reviewed the radiologica1 survey for Ventilated Storage Cask number 11 and found no problems.

..

~

~{

='**

DETAILS

• Plant Operations (71707, 71750, 93702) Control Room Habitability.3 On March 14, 1995, the licensee identified that only three of the required eight self contained breathing apparatuses (SCBAs) were staged and available in the control room in the event of a toxic gas releas The licensee initiated a condition report and provided an additional five SCBAs to the control roo In reviewing the licensees actions, the inspectors noted that eight SCBAs were staged to ensure that the operating crew (six crew members and two spares) could safety operate or shutdown the nuclear power plant under design basis accident condition The inspectors questioned the adequacy of eight SCBAs, as the licensee

• has increased the operating crew by providing an additional SRO on-shift within the last yea The licensee has agreed to provide additional SCBAs to the control room envelope to support the additional shift mannin In addition, the licensee has questioned the basis for providing SCBAs to the control room envelope, and intends to re-evaluate

• the need for SCBAs to satisfy any design basis accident condition Engineered Safety Feature CESFl Systems

• During the inspection, the accessible portions of the Emergency Diesel Generator Trains A and B and Auxiliary Feedwater Trains A were walked dow Minor deficiencies were identified to the license Onsite Event Follow-up 1.3.1 Spurious Actuation of the Left Channel Load Sequencer On March 2, *1995, The licensee reported a spurious actuatiorr of the left channel load sequencer. Overall operator response was goo The spurious actuation resulted in simultaneous actuation of several *

engineered safeguards components {associated with the left channel only). There was no emergency core cooling system injection into the reactor coolant syste Safety injection pumps ran for approximately seven minutes before they were secure However, concentrated boric acid was injected through the charging system into the primary coolant syste As a result, reactor power decreased to 91 percent. All systems were restored to a normal lineup shortly after initiation of the event..

Plant operators declared the sequencer and the associated emergency diesel generator {EOG 1-1) inoperable. Plant technical staff then removed the sequencer, verified the software and performed a functional test. The technical staff found no problem The licensee began a more in-depth evaluation with the vendor on the original sequence. '

• \\.

.

. -*--*

...

1.3.2 Breach of Containment On March 7, 1995, the licensee reported a breach of containment integrity that lasted approximately 2 minute The inspectors determined that the on shift crew had made a poor operability judgement of containment when the containment inner door failed to pass its leak test. The consequences of not immediately recognizing the impact on containment integrity led to several challenges of other Technical Specification Limiting Condition for Operation Action Statement The inspectors also determined that a contributing cause to of the failure of the inner door was a long standing mechanical problem with the closure mechanism that had existed at the time this event occurre Subsequently, the closure mechanism was repaire Technical Specification 4.5.2.C.3 required that if one of the containment doors is inoperable, the other door is to remain locked closed and must be tested within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to ensure compliance with the leakage.limit. However, shortly after discovering that the containment inner door had failed the leakage test,.the control room supervisor ordered an auxiliary operator to enter the containment outer door to try to further close the inner doo Containment integrity was violated when the auxiliary operator opened the outer doo Upon realizing that a mistake was made~ the shift supervisor had the auxiliary operator exit the personnel airlock and re-close. the outer doo Plant operators then satisfactorily tested and locked the outer door, thus fulfilling the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> requirement of Technical Specification

\\ 4.5.2.C.3. The licensee then initiated repairs on the inner doo Technical Specification 4.5.2.C.3 also required that repairs be initiated immediately to ensure conformance with Technical Specification 4.5.2.b.l. The licensee initiated immediate repairs to the inner door by entering containment through the emergency airlock. Subsequent repair and testing of the inner door were completed satisfactorily a short time later within the allowable time fram The transit through the escape airlock necessitated entry into Technical Specification 4.5.2.a (2) to satisfactorily test the escape lock door seals within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This test was likewise completed satisfactoril The licensee declared both airlock penetrations and associated doors operable on March 7, 1995,.within the allowable time fram.4 Fuel Loading of Multi-Assembly Sealed Basket lMSBl #11 (60846)

The inspectors observed the following licensee activities associated with the loading of MSB #1 Access control and radiological controls were very good during all phases observe *

Loading of the MSB and licensee verification of fuel bundles and location in the MSB;

Installation of the shield lid onto the MSB;

• --*

Movement of MSB Transfer Cask out of the spent fuel pool into the washdown pit;

Decontamination of the MSB Transfer Cask and MSB;.

Vacuum drying, welding, and helium backfilling of the MSB;

Transporting the MSB and Ventilated Storage Cask (VSC) to the storage pa.5 Current Material Condition Overall the material condition of the plant was adequat The licensee identified one deficiency associated with Charging Pump P-55 Maintenance workers discovered pieces of plastic tubing inside the crankcase of the pum The tubing was found while the pump was being disassembled for repackin The licensee determined that the tubing was introduced into the crankcase, while the pump was running and an oil sample was being taken (see paragraph 2.4.2 of this report).

Housekeeping and Plant Cleanliness The inspectors identified one housekeeping concern with the condition.of the containment tendon gallery. During a plant tour, the inspectors opened a flood door to assess condition of the containment tendon gallery and found several inches of standing wate Some grease was present that appeared to have dripped from the tendon end caps loca~ed near the ceiling. The flood door provided one access to the tendon gallery that the licensee uses for containment tendon inspection No other plant equipment was located in the gallery. The licensee pumps out the area on an as-needed basis, at least every refueling outage for inspection purpose The inspectors followed up to assess whether a radiological or a material concern existe The inspectors found no radiological concern, based upon the most recent sample results. The sample* results indicated no contamination was presen The licensee determined that the source of the water was either ground or rain water that had seeped through an external hatch cove.0 *Safety Assessment/Quality Verification (40500 and 92700) Independent Safety Review Committee (ISRCl On March 16~ 1995, the inspectors attended a portion of the licensee's ISRC Meeting 95-01 held by the Nuclear Performance Assessment Department (NPAD).

Issues were thoroughly discussed by NPAD staff. Licensee personnel were well-prepared to discuss their respective topics. Also,

• the inspectors confirmed that the ISRC meeting met the requirements of Technical Specification 6.5.2.4.3. Tha inspectors attended discussions on the following topics:

• -...

.

~*

Upper Guide Structure/Stuck Bundle Event During The 1993 Refueling Outage

Control Rod Uncoupling Failure During The 1993 Refueling Outage

Cooldown Event of September 1993

Design Basis Accident Sequencer Actuation of March 1995 Some followup actions for these issues were still incomplet.2 Audits of Fire Protection NPAD audits were detailed and thorough with adequate staff hours devoted to each audi The audits included good findings and in some cases made recommendations to improve the fire protection progra However, the NPAD audit group was not aggressive in ensuring effective corrective action had been assigned.and accomplished to prevent recurrence of conditions adverse to qualit For example, the fire extinguishers issue was similar to findings in the two most recent NPAD Fire Protection Program Audits, PA-94-36 and PA-93-1 The following audits were reviewed:

Fi re Protection Program Audit, PA-94-32, January 11, 1995

Fire Protection Program Audit, PA-93-17, October 15, 1993

Fire Protection Program Audit, PA-92-21, October 15, 1992 Security Self Assessment The inspectors concluded that previous corrective measures were not totally effective for supervisory monitoring of protected area search activities. Previous weaknesses were noted in Inspection Report 50-255/94005{DRSS).

Corrective actions included supervisory overview during periods of heavy personnel traffic and additional personnel to monitor program and personnel search activitie The inspectors reviewed a recent self assessment of securit The assessment results identified 12 deficiencies involving search personnel failures to properly implement procedure requirement The deficiencies included examples of weak or lack of supervisory overview of search activities, reduced officer effectiveness in monitoring personnel search activities and on several occasions, packages search being minimally effective. During this inspection the inspectors observed on one occasion a lack of supervisor overview during a period of heavy personnel traffic and on several occasions; individuals self-identifying hand-carried packages that required a followup physical searc.4 Condition Reports The below concerns are further addressed in Section 8 of this report under Inspection Followup Item 50-255/94014-7..

. '

2.4.1 Fire Protection The inspectors discovered that 89 portable fire extinguishers were not properly maintained since at least February 199 The licensee initiated Condition Report C-PAL-95-0244 to determine the appropriate root c~use and corrective actions. This condition report addressed FPIP-5, "Requirements for Inspection and Testing of Fire Protection Systems and Fire Protection Equipment," Section 5.5.2.b. FPIP-5 states that the specified annual inspection/recharge of fire extinguishers was a "recommended good practice." However, the evaluation did not address that the inspection and maintenance of portable fire extinguishers was a license condition and was not optiona Further, the evaluation did not include the possibility of other license condition requirements being implemented as "recommended good practices" vice as requirements. Also, this condition report was not marked as significant as required by Administrative Procedure 3.03, Section 6.5.2, which circumvented at least one level of management review which may have identified and pursued these issues. This is an area that should have been identified by the fire protection self-assessmen '

In response to an inspector's concern about storage of material in a stairwell (see paragraph 5.1.1.1 of this report), the licensee initiated CR C-PAL-95-024 The CR identified that the area under the stairs was being used as a staging area since October 20, 199 The inspector had the following concerns with this CR:

The CR only addressed fire retardant wood and metal framing and did not discuss the other combustibles stored in the stairwel *

The CR did not address that the Fire Protection Supervisor could have granted a procedural exemptio *

The CR indicated that the material was in the process of being removed from the stairwell even though the material was actually removed after the inspector raised the concern with licensee managemen *

Although several corrective actions were planned, the CR concluded that the condition was~acceptable and that the root cause and corrective action Sections of the evaluation were not applicabl *

The CR was identified as nonconsequential vice significant which resulted in at least one management level review being bypassed which c*ould have resulted in the identification of the preceding concern. '

• ,...

'

2.4~2 Engineering During oil sampling for a charging pump, tubing used to obtain the oil sample broke off when the tubing was caught in the pump's

,gears. The person performing the sampling reported the broken tubing to the charging system enginee However, no condition report was issued by the system engineer to document the operability decision, including the basis for the decision.. The system engineer unilaterally determined that no damage would occur and that the pump would remain operabl The system engineer planned to have the tubing removed at the next opportunity when the pump was disassembled for repacking.

. The licensee counselled all the system engineers that a condition report should have been initiated so that management would have been aware of the issu In addition, a condition report would have allowed Operations Department personnel to make the final operability determination. A condition report was initiated for this* event later when the broken tubing was discovere The inspectors did not identify any instances where a CR was not written for a significant condition adverse to qualit The documentation for the operability determinations associated with C-PAL-94-0794 and C-PAL-95-0053 lacked a clear and logical justification with a sound engineering basis to support the conclusiQn For example, the operability determination associated with C-PAL-94-0794 concluded that the auxiliary feedwater system was operable even though auxiliary feedwater valve M0-0759 was degrade Further review found that the valve had been tagged in its safety position. *However this condition report did not adequately reconcile how the system remained operable or how this valve was operable but degraded while it was tagged and not to be operate No violations, deviations, unresolved, or inspection followup items were identified in this are.0 Maintenance/Surveillance (62703, 61726) Maintenance Activities Portions of the following maintenance activities were observed or reviewed:

Work Order 24412157, "Load and Transport Dry Fuel Storage Cask VSC-11 to Storage Pad Per FHS M-32 and FHS-M-23."

• Work Order 24510900, "Adjust Inner Door Lower Latch Brackets on Personnel Airlock MZ-19."

• Work Order 24510590 and TM 95-019, "Repack Charging Pump P-55A with Titanium Nitrated Coated Plungers."

• • *

Work Order 24510591, "Repack Charging Pump P-55A and Remove Titanium Plungers."

Maintenance workers appropriately identified and reported the pieces of plastic tubing inside the crankcase of charging pump P-55 For further details see paragraph 2.4..2 Preventive Maintenance for Oil Changes The inspectors found a discrepancy between the amount of oil specified in the preventive maintenance document (PPAC) for containment spray pump oil changes (X-OPS310), and what operators actually add to the pum During a recent oil change of containment spray pump, P-54A, plant operators added 4.5 bubblers of oil. During the previous oil change in April 1994, operators added 6 bubbler The PPAC specified 5 bubbler Similar quantitative discrepancies existed with the motor-end motor bearing and pump bearing as wel The inspectors expressed a concern that plant operators had not identified the need for the PPAC document to be update The system engineer stated the PPAC for P-54A would be revised to sp~cify the correct amount of oil to add to the pum In addition, the system engineer would review this issue for applicability with other safety-related pumps as wel The inspectors also expressed a concern that system engineers do not review completed PPACs performed by plant operators. Unlike maintenance PPACs, cqmpleted operations PPACs were not routed through system engineers for revie The reason appears to be related to whether or not the PPAC was performed in accordance with a work order. Maintenance Department PPACs were performed with an accompanying work order, and were routed through system engineering before being file On the other hand, Operations Department PPACs were not performed with a work order, and were filed upon comp Jet ion with out routing through system engineerin The Shift Operations Superintendent stated this would be evaluated with the condition report written for this even.3 Surveillance Activities The inspectors identified a concern with the acceptance criteria for as-left component cooling water (CCW) flow to Charging Pump P-55C's lube oi 1 coo 1 er. The procedure stated that the as-1 eft CCW fl ow rate sha 11 be between 5.0 and 5.2 gp The procedure stated that if 5.0 gpm or greater could not be obtained, then the pump shall be declared inoperable and a condition report writte However, prior to starting the test, the inspectors observed the CCW flow rate to be 4.2 gp As allowed per procedure, the auxiliary operator adjusted the CCW flow rate to just over 5.0 gpm prior to starting the tes Plant operators stated that the 5.0 to 5.2 gpm band was difficult to maintain, especially when CCW flow was change The licensee agreed to evaluate the acceptance criteria to determine whether the operating band

..

for CCW flow rate should be changed to accommodate system flow perturbations. This is considered an inspection followup item pending the licensee's resolutio (IFI 50-255/95004-0l(DRP))

Other surveillance activities observed were:

MI27E, Functional Check of PCS Low Temperature Over Pressure Protection (LTOP) System

Ml-1, NI Power Range Rod Drop Alarm Flux - Delta T Tests

Q0-1, Safety Injection System

RI-23D, Thermal Margin Monitor One inspection follow-up item was identifie No violations, deviations, or unresolved were identified in this are.0 Engineering and Technical Support (37700, 37550, 37551, 60846, 86700)

The inspectors monitored engineering and technical support activities at the site. During this inspection, three inspectors from the Regional office assessed engineering activities to verify the adequacy of engineering in contributing properly to other functions such as operations, maintenance, testing, training, fire protection, and configuration managemen.1 Engineering Management In the past year, the licensee has taken many significant management actions to improve the performance of engineering. These actions have been effective in improving engineering support to other departments, and in clarifying management expectations and engineering objectives. The management actions taken included:

Combining engineering organizations under one engineering manager and shifting some responsibilities from system engineering to maintenance engineering and a new group, plant support engineerin *

Bringing into engineering a number of people from outside the company, and thus adding talent and additional depth of experience to the staf *

Increasing the use of industry engineering experience by visiting other utilities, surveying other utility experiences, and using vendor *

Assigning management and engineering resources to address previous program weaknesses such as Appendix R, and motor operated valve.2 Engineering Support Engineering failed to write a condition report for pieces of sample tubing lost in charging pump P-55A (see paragraph 2.4.2.a). Auxiliary Feedwater System The inspectors conducted* a review of the Auxiliary Feedwater (AFW)

System design basis document (DBD) to determine accuracy and completeness of the DB Weaknesses were identified with the current status and content of the DB A concern was also identified with coordination between Operations and Engineering during troubleshooting of an AFW componen The inspectors did not identify any condition of the AFW system which did not meet the licensing basis for the plan.3.1 Design Basis Document COBO)

The responsibility for the DBDs was recently transferred to Palisades'

Design Engineering organization. The engineer assigned responsibility for the AFW DBD had not received a turnover and was unaware of the responsibilities for the maintenance of this documen The engineer was also unable to provide a current status for the 12 open items associated with this DB The inspectors discussed this issue with licensee management and determined that the expectations for the maintenance of DBDs had yet to be communicated to the responsible engineer In addition, the System Engineering Group planned to reassign AFW and EOG engineer The combination of a new system engineer and a DBD which was not updated was not planned fo The licensee presented plans for initiating DBD ownership by design engineer In addition, the inspectors noted the following areas in the AFW DBD that could not readily be reconciled with other Palisades documentation:

The DBD and the basis for the auxiliary feedwater Techni'cal.

Specification identified that 100,000 gallons of condensate was required for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of operation. However, the DBD indicated that the original design basis for this could not be locate The subsequent calculations performed to determine whether sufficient capacity was available to meet this requirement indicated that this 100,000 gallon capacity could be expended in as little as 5.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> *

The purpose and use of the Feed-Only-Good-Generator valves as described in the DBD and the Updated Safety Analysis Report (USAR)

differed.. Subsequent investigation indicated that the description in the USAR was representative of the use of these valves at Palisade These two discrepancies combined with the status of the open items for this DBD indicated that continued management attention was needed to ensure that these documents were accurate representations of the design basis for the associated system.3.2 Coordination of Work Activities During observation of the troubleshooting of the AFW turbine driven feedpump steam block valves, the inspectors determined that the coordination between system engineering and operations prior to the pre-job brief was poor. This was evidenced by the types of questions raised during the pre-job brief which ultimately resulted in the postponement of the troubleshooting for two days while these questions were resolved and the procedure was modifie The procedure had previously been reviewed by the operations staff; however, this review was performed by a different shift than the one assigned to perform the testin The inspectors were concerned that the thoroughness of these reviews differed between shifts. The questions raised by the participants in the pre-job brief were indicative of a good questioning attitud.3.4 Facility Changes CFCs) and Modifications The inspectors identified several weaknesses in the modification These weaknesses included:

failure to account for a design basis condition; inadequate justification of an assumption; procedure revisions required by a modification; and administrative control.3.4 AFW Modifi~ation. FC-954 The inspectors were concerned that some asstimptions used in calculations for Facility Change (FC), FC-954 were inappropriate and did not receive proper revie This FC was created to move the low suction pressure AFW turbine trip from CV-0521 to CV-0522A because the alternate steam supply valve, CV-0521, had been unreliabl This FC included calculations EA-FC-954-02, "Low Pressure Suction Trip on the Auxiliary Feedpump - Setpoint Change," and EA-C-PAL-95-00538~01, 11 lnc9rporation of a Higher Auxiliary Feedwater Pump Low Suction Pressure Trip Setpoint into the T-2/T-81 Inventory Calculations Using the RETRAN Program."

The ~ssumptions used for condensate temperature were incorrect and could have prevented the full injection of 100,000 gallons of condensate as required by Technical Specifications, Section 3.5. Furthermore, the calculations had not received an adequate design revie This FC had been approved for installation on March 14, 199 This failure to adequately consider the design basis temperature and perform a thorough design review of FC-954 was considered a violation of 10 CFR Part 50, Appendix B, Criterion Ill, Design Contro (255/95004-02(DRS))

In addition, these calculations used an assumption of two minutes for the delay time from trip signal initiation to the closure of valve CV-052 However, these calculations did not justify or demonstrate that this assumption was appropriate and conservativ Further, this assumption had not been validated against expected system parameter ;.*-*

The FC also included an evaluation of relay GEI2HGAIIIJI2, which was associated with the CV-0522A handswftc The FC did not adequately address the seal in feature for the relay even though the post modification test procedure verified the functionality of this featur.3.5 EDG Modifications FC-940 Facility Change FC-940, Revision I, consisted of IO modifications, 6 of which upgraded the emergency diesel generators' (EDGs) start and protective trip logic circuits. Modification No. 2 upgraded the EOG start logic, while the other five modifications upgraded the trip circuits to meet Regulatory Guide I.9 and IEEE 387-I98 FC-940, Revision I, was approved on February I995 for installation and testing during the I995 refueling outag The six modifications reviewed by the inspector were:

Modification No. 2 to upgrade the EDG bus undervoltage start logic by eliminating the requirement that an undervoltage condition on either the IC or ID buses start both engine Instead, bus IC will provide an auto start command to both circuits of EOG I-I,.

• and bus ID to both circuits of EOG I-Each EOG (both start circuits) will c*ont i nue to be powered by an independent I 25 Vdc, Class IE sourc Modification No. 4 eliminates the EOG on line overcrank trip logic to the shutdown relay. Overcrank will continue to shutdown the air start motors if a start does not occur within 35 second *

Modification No. 5 upgrades the existing I of 2 overcurrent trip logic of each EDG to a coincident trip logic (2 out of 2).

• Modification No. 6 eliminates the EOG field shutdown timer logic during accident conditions to prevent an unnecessary breaker tri *

Modification No. 7 upgrades the EDG start circuit B air starting motor protection by preventing a single failure from restarting the air start motor regardless of engine spee *

Modification No. 8 provides EOG with a coincfdent low jacket water pressure trip logi The review consisted of selected 50.59 evaluations; engineering analysis; installation/removal procedures; procurement documents; revised drawings; affected operating, surveillance, and alarm response procedures; post modification test procedures; and FSAR change The inspector determined that the documents reviewed met the requirements of NRC regulations, the Technical Specifications, and licensee administrative procedures controlling facility change However, the following omissions were noted:

Modification No. 4 was not reflected in the proposed revised pages to the FSA I5

Modification Nos. 4 and 8 were not reflected in the proposed changes to the alarm and response procedures for ARP The licensee plans to re-review the proposed changes to the FSAR and the alarm and response procedures to ensure the changes reflect all planned FC-940, Revision 1 modification.3.6 Modification to Dry Fuel Storage Vacuum Drying Ski The* licensee experienced one problem during the vacuum drying process for multi-assembly sealed basket (MSB) 11. A plant engineer modified*

the piping arrangement on the vacuum drying skid prior to use on MSB 1 The main intent of the modification was to improve the vacuum drying proces However, the modification proved inadequate in that the new arrangement resulted in the trip of both vacuum pumps just after vacuum drying commence This occurred when the discharge side of one of two vacuum pumps became flooded, and the associated oil box filled with wate The failure of the pump necessitated that compensatory measures be implemented, while action was taken to repair or replace the pum The licensee disconnected the vacuum drying skid from the MSB, and proceeded to backfill the MSB with heliu This action was allowed by plant procedures and the MSB was allowed to be in this configuration for up to a two week period. Following the helium backfill, the licensee modified the piping on the vacuum drying skid back to the original configuration. This action was completed within the next several hour Plant personnel then satisfactorily tested the vacuum drying skid and proceeded with the remaining activitie The inspectors found that although this event lacked safety significance, the licensee had not utilized proper administrative controls over the design and implementation of this modificatio The licensee initiated a condition report to investigate this even.4 Packing Configuration Control The inspectors reviewed the controls for packing replacements on air operated valve Packing configuration control was maintained by the work order process as allowed by two general specification changes (SC),

SC-87-122 and SC-89-04 The evaluation conducted for these SCs did not reconcile the vendor specific packing configurations for the various styles of valves and the associated actuator Nor did the evaluation address the ability of these valves to perform the intended functions following ~modification of the packing configuratio The licensee indicated that the ability of the valves to perform their intended function was assured by the post-maintenance testing. However, the minimum testing to be performed and the acceptance criteria for this

, testing was not defined. This matter is considered an Inspection Follow-up Item pending further NRC review of the licensee's packing *

configuration control program._ (255/95004-03(DRS))

I. '

..

.!

• Rosemount Transmitters

The inspectors reviewed the licensee's actions pertaining to potential issue with Rosemount transmitters. The licensee took aggressive action to identify and evaluate the potential problem transmitters in the plan On March 24, 1995, the licensee was informed that Rosemount Nuclear f~struments issued a 10 CFR Part 21 Report concerning nuclear qualified Rosemount transmitters models 1152, 1153 and 115 The Part 21 identified that certain transmitters and sensor modules were supplied with isolator diaphragms manufactured with Monel 400 rather than Type 316 ~tainless steel. Sixteen of the suspect transmitters or sensor modules were supplied to Consumers Power Compan Four modules were found to be spare components located* in the warehouses and staging areas within the plant while the remaining 12 were installed in the primary system and the secondary system for the steam generator The licensee has reviewed the specific applications and the specific function of the 12 installed pressure transmitters and provided an operability determination for each installed transmitter. While an adequate justification was provided for each application, the licensee was in the process of evaluating replacement of the suspect.

transmitter The licensee has decided to evaluate replacement of PT-01048 while on-line to ensure proper operation while the plant was off-line during low pressure condition The remaining transmitters were being evaluated for replacement during the upcoming outag.6 10 CFR 50.59 Safety Evaluation's The inspectors reviewed two 10 CFR 50.59 safety evaluations completed for fire protection, Compensatory Measure for Primary Coolant Pump Lube Oil Collection System Deficiencies, 95-0189, and Fire Suppression Water

,System,95-017 The evaluations appeared to be accurate and take significant factors into account. All of the changes were appropriate and neither appeared to be detrimental to fire protection safet One violation and one inspection followup item was identified in this are No deviations were identifie.7 Alloy 600 Project The inspectors met with the licensee to discuss the plans for Inconel 600 inspections during the upcoming refueling outage. Overall, the inspection plan presented was considered technically soun The licens~e is planning on implementing methods recognized in NUREG/CR-6245, Assessment of Pressurized Water Reactor Control Rod Drive Mechanism Nozzle Cracking, for mitigating and controlling primary water stress corrosion cracking (PWSCC) in Inconel Alloy 60 Licensee personnel and management were involved with industry groups and with

.. *

other licensees performing Inconel Alloy 600 inspections for PWSC NDE procedural and personnel qualification methods chosen appear to be thorough and well thought out, including utilization of Palisades specific mockups which account for expected geometric problems to be encountered during NDE examination.0 Plant Support (64704, 71750) Fire Protection Program The fire protection program was adequate overall with good fire brigade training; but, weaknesses were noted in the testing and maintenance of fire extinguishers, the existence of numerous long term work orders, and one case involving the control of combustibles. This inspection consisted of plant area observations and reviews of fire protection audits and surveillances, fire reports, maintenance work requests, safety evaluations, maintenance on fire protection equipment, and fire brigade training and drill The staff was experienced, knowledgeable, and proactive in dealing with most plant problems.. Good cooperation was observed among the staf During the last six months, significant improvement had been made in identifying long term problems and initiating correcti've action in the fire protection progra An electrical engineer was added to the fire protection staff and the fire protection responsibilities were consolidated into one grou However, additional improvements were still needed with procedural compliance and accuracy in some areas of the fire protection program, i.e., discrepancies between the.Fire Protection Implementing Procedures, the Fire Protection Plan, and the requirements that constituted the approved fire protection program as discussed in paragraphs 5.1.1.1 and 5..1.1 Plant Area Observations The inspector toured the auxiliary and turbine buildings and the cooling tower pump house to observe the control of combustibles and the condition of fire doors, hose stations, detection equipment,*

extinguishers, sprinkler systems, emergency lighting, and housekeepin The material condition of most fire protection equipment was goo This included fire brigade equipment, fire doors, dampers, fire detection and suppression systems, portable extinguishers, and hose station However, the fire doors to the diesel gene~tors and the screenhouse did not self-close and latch due to high differential pressur The licensee was pursuing a Functional Equivalent Substitution (FES) for the doors to the screenhouse to provide a stronger closing actuato The resolution of the diesel generator doors was awaiting the results of this FES which was scheduled to be ~ompleted in September 199 *

.,

5~1.1.1 Combustible Materials in a Stairwell The inspector identified that the area at the bottom of the stairwell in the auxiliary building leading to the safeguards rooms was being used as a storage area for various maintenance activities. This stairwell was the primary access and egress route for local operation of equipment in the safeguards rooms in the event of certain accidents which would require the evacuation of the control roo This storage of material in stairwells was contrary to the requirements of the Fire Protection Implementing Procedure (FPIP), FPIP-7, "Fire Prevention Activities,"

Section 5.1, which states in part that stairways shall be kept clear of storage at all times. This was considered an example of a violation of*

Palisades Nuclear Generating Facility's Operating License, Section

. 2.C.(3), that pertains to the fire protection program (255/95004-04a(DRS)).

See also paragraph 2.4..1.1.2 Turbine Lube Oil Storage Room Fire Walls During a tour of the turbine building, the inspector noted that the west wall of the turbine lube oil storage room, located on the 590'

elevation, was a non-fire rated wall and the south wall, a three hour rated fire barrier, had two penetration seal impairment The approved

~ire frotection Program appeared to allow the west wall of this room to be non-fire rated based on this wall being an outside wal Howev~r, an addition to the turbine building was constructed by a previously

• installed fe~dwater purity modification which resulted in this wal.l n longer being an outside wall. This change in the plant configuration *

did not appear to the be addressed in the approved Fire Protection Progra The inspector also identified concerns with two openings in the area of the turbine lube oil.storage room:

Subsequent to the completion of the feedwater purity modification, an evaluation of this addition was conducted. This evaluation was incomplete and insufficient to demonstrate compliance with the licensee's Fire Hazards Analysis (FHA) and their response to the Branch Technical Position (BTP), BTP APCSB 9.5-1. This evaluation was not reviewed or dated and was not consistent with the current plant configuratio For example, it indicated that t.he non-fire rated wall would prevent direct flame from entering the addition; however, a large opening at the top of the west wall existed which would have allowed direct flame transmission to the cable trays in the feedwater purity addition. The inspector also identified that*

in 1989, the licensee submitted to the NRC a proposed revision to the FHA and their response to the BTP APCSB 9.5-1, which would have allowed the current configuration of the facilit Apparently this proposed revision was never reviewed or approved by the NR *

Another large opening, approximately 10' x 12', existed between the turbine building and the component cooling water (CCW) room in

• the auxiliary building on the 590' elevation near the turbine lube oil storage roo The licensee did not have an approved exemption for this openin However, an evaluation was performed by the licensee in 1989 which relied on the minimal fire loading in the vicinity of the opening not being sufficient to transmit a fire as justification for the opening between these fire zones being acceptable. This evaluation did not quantitatively evaluate the fire loading in the area nor was not reviewed or date In addition the licensee had no controls which would prevent transient combustibles from being stored in this are This opening could impact the safe shutdown analysis (SSA) for *a turbine building fire or a fire in the CCW roo At present, the licensee's SSA addresses and assesses separately a fire in the turbine building and a fire in the CCW roo The SSA does not *

address the affects on safe shutdown of a fire in both rooms such as a fire originating in the turbine building which could propagate to the CCW room due to the opening and the negative pressure in the CCW room maintained by the ventilation syste The licensee had previously initiated an Appendix R Enhancement Program to ensure compliance with the approved Fire Protection Progra The Appendix R Enhancement Program was in progress and will be completed by June 199 The scope of the enhancement program would not have identified and resolved the above issue The above concerns are considered an unresolved item pending further NRC review (255/95004-05(DRS)). *

5.1.2 Fire Brigade During an unannounced dri 11, in the turbine 1 ube oil storage* room, the fire brigade's ability to extinguish a fire was evaluated by the inspector as being satisfactory. *The fire brigade responded in a timely manner; however, subsequent command and control deficiencies resulted in

• unnecessary delays in attacking the simulated fire. A critique was held at the end of the fire drill with all of the participants in the drill presen The participants were allowed to identify any problems during the performance of the drill. The inspector*.evaluated the critique as being an effective method for problem identification. Overall, the fire protection training program was considered a strengt.1.3 Emergency Lighting A review of the emergency lighting system surveillances ~as conducted which indicated a typical failure rate for.emergency lighting units utilized throughout the industr During the course of this inspection, the inspectors found two units that were not operating properl The licensee initiated two work requests to troubleshoot and repair these units. Other corrective actions associated with the emergency lighting system were described in the Nuclear Engineering & Construction Organization Engineering Programs Procedure, EPP-07, "Final Safe Shutdown Analysis Technical and Administrative Instructions," Section

. *

6.6.3. The planned actions associated with the emergency lighting units appeared to be acceptabl.1.4 Portable Fire Extinguishers During the performance of a plant tour the inspectors noted that a portable fire extinguisher that had been used by a fire watch earlier in the shift had not had the annual maintenance performed as required by the National Fire Protection Association Standard 10, Section 4-Subsequent investigation identified that the 89 fire extinguishers maintained by the Project Management & Modifications Group for use by fire watches had not received this maintenance since at least February 199 The remainder of the plant's extinguishers were maintained by the Fire Protection Staff.. Two CRs (C-PAL-95-0206 and C-PAL-95-0244)

documented the immediate corrective actions taken and the programmatic deficiencies associated with this issu The required annual maintenance was subsequently performed on these portable fire extinguishers and resulted in the replacement of six cartridges and the hydrostatic testing of two extinguisher In addition, one extinguisher was found to be missing at the time of the maintenance and subsequently determined to have been turned over to Palisades Property Protection personnel to be recharge This failure to conduct the required annual maintenance on these

.portable fire extinguishers was an example of a violation of Palisades Nuclear Generating Facility's Operating License (255/95004-04b(DRS)).

Condition Reports, C-PAL-95-0206 and C-PAL-95-0244, are further discussed in paragraph 2.4..1.5 Maintenance Backlog Palisades has a large number (over 100) of impairments and open work requests for fire protection barriers and equipmen Two work requests to repair impairments date back to 1989 and are in planning hold while 12 other impairments from the first and second quarter of 1992 are not currently scheduled to be completed until March 199 This issue was also identified in the January 1995 NPAD audit report on the fire protection program, PA-94-3 Palisades has recently instituted a 13-week rolling work schedule which gives the fire protection staff an opportunity to provide input to have fire protection work requests completed in the appropriate priorit Indications are that continued management involvement was necessary to ensure that progress is continued in this are.1.6 Fire Reports There were only a few, insignificant fires documented during this assessment period. These included electrical component fires and a minor fire in Containment as a result of hot wor A review of the subsequent investigation and corrective actions assigned indicated that the threshold for reporting fires and the actions taken were appropriat *

5.1.7 Fire Watches The inspector observed the fire tours being performed by the plant's security force as compensatory measures for fire protection impairment These tours were performed along a specified path with the individual looking for indications of a fire along the rout The security force had been effective at ensuring these tours were completed in a timely manne The only weakness in the performance of these compensatory m'easures was that the fire watches performing tours were not aware of the nature of the impairmen Since only one side of an impairment was required to be observed during performance of the tour, the fire watch was not able to identify if impairments had been further degraded, e.g.,

combustible material being temporarily stored in the vicinity of an inoperable sea.1.8 Zebra Mussels Zebra mussels presented no threat to the fire protection water suppression system at the time of the inspectio The fire protection system was being chemically treated in accordance with Palisades Nuclear Plant Chemistry Operating Procedure, COP-15, "Service Water System Chemistry", and Palisades Nuclear Plant Special Operating Procedure, SWS0-4, "Molluscicide Treatment of Service Water System." During the most recent inspections of the fire protection systems, no zebra mussels were foun * Radiological Controls The inspectors verified that personnel were following health physics procedures for dosimetry, protective clothing, frisking, posting, etc.,

and randomly examined radiati-0n protection instrumentation for usej operability, and calibration. The inspectors reviewed the radiological survey sheets for Ventilated Storage Cask number 11 and found no problem.3 Security 5.3.i Access Control/Authorization - Personne During this inspection, the inspectors reviewed an fncident which was not reported to management for evaluation and action that involved a physical altercation between two armed security force member This altercation reflected adversely on the reliability of both individuals and was brought to the licensee's attention in a NRC letter dated December 21, 199 During the inspectors' review of the results of the licensee's investigation of this incident, the inspectors identified that in early 1994, a security officer twisted the arm of a security supervisor from behind, without forewarning and with considerable pressure. During the altercation, the supervisor stabbed the officer with a pe Licensee investigation results identified that the incident occurred in the weapons room i~ the presence of numerous security force member This incident was not documented, nor reported by any of the

• personnel presen Even though everyone present agreed that the altercation demonstrated atypical behavior and should have been reporte This finding is contrary to Palisades Nuclear Plant Policy/Procedure 1982-6, "Atypical Behavior," which requires, in part, that physical threats against persons be reported immediately to the site security management and is considered a violation (Violation 50-255/95004-05(DRSS)).

The Site Property Protection Superintendent (PPS) evaluated the inspector's finding and concluded that the altercation referenced above did meet the licensee's definition of atypical behavior and required reporting to managemen Both individuals were no longer employed at the plan The PPS was aware of the altercation from previous review of the licensee's investigation report, referenced above, but did not recognize the adverse behavioral issue until identified by the inspecto Review of records and interviews showed that several other physical altercations have occurred between members of the armed security organization in the past 10 year Some involving the individuals refe~enced in this ite None were documented and if management was aware,. only a cursory review to determine the facts. was conducted.

Review of the licensee's continual behavioral observation training program (CBOP) showed that physical altercations were not specifically included in either classroom or handout material. The licensee's cognizant training individual agreed that a physical altercation could reflect atypical beh~vior and CBOP should be modified to address the issu The failure to report this event was caused when security officers failed to recogniz~ ~nd understand the significance of an observed*,

aberrant behavior event. *1n addition, the licensee's CBOP training did not identify a physical altercation as an example of atypical behavio The PPS, when aware of the event did not recognize the significance of the aberrant behavior issu Licensee corrective action included modification of the CBOP training program to include physical altercation as atypical behavior and the responsibility to immediately report such activity to station*

managemen All security personnel were advised that any observed physical altercations were to be identified as atypical behavior and must be immediately reported to station security managemen.3.2 Management Effectiveness The inspectors determined that licensee and security contractor managers and supervisors were providing an adequate level of overview to the security program and that self-assessment activities has shown some

,*

r

'

I

.*

..

• • ~

improvemen However, managements' action in assuring effective corrective actions identified during self assessments and audits were.

not totally effective. This is further discussed in paragraph 2.3 of this repor Two violations and one unresolved item were identifie No deviations or inspection followup items were identifie.0 Report Review (90713)

~ During the inspection period, the inspectors reviewed the licensee's monthly operating report for February and March, 199 The inspectors confirmed that the information provided met the reporting requirements of TS 6.9.1.C and Regulatory Guide 1.16, "Reporting of Operating information."

• No violations, deviations, unresolved, or inspection followup items were identified in this are.0 Meetings and Other Activities (30703)

On March 9 and March io, 1995, NRC senior management conducted a site visit to assess plant status and discuss topics of mutual interest.

On March 17, 1995, a management meeting was held on site to discuss the Jicensee's plans for the upcoming refueling outag.0 Action on Previous Inspection Findings (92901, 92902, 92903, 92904)

(Closed) IFI (50-255/92024-02CDRSSll:

The physical fitness agility testing for armed response personnel was not effective. The inspector had been able to walk the agility course within the licensee's minimum established time limit. Initially, the licensee reduced the maximum completion time. This action was not effective. During a subsequent inspection the inspector could still walk the course within the time limit. Consequently, the licensee conducted a full evaluation and validation of a new physical agility cours The inspector determined that licensee action was adequate and addressed the inspector's concern and that cognizant *requirements were me This item is closed..

(Closed) Inspection Followup Item C50-255/93011-02CDRSSll:

This issue was described in Section 5.b of the above noted report and followed up in Section 2.c of Inspection Report 50-255/9400 The issue pertained to the licensee's action to improve the performance of four protected areas and intrusion alarm zone The issue had remained open because licensee evaluation on corrective measures was continuin The inspectors' review determined that this action has increased in-service time by approximately 50% and reduced false alarm No problems were noted. This item is close *

(Open) Inspection Followup Item (50-255/94005-0lCDRSSll:

Two issues were described in Sections 5.a and b of the above noted repor On some occasions, security search activities were minimally effective and a vulnerability existed that would allow easy opportunity for a single individual to circumvent the badging system without detectio To address the badging vulnerability, the licensee established a dual personnel verification process for newly issued badges to prevent unauthorized badges. A badging specialist would conduct the badging activities and another security force member would verify the badging activity prior to badge actuation. This item is close Licensee action to address the search program weakness was not totally effective. Refer to paragraph 2.3 of this report for further detail.

This item will remain open pending additional licensee action to address weaknesses in the search progra Licensee action will be reviewed during future inspection (Open) Inspection Followup Item (50-255/94005-02CDRSS));

This issue was described in Section 5.c of the above noted report and involved low morale in the security organizatio The licensee has proposed additional measures to improve security force moral This item will remain open pending further review of licensee actio (Closed) Violations (50-255/94005-03, 04, 05. and 06CDRSSll:

These violations were described in Section 6 of the above noted report and pertained to automatic data processing systems used to maintain protected information that were not self-contained within the licensee's facility; protected information that had been transmitted on unprotected telecommunication circuits; some computer tapes and drawings containing protected information that were not stored properly and some computer tapes that were not stamped to indicate the presence of protected informatiq Licensee corrective action was documented i letter dated September 15, 199 The following corrective actions, implemented by the licensee, were evaluated by the inspectors:

(1) Ownership of the Safeguards Information (SGI} program was assigned to the Site Property Protection Superintendent; (2) A self-assessment program was establishe An initial assessment was conducted between October 1994 and January 199 Results were being evaluated by the licensee and corrective action to findings were being implemented; (3) SGI training programs have been develope Approximately 200 plant employees have been trained in the control and protection of SGI; and (4) New plant procedures have been implemented and existing corporate procedures which address the SGI program have been revised to provide new guidance for the control and protection of SGI processes on computer No additional problems were identified. This item is close (Closed) IFI 255\\94014-01; Corrective actions for Diagnostic Evaluation Observation (DEO) ENG-047 included revision of the Palisades Reload Design procedure RSA-02.. The inspector reviewed RSA-02, Rev. 1 and

correspondence between S~emens ~ower Corp and the license The procedure appropriately specified review responsibilities for core reload plant parameter By letter dated March 24, 1995, SPC proposed a new format for the Plant Parameter Document (PPD), requirements for SPC analysts to use this document and for a thorough review by the license A draft PPD for cycle 12 at Palisades was being prepare (Closed) IFI 255/94014-12: Procedure writers did not revise the surveillance test procedure to include monitoring of the fuel oil belly tank level. Testing was conducted to establish emergency diesel generator fuel consumption and fuel oil day tank and belly tank capacities. This testing established that the day tank alone would meet the Technical Specifications requirement for having 2500 gallons of fuel available. Surveillance requirements for the belly tank were no longer needed and were not added to the surveillance procedure The inspector reviewed the surveillance procedure for operaters daily/weekly items,

• D/W0-1, and surveillance requirements were appropriat CClosedl IFI 255/94014-13: Operating procedure SOP-022, "Emergency Diesel Generators" was revised that changed the valve lineup, however, the system checklist was not revised to reflect this chang The inspector reviewed administrative proce~ure 4.02 "Control of Equipment",

A-PA~ 94-104, and A-PAL-94-13 The administrative procedure had been revised and improved to better control check lists, assigning them to the same individual as the system operating procedure and specifying a two year review cycle. A memo to operations procedure reviewers reemphasized expectations for reviewers was issued June 23, 1994 and January 14, 1995 and is intended for annual reissu The specific check list, CL No 22.2, had been revised in Revision 14, dated 6/7/9 <Closed)

IFI 50-255/94014-25; Weaknesses identified by the DET during a monthly test of EOG 1-The inspector reviewed Surveillance Procedures M0-7A-001/2, Revision 34, and determined that Step 5.3.7 now requires a 20 minute wait before starting the engine following the reset of the overspeed trip devise (after completion of the cylinder leakage test).

Operating Procedure No. SOP 22, Revision 15, incorporates the same requirement. This action resolves the first half of IFI 255/94014-2 However, the "preconditioning" concern must address more than just a waiting perio If the EDGs are to be cranked for 5 seconds for a cylinder leakage test prior to their operability test, events experienced during the 5 sec test must be addressed when determining whether the EDGs were operable, and whether the test was a valid success or failure for reliability calculations. For example, personnel performing the test should be aware of the approximate quantity of fluid which, if ejected* out of a cylinder, would constitute an inoperable engine (hydraulic lock).

The licensee plans to add a caution statement to the cylinder leakage test to address the NRC's concern. This issue is considered an Inspection Followup Item pending NRC review (50-255/95004-06 (DRS)).

The second half of the DET concern involved the over ranging of 0-100 psig gauge used for determining the differential pressure (tJ>) across

-*

the lube oil strainer on EOG 1-1, and the lack of an acceptance criteria for the llP readin The inspector determined that the llP gauge in question was replaced with a 0-160 psig range gauge on both EDG In addition, a review of surveillance procedures M0-7A-001/2 showed an acceptance criteria of 58 psid for the lube oil strainer. This item is considered resolve COpenl IFI 255/94014-39: Roles and responsibilities of the two onsite engineering organizations were not well defined. Discussions with engineers in the Plant Support Group indicated that roles were understood with minor discrepancie In the design engineering organization, the recent relocation of responsibility for system design basis documents (DBD) had been initiated but roles not yet establishe The licensee presented plans for initiating DBD ownership by design engineer CClosedl IFI 50-255/94014-42: Modification to change the air start motors actuation circuits. The inspector reviewed Facility Change FC-940, Revision 1, which includes Modification No. 2, an upgrade to the EOG bus undervoltage start logi Based on this review (see Section 4.3.2 of this report) this item is considered resolve (Closed} IFI 50-255/94014-45:

The low suction pressure trip function for the turbine driven auxiliary feedwater pump was being fulfilled by CV-0521, which had been unreliable, on both opening and closingJ since 198 This item is closed based on the issuance of a violation which is discussed in Section 4.3.1 of this repor CClosedl !Fis 50-255/94014-65 and 66:

Vendor recommendations for EOG and AFW not fully evaluated by Systems Engineering, and Vendor Information Program did not *nsure that updated vendor bulletins were routinely requested. These two issues have been incorporated into IFI 50-255/94014-64, weak control and maintenance of vendor manuals, which remains ope The inspector reviewed the licensee's action regarding these concern Administrative Procedure No. 3.16, Revision 3, "Industry Experience Review Program" directs how information received from industry/vendors is processe Procedure No. 9.45, Revision 0, "Vendor Manual Control" describes the controls for developing, maintaining, and distributing vendor manual file The inspector determined that these two procedures should be better integrate For example, Procedure 9.45 does not reference or explain how Procedure 3.16 interfaces with vendor manual informatio During discussions with the licensee it became evident that they had similar concerns and the procedures were being revise During March 1995, Procurement Engineering sent letters to its.

commercial grade suppliers requesting notification of problems, or potential problems, with the products they have supplied. There is no guarantee that the vendors will comply with the reques...

These issues remain open (IFI 50-255/94014-64.) pending the licensee's upgrade of Administrative Procedures No. 3.16, Revision 3; and ~o. 9.45, Revision 0, and more experience is gained with their implementatio In addition, more time is needed to evaluate the vendors response to the licensee's request for informatio COpenl IFI 50-255/94014-73; The corrective action process was ineffective. The inspectors reviewed several condition reports associated with both the fire protection and the engineering activitie This review identified the following concerns which were indicative that certain aspects of the corrective action process still needed improvement:

As discussed in paragraph 2.4.1, condition reports C-PAL-95-0244 and C-PAL-95-0245 were treated as nonconsequential vice significant, as required by Administrative Procedure 3.03, Section 6. *

No condition report was issued to identify the oil sample tubing that was caught in charging pump P-55 *

The evaluations conducted for C-PAL-95-0244, C-PAL-95-0245, and C-PAL-95-0246 were incomplete and in some ~ases inaccurat *

The operability determinations ~ssociated with C-PAL-94-0794 and C-PAL-95-0053 lacked a clear and logic~l justification with a*

sound.engineering basis to support the conclusions. See paragraph 2.4.2.b for further detail The above concerns were discussed with the licensee. This will remain open pending completion of planned revisions to and further review of the licensee's corrective action proces.0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviation An unresolved item is discussed in Section 5.1.1.2 of this repor.0 Inspection Follow-up Items Inspection follow-up items are matters which have been discussed with licensee personnel, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or the licensee or bot Inspection follow-up items noted during the inspection are discussed in Sections 3.3, 4.4, and 8.0 of this repor !

':....... f'

11.0 Exit Interview (71707)

The inspectors met with the licensee representatives denoted in paragraph 1 during the inspection period and at the conclusion of the inspection on April 12, 199 The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection repor The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur.0 Persons Contacted Consumers Power Company

• R. A. Fenech, Vice President,. Nuclear Operations

1. • T. J. Palmisano, Plant General Manager

1. K. P. Powers, Engineering and Modifications Manager

• R. Swanson~ Director, NPAD

1. D. W. Rogers, Operations Manager

1. • D. P. Fadel, Engineering Programs Manager

• J. P.* Pomaranski, Deputy Maintenance Manager H. L. Linsinbigler, Project Management and Modifications Manager

1. • S. Y. Wawro, Planning ~anager K. M.*Haas, Safety & Licensing Director R. B. Kasper, Maintenance Manager

• R. C. Miller, Deputy Engineering and Modifications Manager

• C. R. Ritt, Administrative Manager*

1. • R. M. Rice, System Engineering Manager M. P. Knopp, Chemistry Superintenden #*D. J. Malone, Radiological Services Manager

1. K. A. Toner, Design Engineering Manager D. G. Malone, Shift Operations Superintendent R. A. Vincent, Licensing Administrator

1. • D. J. Vandewalle, Plant Support Engineering Manager Nuclear Regulatory Commission

• W. Kropp, Chief, Projects Section 2A

1. • M. E. Parker, Senior Resident Inspector

1. • D. G. Passehl, Resident Inspector

1. E. W. Cobey, Reactor Inspector

• T. Madeda, Safeguards Inspector

1. • R. M. Lerch, 'Reactor Inspector

1. F. Maura, Reactor Inspector

• D. W. Nelson, Health Physics Inspector

1. Denotes those attending the interim technical exit interview on April 7, 199 * Denotes those attending the exit interview conducted on April 12, 199 The inspectors also had discussions with other licensee employee