IR 05000255/1982024
| ML20028C037 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/03/1983 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20028C034 | List: |
| References | |
| 50-255-82-24, IEB-80-11, NUDOCS 8301050318 | |
| Download: ML20028C037 (32) | |
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SALP 3
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U.S. NUCLEAR REGULATORY COMF11SSION
REGION III
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SYSTE!!ATIC ASSESS!!ENT OF LICENSEE PERFORr!ANCG s
Consumers Power Compary PALISADES NUCLEAR GENERATING PLAST Docket No. 50-255 Report No. 50-255/82-24 Assessment Period July 1, 1981 through June 30, 1982 8301050318 830103 PDR ADOCK 05000255
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CONTENTS Page i
Letter to Licensee from SALP Board Chairman.....................
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Licensee Comments vii
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Introduction............
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II.
Criteria.....................
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III. Summary of Results
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Performence Analyses
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Supporting Data and Summaries.............................
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Docket No. 50-255 Consumers Power Company j
ATTN:
Mr. R. B. DeWitt Vice President
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Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201
Gentlemen:
i This is to confirm the conversation between Mr. D. J. VandeWalle and
Mr. R. D. Walker of the Region III staff scheduling October 28, 1982, at
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10:00 a.m. as the date and time to discuss the Systematic Assessment of Licensee Performance (SALP) for the Palisades Nuclear Generating Plant.
This meeting is to be held at the NRC Region III Office in Glen Ellyn, Illinois.
Mr. A. B. Davis, the Region III Deputy Regional Administrator, and members
I of the NRC staff will present the observations and findings of the SALP
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Board. Since this meeting is intended to be a forum for the mutual under-
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standing of the issues and findings, you are encouraged to have appropriate representation at the meeting.
As a minimum, we would suggest Mr. J. D. Selby, President, Mr. R. J. Reynolds, Executive Vice President, Mr. R. W. Montross, General Manager, and managers for the various functional areas where problems have been identified attend the meeting.
l The enclosed SALP Report which documents the findings of the SALP Board is for your review prior to the meeting.
Subsequent to the meeting the SALP Report will be issued by the Regional Administrator.
Enclosure 1 to this letter summarizes the more significant findings iden-tified in the SALP Board's evaluation of the Palisades Nuclear Generating Plant for the period of July 1, 1981 through June 30, 1982.
If you desire to make comments concerning our evaluation of your facility, they should be submitted to this office within twenty days after the meeting date; otherwise, it will be assumed that you have no comments.
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Consumers Power Company
In accordance with Section 2.790 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Federal Regulations, a copy of this letter, the SALP Report, and your comments, if any, will be placed in the NRC's Public Document Room when the SALP Report is issued.
If you have any question concerning the SALP Report for the Palisades Nuclear Generating Plant we will be happy to discuss them with you.
Sincerely, J. A. Hind, Chairman Region III SALP Board Director, Division of Emergency Preparedness and Operational Support Enclosures:
1.
Summary of Significant Findings 2.
Preliminary Palisades Nuclear Generating Plant SALP 3 Report (5 copies)
cc w/encls:
Resident Inspector, RIII
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ENCLOSURE 1 Summary of Significant Findings General Observations For the second consecutive SALP period the licensee's overall performance has continued to improve with one major exception: while the licensee has continued to meet the commitments in their Regulatory Improvement Program, their performance in Radiological Controls has deteriorated. This deteri-oration is primarily due to a continued failure to meet commitment dates for correcting liealth Physics Appraisal findings and the failure to conduct an effective ALARA Program.
Significant indications of the licensee's overall improvement include a reduction in identified noncompliances from the previous SALP period (17 versus 36), increased responsiveness in most areas to NRC concerns and issues, and a general reduction in the significance of reportable events and noncompliances.
Weaknesses in staffing and training continued although the licensee continued to put emphasis on increased staffing and a major revamping of the overall training program.
Plant Operations Strong management control and involvement resulted in continued overall improvement. Ilowever, staffing and training weaknesses continued.
Radiological Controls Performance deteriorated as described in General Observations.
Surveillance Management involvement and attention has resulted in a major turnaround in the performance from the previous SALP period.
Emergency Preparedness The use of a simplistic scenario for the full scale exercise conducted in February 1982 detracted from an otherwise satisfactory performance in this area.
Licensing Activities Increased management attention and responsiveness to priority issues resulted in an improved performance in the handling of licensing activities.
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Quality Activities The resolution of significant programmatic weaknesses resolved in improved performance.
Training The licensee was engaged in a major revamping of the company's overall training program; however, implementation at the plant remained incomplete.
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CORSumBIS i-~
power on.w a v. wow no
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Generet offices: 212 West Michigan Avenue, Jackson, Mt 49201 e (517) 788-0550 November 17, 1982 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 00137 DOCKET 50-155 - LICENSE DPR-6 - BIG ROCK POINT PLANT -
DOCKET 50-255 - LICENSE DPR-20 - PALISADES PLANT -
COMMENTS ON SYSTEMATIC ASSESSMENT OF LICENSEE PREFORMANCE Your letters of October 18 and October 22, 1982 transmitted the Systematic Assessment of Licensee Performance (SALP) reports for the Palisades and Big Rock Point Plants, respectively. These reports covered the period from July 1, 1981 to June 30, 1982. As we discussed in our October 28, 1982 meeting, Consumers Power Company finds these reports to be fair and accurate assessments of our performance during this SALP reporting period, with the i
possible exception of the Security and Safeguards area for Big Rock Point Plant. We would like to discuss this issue further with appropriate members
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I of your staff at your convenience.
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l David J VandeWalle (Signed)
David J VandeWalle Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector-Big Rock Point NRC Resident Inspector-Palisades
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I.
INTRODUCTION
The NRC has established a program for the Systematic Assessment of Licensee Performance (SALP). The SALP is an integrated NRC Staff effort to collect available observations and data on a periodic basis and evaluate licensee performance based upon those observa-tions. SALP is supplemental to normal regulatory processes used to insure compliance to the rules and regulations.
SALP is intended
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primarily from a historical point to be sufficiently diagnostic to provide a rational basis for allocating future NRC resources and to provide meaningful guidance to the licensee's management to promote
quality and safety of plant construction and operation.
A NRC SALP Board, composed of the staff members listed below, met on September 20, 1982, to review the collection of performance observa-I tions and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, Systematic Assessment of Licensee Performance:
a summary of the guidance and evaluation
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criteria is provided-in Section II of this report.
This report is the SALP Board's assessment of the licensee safety
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i performance at Palisades Nuclear Generating Plant for the one year
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period July 1, 1981 through June 30, 1982.
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l The results of the SALP Board assessments in the selected functional
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areas were presented to the licensee at a meeting held on October 28, 1982.
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SALP Board for Palisades Nuclear Generating Plant:
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J. A. Hind, Director, DEPOS, SALP Board Chairman
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R. L. Spessard, Director, DPRP
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C. E. Norelius, Director, DETP I
T. N. Tambling, Chief, Programs Support Section L. R. Greger, Chief, FRP Section, DETP L. Reyes, Chief, Reactor Projects Section 2B B. L. Jorgenson, Senior Resident Inspector J. K. Heller, Resident Inspector T. V. Wambach, Licensing Project Manager, NRR M. M. Holzmer, Project Inspector, DPRP P. C. Lovendale, Radiation Specialist, DETP
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II.
CRITERIA The licensee's performance is assessed in selected functional areas depending whether the facility is in a construction, pre-operational or operating phase.
Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas.
Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess cach functional area.
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Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint 3.
Responsiveness to NRC initiatives I
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Enforcement history S.
Reporting and analysis of reportable events 6.
Staffing (including management)
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Training effectiveness and qualification.
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:
Category 1.
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are
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concerned with nuclear safety; licensee resources are adequate and l
are reasonably effective such that satisfactory performance with l
respect to operational safety or construction is being achieved.
i Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers l
nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory j
performance with respect to operational safety or construction is being i
achieved.
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III. SUMMARY OF RESULTS Performance Category Functional Area Assessment Category 1 Category 2 Category 3 1.
Plant Operations X
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Radiological Controls /
X Environmental Protection 3.
Maintenance X
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Surveillance and X
Inservice Testing 5.
Fire Protection X
and Housekeeping 6.
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Security and Safeguards X
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Refueling Activities X
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Licensing Activities X
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Quality Activities X
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Training X
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IV.
PERFORMANCE ANALYSES 1.
Plant Operations a.
Analysis NRC examinacion of this functional area consisted of parts of eleven inspections to evaluate compliance with Technical Specifi-cations and plant procedures. Two noncompliances were identified:
(1) Severity Level VI - containment sump drained using valve lineup not specified by orocedure (IR 81-23).
(2) Severity Level III - containment integrity violated via open inner personnel airlock and open manual valve through outer door frame (IR 81-28).
Escalated enforcement in the form of a $10,000 Civil Penalty was imposed for the second item.
Neither item was directly repetitive of noncompliance identified during SALP 2, but con-tinuing NRC concern relative to the lack of rigorous control of safety-related components, along with consideration of the occurrence of a previous significant containment integrity violation (SALP 1), influenced the decision to impose the Civil Penalty.
Five Licensee Event Reports (LERs) relating to this functional area were for events caused by personnel error (three events -
81-44, 81-50, 81-52) or procedural deficiencies (two events -
81-31, 82-17) and are therefore, considered preventable. This is half the number of similar items noted during SALP 2.
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the events resulted in the noncompliances stated above. Only
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two of the items (81-52: containment depressurization via air-lock, and 82-17: NaOH Tank low level) involved safety-related l
components being compromised. This is a significant improvement l
from the six events involving safety component inoperability (
which occurred during SALP 2.
The other three items involved potential component compromise which was prevented by timely licensee identification.
Management controls continued to improve as a result of con-tinuing implementation of program developments begun in SALP 2.
Improved planning and scheduling functions were developed and activities therefore generally exhibited evidence of prior planning and coordination.
The Severity Level III noncompliance
occurred in part due to a breakdown in the normal level of prior l
planning and coordination; but this appeared to be an isolated l
occurrence.
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Corporate management reviews of the area of plant operations (
included frequent visits by the responsible Vice President and daily auditing of plant activities, including plant operations,
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by a member of the corporate office continued in accordance with provisions of an Order originally issued during SALP 2.
Few technical issues relating to plant operations required resolution during SALP 3.
Those items initiated by NRC which depended upon licensee responsiveness were typically dealt with in a timely manner with acceptable resolutions being proposed.
The staffing level of licensed personnel continued at a lower than desirable level. The licensee has been striving to acquire additional NRC Reactor Operator licenses for selected personnel for some time.
Through SALP 3, this licensee effort continued to meet with limited success, such that the staffing situation ended the SALP 3 period about the same as it began.
(Training is addressed in Section 11)
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Conclusion The licensee is rated Category 2 in this area.
Strong management control and involvement continued during the assessment period.
However, staffing and training weaknesses still exist and need management's continued attention. One Severity Level III noncom-pliance occurred, but it appeared to be an exception to the general rule of improved planning and coordination of activities.
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Board Recommendations None.
2.
Radiological Controls / Environmental Protection a.
Analysis NRC examination of this functional area consisted of parts of fourteen inspections by the resident inspector and regional specialists to evaluate Health Physics Appraisal followup items, TMI Action Items, refueling radiation protection, operational radiation protection and radwaste, and confirmatory measurements.
Three items of noncompliance were identified:
(1) Severity Level V - Failure to follow radiation protection procedures concerning worker contamination surveys (IR 82-13).
(2) Severity Level V - Inadequate testing of fuel handling area llEPA filter efficiency (IR 82-10).
(3) Severity Level VI - Failure to report personal exposure information (IR 82-05).
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An additional weakness concerning maintenance, surveillance, and testing of air cleaning systems was identified (IR 82-10).
Due to this weakness several systems were incapable of meeting their original design intent.
The Confirmatory Measurements inspection showed one disagree-ment in thirteen comparisons. The disagreement, gross beta in liquid, was nonconservative and as of the end of the SALP period had not been resolved. The licensee's gamma spec-troscopy system in the low level counting room is evidencing deterioration by:
(1) a full width at half maximum value larger than normal for this size system (2) drifting; which necessitates the use of a wide energy tolerance for peak identification (3) distorted peak shapes In addition, electronic components have not been readjusted as necessary when other components have been repaired.
The licensee agreed to repair, adjust, and recalibrate the system.
No Operational Environmental Monitoring inspection was performed during this period.
The licensee had not completed corrective actions for the significant findings identified during the Health Physics Appraisal.
These findings were first communicated to the licensee in November 1980.
Only after repeated requests by Region III, including several telephone discussions with licensee management and discussions at management meetings conducted February 18, 1981, and February 17, 1982, did the licensee propose adequate corrective actions and implementa-tion schedules for these findings. NRC inspection disclosed licensee failure to meet the established implementation
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schedule. The licensee extended their implementation schedule by six months; subsequent NRC inspection disclosed licensee failure to meet the newly established completion date.
Five of the Health Physics Appraisal significant findings remained uncorrected at the end of this assessment period.
(Corrective actions have since been implemented.) The time required to correct the Health Physics Appraisal items is considerably longer than other Region III licensees.
Worker radiation exposures during this assessment period were significantly higher than the average for pressurized water reactors, both for total personrems and when normalized for power (personrems/MWe). Operational problems and accompanying main-tenance outages during the assessment period contributed to the high personal radiation exposures, but the licensee's failure to implement an effective ALARA program (a Health Physics Appraisal significant finding) appears contributory
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to the high personal radiation exposures.
In addition to failing to implement an effective ALARA program, the licensee suspended use of the minimal program in place at the beginning of the SALP period.
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Solid radioactive waste volume and activity and gaseous radio-l active effluent releases were about average for pressurized i
water reactors. Liquid radioactive releases were slightly lower than average. Three minor unplanned radioactive releases occurred during this assessment period. No radioactive material trans-portation problems were identified during this assessment period.
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Conclusion
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The licensee is rated Category 3 in this area. This rating
is based on the licensee's lack of responsiveness to the Health Physics Appraisal significant findings and for failure to conduct an effective ALARA Program, which apparently contributed to the high worker radiation exposures. This is a reduction in the licensee's performance rating over the previous SALP period and is the second Category 3 rating in the three SALP assessment periods to date.
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Board Recommendations
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NRC inspection effort in radiological control should be increased to the supplemental inspection program.
Inspections i
should focus on implementation of corrective actions for the Health Physics Appraisal significant findings and on imple-i mentation of an effective ALARA Program.
It is noted that a corporate radiation safety standard, developed near the end of the previous SALP period, was
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designed to effect uniformity and improvement of the individual plant radiation protection programs and to resolve NRC concerns identified during the Health Physics
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Appraisals. The corporate radiation protection standard has not yet been implemented at the Palisades plant.
Increased
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plant and corporate management attention should be directed to this area to ensure effective and timely implementation of commitments and program improvements.
An Environmental Monitoring Inspection should be performed during the coming SALP period.
3.
Maintenance l
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Analysis NRC examination of this functional area consisted of parts of eleven inspections to evaluate compliance with Technical Specifications and plant procedures. Two noncompliances were identified:
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(1) Severity Level IV - control rod drive mechanism misassembly resulting in primary system leak (IR 81-28).
(2) Severity Level VI - failure to follow administrative procedures for " emergency" maintenance (IR 81-28).
Escalated enforcement in the form of a $6,000 Civil Penalty was imposed for the first item.
Neither item was repetitive of noncompliance identified during SALP 2.
Coincident failure of two personnel (including a member of management) to perform their functions as specified in the requisite safety-related mainten-ance procedure contributed to the decision to impose a Civil Penalty for the Category IV item.
The licensee identified one LER associated with maintenance l
(LER 81-49) as being caused by personnel error and none as being caused by deficient procedures. The one item resulted in the noncompliance for CRDM misassembly stated above.
In evaluating LERs for this report NRC identified one (LER 82-13)
which appeared to be caused by a deficient procedure or per-sonnel error. Tape was left in or on a solenoid following maintenance, resulting in a subsequent failure of the control valve to close. The licensee had classified this item as due to component failure.
Two additional LERs (81-45 and 81-48) involved construction personnel adversely affecting installed plant equipment.
Three LERs involving construction personnel were identified in SALP 2, when far fewer construction personnel hours were spent onsite than during the current assessment period. Thus,
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the items involving construction personnel are not considered
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indicative of an adverse trend.
Management controls in the area of maintenance were generally strong evidencing prior planning, proper understanding and implementation of policies and procedures, and sound and timely reviews.
Inadequate understanding of policy relating to procedure signoff apparently contributed to the Severity Level IV noncompliance.
Other occasional examples of failure to follow procedures were identified and corrected by the licensee in his own reviews and did not result in noncompliance citations.
The licensee expanded procedure coverage of selected activities such that relatively less reliance had to be placed on vendor manuals as procedural controls. Additional expansion of procedure coverage is needed and is planned.
As intended, the licensee's Planning and Scheduling organiza-tion has affected maintenance more strongly than other functional areas.
Improved coordination of activities has resulted in a
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1 significant reduction of " overdue" preventive maintenance activities and better control of routine corrective maintenance and special outage-only maintenance.
Staffing and training in the maintenance area appear adequate, though first-line supervisory positions are not always filled expeditiously nor with the most experienced personnel, b.
Conclusion The licensee is rated Category 2 in this area. Management control appears improved overall, but occasional breakdowns are evidenced in procedure violations. Additional expansion of procedures remains necessary, c.
Board Recommendations Expansion of maintenance procedures should continue to be followed under the licensee's Regulatory Improvement Program.
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Surveillance and Inservice Testing i
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Analysis Due to previously identified significant programmatic problems this area received a high level of attention by both the licensee and the NRC inspection program.
NRC examination of this functional area consisted of parts of thirteen inspections to evaluate compliance to Orders, Technical Specifications, and plant procedures. Two minor noncompliances were identified:
(1) Severity Level V - using noncalibrated hydrometers for l
testing station batteries (IR 82-07).
(2) Severity Level V - failure to perform monthly AFW flow channel comparison in May 1982 (IR 82-15).
Both items were identified in the second half of the SALP period. Neither item was considered particularly significant or symptomatic of significant underlying causes, was directly repetitive of previously identified noncompliance, nor involved compromise of safety-related equipment.
This enforcement record is dramatically improved from the previous SALP, when ten noncompliances were identified, includ-j
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ing several significant items for which escalated enforcement was required.
Six of the noncompliances identified in the previous SALP also involved safety component compromise.
No licensee Event Reports (LERs) identified in this area were caused by personnel error or procedural inadequacy. This compares favorably with three such events in the previous SALP.
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The licensee continued implementation of his program for improvement of regulatory performance during this SALP period, along with implementation of another Order requirement for special monthly surveillance of safety equipment status outside
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the control room. The quality of surveillance procedures was i
maintained at a high level, though two potential problems became evident. First, difficulties in interpreting license j
requirements arose for selected cases of safety components
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being out of service. As part of the Regulatory Improvement Program, the licensee developed an LCO matrix manual for selected specifications late in this SALP period to aid in these interpretations.
Second, licensee administration of the test scheduling function on the primary basis of frequency
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rather than on the basis of plant condition, was of some con-l cern to inspectors because of the inherent potential for omission of required testing when plant conditions change
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frequently as they did during this SALP. This is considered an underlying cause of the second noncompliance noted above.
Overall management controls in this area were considered effective; resulting in typically very good procedure adherence,
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review and documentation.
Licensee responsiveness to technical
issues and NRC initiatives in this area was generally good.
Work was begun on conversion of the Palisades Technical
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l Specifications to " standard" format which should result in j
surveillance program improvement.
i In the area of staffing or training no significant strengths or weaknesses were identified. However, the training and qualifi-cation program available for surveillance and inservice testing appears to have been effective in the reduction of personnel l
errors and failure to follow procedures identified in the previous SALP period.
b.
Conclusion
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The licensee is rated Category 1 in this area. The licensee j
has developed and is implementing a program for completion, I
review, and documentation of required testing while avoiding adverse impact on the systems or components being tested. A
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very good regulatory and reportable event history has resulted.
This is a significant improvement over the previous SALP assessment.
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Board Recommendations
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The inspection program should be reduced over the coming SALP
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l period to the Basic inspection program level. Continued licensee attention is recommended to ensure continuation of the high level of performance.
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Fire Protection and Housekeeping a.
Analysis Determination of compliance to fire protection requirements and of good housekeeping practices was an associate part of eleven inspections in which operations and/or maintenance were examined by the resident inspectors. There were no inspections of fire protection activities by Region III specialists. The licensee has not yet been inspected for compliance to new requirements applicabic to Palisades contained in 10 CFR 50 Appendix R.
The licensee did complete selected plant modifications required under Appendix R during the refueling outage, but these have not been thoroughly examined by NRC as yet.
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Two items of noncompliance were identified in this area:
(1) Severity Level V - construction personnel welding without readily accessible fire extinquisher (IR 81-23).
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l (2) Severity Level VI - open fire barrier penetration (lube oil room door) without establishment of firewatch (IR 82-01).
l These items of noncompliance are not repetitive of previously identified noncompliance, but they were common in that the i
individuals involved failed to recognize what are considered usually well stated, disseminated and understardable require-ments.
A possible contributor to the first item is the absence (
of a specific " hot work" permit system. However, the licensee
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normally expects personnel to be fully aware of fire protection requirements through training combined with appropriate refer-ences in applicable work instructions or procedures.
In addition, the licensee utilizes a fire protection specialist to make frequent independent reviews and on-the-job checks. This normally results in prompt and consistent corrective action where required.
The inspectors observed several in-house drills and one drill involving off-site fire fighting personnel, as well as several fire fighting live training sessions. A potential problem l
relating to fire brigade leader designation and functioning I
was observed during a major exercise involving the offsite local fire department. This was discussed with the assigned licensee management.
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In general, housekeeping conditions declined during this SALP period compared to the previous period. There were increased construction personnel and activities onsite during the current period, especially during the major outage, which contributed
to the development of generally messier conditions over the i
first half of the period. Thereafter, the licensee appeared
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unable to restore cleanliness conditions to the level estab-
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lished prior to the major outage. On more than one occasion during facility tours the resident inspectors identified poor housekeeping conditions of which the licensee was apparently unaware. The degradation in housekeeping conditions appeared greater than warranted for overall plant activities.
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No LERs, caused by personnel error or deficient procedures relating to fire protection or cleanness were reported. This is a good record considering the amount of hot work and the number of involved personnel, especially including construc-l tion personnel, onsite during the major outages.
No staffing problems were evident in review of this area. As noted during the previous SALP, the licensee has a strong fire protection and firefighting training program.
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Conclusion The licensee is rated Category 2 in this area. This is a j
deterioration in performance from the previous SALP period and is due mainly to the observed degradation in plant housekeeping.
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c.
Board Recommendations
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The licensee should be inspected under 10 CFR 50, Appendix R l
during the coming SALP period.
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a.
Analysis NRC examination of this functional area consisted of parts
of five inspections to evaluate compliance to 10 CFR 50
l Appendix E Technical Specifications, and procedures. One j
item of noncompliance was identified:
Severity Level V - failure to perform routine testing of systems for emergency communication to NRC (IR 82-08).
Within this time frame, an Emergency Preparedness Appraisal was conducted from September 21 through October 3, 1981, and a full scale emergency exercise conducted on February 23, 1982, was observed. An initial inspection and testing of the prompt public notification / warning system was conducted prior to February 1, 1982, wherein inspectors confirmed that the
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licensee had installed 81 sirens and successfully tested them within the 10 mile Emergency Planning Zone (EPZ).
Licensee written replies to the Confirmation of Action Letter accompanying the emergency preparedness appraisal report have been timely and adequate in addressing the four significant deficiencies which included minimum shift staffing, prompt public notification system including the ten mile EPZ, revision of certain Emergency Operating Procedures, and
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l development of a satisfactory public information brochure.
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Two other significant deficiencies relating to Emergency Implementing Procedures and evacuation of owner controlled areas were also identified in the appraisal. Timely replies
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j to these items were received.
I A followup inspection on the appraisal findings was made in June 1982 to verify that corrective actions were made on items addressed in the previous paragraph. Also other open items and emergency preparedness improvement items were reviewed. No new
concerns were identified and the licensee appeared to be making satisfactory progress in resolving the appraisal findings and other open items.
A full scale exercise conducted February 23, 1982, resulted in
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twenty-three deficiencies being identified. Four significant items were: scenario deficiencies; inadequate management and direction provided to licensee's controllers; inadequate man-agement of the Operations Support Center (OSC); and inadequate activation of the Emergency Operations Facility (EOF). The licensee's reply received in 60 days (June 2, 1982) rather than the requested 30 days addressed these deficiencies. The inspectors general observations were that due to the simplistic scenario the licensee conducted a weak exercise which did not fully involve operational, technical, maintenance and radio-
,
!
logical specialists.
!
Management involvement at the plant level was satisfactory;
,'
however, corporate responsiveness and timely actions to initiate changes required by the NRC for emergency preparedness needs improvement.
b.
Conclusion i
The licensee is rated Category 2 in this area.
c.
Board Recommendations
!
l Although the licensee overall performance is rated Category 2, licensee performance during the exercise was marginally acceptable
,
warranting increased attention by both management and NRC.
7.
Security and Safeguards n.
Analysis
,
One Material Control and Accountability Inspection and a security-related investigation have been conducted by region based inspectors during the assessment period. The investi-
!
gation was conducted in response to various allegations
!
regarding plant security. The resident inspectors made periodic tours of accessible protected and vital areas. Two i
noncompliances were identified:
i
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t
i
- - - -. - - -. - -
. - -...... - -.
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.
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-
- -
_
-_
.
.
_. _. - _. =
_.
-
..
-
-
.
i i
I (1) Severity Level V - failure to properly maintain docu-mentation of all routine security tours to include the name of the individual making the tour, date and the results of the tour (IR 81-14).
(2) Severity Level V - failure to prohibit access to vital areas for purposes of general familiarization and other
'
nonwork related activities (IR 81-14).
In addition to the above noncompliances, the investigation
identified deviations from security force procedures and various concerns regarding performance of the security force. The investigation findings were indicative of inadequate supervision and a breakdown in management control.
In response to NRC concerns, the Licensee's Property Protection Department conducted its own audit / investigation
'
into these matters. The audit confirmed the lack of effective supervision over the security force; the ineffective lines of communication among licensee management; the contract security force; and serious morale problems. The audit report identified
the corrective actions taken or planned. The audit was thorough
'
and demonstrated the licensee's willingness to cooperate in resolving the problems identified.
The major Safeguards tasks facing the licensee are the full implementation of 10 CFR 73.55, Appendix B, training re-
quirements, and the selection / installation of an effective exterior perimeter alarm system to replace the existing one which has been found to have recurring deficiencies.
b.
Conclusion The licensee is rated Category 2 in this area. This is based,
!
in part, on their responsiveness to the concerns identified above.
c.
Board Recommendations The Board notes that subsequent to the assessment period an i
inspection substantiated that the licensee had implemented planned improvements.
,
!
8.
Refueling Activities
.
a.
Analysis Refueling was examined as part of three inspections to determine compliance with Technical Specifications and plant procedures.
One item of noncompliance (with two examples) was identified:
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i
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.
.
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i Severity Level V - refueling activity procedures not followed in:
(1) changing speeds on fuel inspection j,
elevator gearbox, and; (2) completing all shiftwise checklist data recording (IR 81-23).
One of the two nonompliances relating to the previous refueling (during SALP 1) also involved a failure to follow procedures The items are not considered especially significant taken either
separately or in series; it appears procedures and' policies in this area are rarely or only occasionally violated. On the other
.
hand, some problems relating to understanding documentation re-j quirements were noted in review of records. This is a negative indication with respect to staff training or qualifications, and may be reflection of the lack of separate specific training pro-
.
'
grams for refueling activities. Training deficiencies apparently contributed to both examples cited in the above noncompliance.
,
Management involvement in refueling functions appears more distant than for power operations activities. The reactor engineers, who are not normally in the operations management chain, were heavily j
relied upon for development and implementation of policies and procedures, ongoing oversight and review of activities being
,
!
impicmented, and independent verifications. Timely review of developing documentation was not always completed, such that
j minor documentation inconsistencies went unrecognized, and some
!
records were misplaced at least temporarily.
Two problems involving fuel handling activities were experienced.
A fuel shuffling error resulted in two mispositioned bundles
!
which were subsequently identified and properly relocated as a function of the licensee's independent verification process. The other item involved bumping of a control rod handle with the re-fueling machine mast during a move, such that the handle was bent and the rod had to be replaced with a spare. Contact between a rod and the mast should not be possible if the machine is working properly and the rods are full in.
The licensee believes the rod in question had been partially lifted and " hung up" during a previous move. The procedures were changed to prevent contact even with a partially withdrawn rod by requiring full withdrawal of the mast for moves over the core.
No LERs were identified in this area as caused by personnel
!
error or procedural inadequacies.
The general shortage of licensed operators noted in Section IV.1 also affected refueling contributing to work backlogs and extended use of overtime.
c.
Conclusion The licensee is rated Category 2 in this area. A good regulatory and reportable event history was achieved, but some weaknesses were noted in staffing, training, and day-to-day management control functions.
. - - -
-
. --
- - - - - - -.. - -
. - -.
- - - -
- - --
..
c.
Board Recommendations None.
9.
Licensing Activities a.
Analysis This evaluation was based on review of the following licensing activities:
-Responses to NUREG-0737 items-Appendix R activities-Core reload and fuel performance-Inservice inspection / inservice testing-Degraded grid voltage-Operator licensing-Systematic Evaluation Program-ESF reset-Control of Heavy Loads-Equipment qualification-Steam Generator leakage limits-Snubber Technical Specifications It is evident that management efforts are effective in accomp-lishing a good quality evaluation and submittal for the tasks that are high priority.
In general, the priority assigned to licensing activities is appropriate to the significance of the issue. The performance in responding to NUREG-0737 and l
equipment qualification were especially good examples of man-
'
agement commitment and planning. A licensee representative was assigned to work at the Bethesda office of the NRC to expedite completion of SEP for Palisades and this effort did assist in
,
Palisades being the first plant to complete the program.
l l
This licensee makes an attempt to understand regulatory requirements and puts forth a reasonable effort to meet them.
If a conflict arises, the licensee is amenable to working out a resolution which would meet the intent of our requirements but not have an undue adverse impact on the plant's operation.
,
!
In general, mutually agreeable resolutions are reached without much difficulty.
For those licensing actions of high visibility and, therefore, high priority, the licensee's responsiveness is very good. For the more routine type of licensing activities, however, such as l
informal requests, commenting on draft safety evaluation reports and NRC positions, long standing generic activities, etc. there is some lack of responsiveness. Typical activities that exhibit this shortcoming are:
inservice test program, charcoal filter Technical Specifications, control of heavy loads, and descrip-tion of purge and vent modifications.
It is recognized that placing high priorities on the " issues of the day" does produce good results. However, some additional attention is needed for
.
- -
..
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.
. -
- -
._. _-
..
1*
l I
i l
I ensuring that the lower priority activities maintain sufficient
!
activity to move them toward resolution. Followup on informal
'
commitments made during telephone calls and meetings needs
improvement.
]
Events are usually reported in a timely manner with either a full
!
explanation of the event and its corrective measures or a followup
!
report closing out the issues.
!
The staffing appears adequate for most high priority issues.
'
However, manpower limits may prevent work from proceeding on
tasks other than those of the highest priority.
'
b.
Conclusion l'
l The licensee is rated Category 2 in this area. This improved rating from the previous SALP is indicative of increased man-l agement attention and responsiveness to licensing activities.
l Management involvement expedited completion of the Systematic
Evaluation Program for Palisades during this period. The
'
licensee addressed several high priority activities such as response to NUREG-0737, equipment qualification, and fire pro-tection in a professional and timely manner. Technical issues
!
i are readily resolved on most matters. Some attention is needed I
to direct efforts on generic issues of moderate priority, some of which are long standing.
Followup on informal commitments
,
j made in telephone calls and meetings needs improvement.
I c.
Board Recommendations i
!
None.
l 10.
Quality Activities a.
Analysis i
This area was examined as part of eight NRC inspections to l
determine compliance with Technical Specifications, procedures, l
the Quality Assurance Program, and codes and standards.
l Specific areas examined in part were: procedures; calibration; i
procurement; committee activities; corrective action; reporting; l
review and audit; organization and administration; and design changes. One item of noncompliance was identified:
l Severity Level V - administrative procedures for modifi-
!
cations and setpoint changes not adhered to (IR 82-13).
Regulatory performance was significantly improved in this func-l tional area compared to SALP 2, when nine items of noncompliance
!
were identified. Further, the noncompliance identified in this appraisal period does not appear programmatic in nature, thus
'
being less significant than selected items identified in the previous period.
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I I
!
e
_
- _ _ _.____ _ ___ _ _._ _ _ _ _ _, - _. _,
_
. -, _ _.
_ _ _ _ _ _ _ _ _ _, _,.. _ _ _ _,
-
-
.- _
-
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..
No LERs were identified in this area as being caused by per-sonnel errors or poor procedures. The licensee's program for identification, classification, and reporting of LERs continues to be effective. Differences in classification of events by cause, comparing licensee and NRC opinion, are infrequent i
and do not appear systematic. Noncompliances identified in review of reportable events are discussed under the functional areas to which they were assigned above.
The licensee submitted and received approval of a new QA Program topical report during this SALP period. This appeared to improve clarity of management policy in this area. Corporate management involvement in quality activities addressed some concerns iden-tified during the previous SALP assessment appraisal:
}
(1) Auditing schedules for proper completion of required audits were redeveloped and the schedules were being met.
(2) The corrective action system was upgraded to improve management involvement and overview.
The second item above was performed as part of the licensee's
,
ongoing Regulatory Improvement Program, which also included work on other areas such as: development of Nuclear Operations Department (NOD) standards to integrate the QA Program with
other requirements; development and beginning implementation of improved NOP training programs; and evaluation of safety audit
,'
program effectiveness. Some of these activities are complete while others remain underway.
i Licensee action during this SALP resolved a programmatic weakness previously identified, when authority to bypass QC hold points simply on inspector unavailability was deleted.
There was also a significant improvement noted in storage of
{
test and measuring equipment.
The corrective action system remained ambitious and program-matica11y strong. The licensee developed and implemented a
,
process involving a Corrective Action Review Board (CARB) at i
the front end of the system to streamline and consolidate
!
involvement of the principal functional managers. This has i
improved timeliness of processing and reduced ambiguity in assignments of responsibility. Some of the earlier concerns,
relating to poor understanding and little appreciation of the j
corrective action system by many of the plant staff, were not l
completely resolved.
It appeared progress was being made,
!
however.
Plant records were generally found to be well maintained.
An exception to this involved unavailability of a number of
'
'
training records early in the SALP period.
Documentation of calibration activities was specifically noted to be improved.
!
'
_ _ - - _ _ _ _ _ _ _ -, _ _ - _ _. - _ - - _ _ _ _ _. _
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.
No particular procurement problems were identified in general reviews performed by the resident inspectors. However, in
the case of one plant modification (containment purge lines)
components were installed, tested, and considered available for service (though not actually used) before it was learned some quality documentation was lacking.
In other cases, including two leading to reports under 10 CFR Part 21, licensee reviews or checks identified potential problems before any reliance was
placed on questionable equipment.
i j
Committee activities appeared to be functioning properly.
The
!
inspectors expressed a concern about the licensee practice in permiting personnel to serve as onsite review committee members who have not had orientation or training specifically covering
,
related requirements and who do not have specific minimum qualifications for membership other than by job title. Although this creates some potential for problems in the conduct of review committee business, the licensee practice is permitted by the
,
l Technical Specifications and no problems were observed. Major monthly meetings generally involve the same experienced personnel.
'
'
b.
Conclusion i
The licensee is rated Category 2 in this area. This rating represents an improvement over the previous SALP assessment and reflects management's efforts in correcting many of significant
.
programmatic problems.
Other needed improvements have been
{
identified by the licensee and progress is being made in these
areas.
c.
Board Recommendations l
A general QA inspection should be scheduled to verify implementation of the licensee's newly revised QA Program.
11.
Training a.
Analysis This area was examined as part of four inspections by the resident inspectors and regional based specialists. Within the scope of these inspections one item of noncompliance was identified:
Severity Level V - required training and documentation was not completed (IR 81-16).
As part of the licensee's Regulatory Improvement Program, commitments were made to revamp thd whole training organization structure and program for the company's nuclear power facilities with the program falling under corporate direction. This effort l
included a new training center at the Midland site, plant
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specific simulators, increaseJ staffing and restructure training programs. To date the licensca has met all milestone commitments.
,
~
Notwithstanding the significant improvements inshoth physical facilities and staffing rescarces for trainiDg, there has been little evidence of change at the plant site and training prog. ram implementation continued tq be a weak area.
For example, '
licensed operator requalification was being cheduled at the minimum required levels rathor than at the level yltimqtely intended.
Three of five candidatys taking operatut' licence'
examinations f ailed to pass,. _.reqqjring retraining' in order' to retake the test.
The one candidate for a senior raawtor
~
operator license succ7ssfu11y passed his test.
. _.,
.
-
.
,.s,
'
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Although minor, the item of noncqsp),iance wqs'a repeat item
.
~
,_
in that for three construtive inspections tk81ning was not being conducted as required by Chapter 13 of the-Administrative J-c Procedures.
-
s
'
Training records were very difficult to retrievt because they
'
-
were still packed in cardhuard boxes after m.iclofilming at the corporate headquarters in' Jackson, Michigan. The content and quality of training sessions observed by,EFC innFoctors OEt '
-
'
.,
mixed, with two sessions considered good and,vndi.onsidered poor.,
w
_
b.
Conclusion
-
'
-
The licensee is rated Cotogory J~in this area.
Signif1 3nt
<
improvements have been made In the rpy4mp,ing-of.the oVorall Z
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_
corporate training program; however, implementation of traintag '
"N
,
programs at the plant site has not I.cceived the paralleled
,
attention it should have..This lack nf progress in the imple-mentation of the site tryining program has dstractod trom an
'
otherwise ambitious and neede4 plan for improved, tiaining.
_.
,
'
c.
Board Recommendations
' s-
-
s An inspection of the overall training area shculd be coudacted as soon as possible.
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.
V.
SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data Facility Name:
Palisades Docket No. 50-255 Inspections:
No. 81-12 through 81-29 No. 82-01 through 82-15 Noncompliances and Deviations Severity Levels Functional Area Assessment I
II III IV V
VI Dev.
_
1.
Plant Operations
1
-
2.
Radiological Controls /
1
'
Environmental Protection 3.
Maintenance
1 4.
Surveillance and
Inservice Test:
5.
Fire Protectic n mad
1 Housekeeping
Security and Safeguards
-
8 '.
Refuell'ng Activities
9.
Licensing Activities 10. QualiLy Activities
_
'
-
11. Traibir.6
..
TOTALS,
0
1
4
,
The-total number of noncompliances was less than half that identified
.during SALP 2 (17 vs 36).
,
.
.
mh r
%
~%.
%
~
s
.
21'
.
s
,
O
%
-
I
.
B.
Licensen_ Report Data 1.
Licensee Event Repory LERs No. 81-28 through 81-53 No. 82-01 through 82-19 Licensee Proximate Cause Code Assignments:
Cause Type SALP 1 SALP 2 SALP 3 Personnel Error
8*
Design Deficiency
2
Defective Procedures
7
Component Failure
32**
Other
5
Total Number
54
- Two events also included in SALP 1 due to overlap.
- Three events also included in SALP 1 due to overlap.
Discussion:
No statistical trend is evident from a review of LER numbers fo; the various cause codes; however, the significance 1cvel of the reported events associated with personnel errors and defective procedures has been trending downward.
This represents continua-tion of a trend apparently developed in the second half of the SALP 2 period.
The major cause category for reportable events was component failure, as expected for most licensees. The rate of component failures yielding reportable events was slightly lower than during the previoun SALP period; however, there appears to be no statistically valid trend. The major categories of equipment failures were containment penetrations (six events), engineered safety features (five ovents) and snubbers (ten events), with the occurrences being fairly evenly distributed over ti.ne.
,
'
Instrument and emergency electrical system failures did not recur at the frequency observed in the previous period.
2.
Part 21 Reports l
Part 21 reports generated as a result of activities or findings at the Palisades site during this evaluation period were cs follows:
a.
Inadequate welds on mounting racks for station batteries -
racks manufactured by C and D Battery Company.
b.
Emergency diesel generator governor misassembly - Woodward Governor Company.
Corrective actions for the specific problems noted at Palisades were properly completed.
Generic evaluation of the items by NRC has not been completed.
Both items were identified through the licensee's quality review processes prior to accepting the components for service; i.e.,
reliance was never placed on the deficient components.
C.
Licensee Activities 1.
Operations The Palisades plant routine power operations was intermittant during this SALP period.
A major scheduled outage for plant rofteling, modification and maintenance was conducted from August 29 through December 31, 1981.
Other plant outages are summarized below, a.
July 12 - August 9, 1981:
maintenance on primary coolant pump and control rod drive seals b.
January 24-30, 1982:
correction of steam generator chemistry problems from caustic intrusion c.
February 4 - March 4, 1982:
repair damage from hydrogen explosion in main generator exciter d.
March 12-17, 1982:
repair main transformer iso phase bus overheating damage March 24 - May 10, 1982:
investigate and repair l
e.
l Icaking steam generator tubes f.
May 12-26, 1982:
replace damaged permanent
!
magnet in generator; repair failed shaft bearing g.
June 12-14, 1982:
repair small primary coolant pump oil leak There was one restriction on plant operations during this SALP period. The steam generator tube leakage limit was reduced to 0.1 g:>m for the remainder of Cycle 5.
Closed circulating water system efficiency conditions resulted in slightly reduced power i
output during hot weather.
23 l
l l
.
l 2.
Modifications The licensee completcd modifications to several important systems during the SALP 3 period; primarily during the scheduled refueling outage.
a.
Auxiliary Feedwater:
separate dedicated supply headers were routed to new spargers inside the steam generators to supply the generators directly instead of via the main feedwater lines; a redundant parallel valve was added in the pump suction line; and system auto-start and flow control circuitry was upgraded to safety grade.
b.
liigh Pressure Safety Injection:
provided with hot-leg injection capability for long-term cooling after a LOCA.
c.
Low Pressure Safety Injection:
taps added to enabic check valve integrity testing; motor operators installed on pump suction valves.
d.
TMI Lessons Learned:
reactor vessel head vent installed; assorted shield walls and plugs constructed; and contain-ment wide-range pressure and water level monitoring system installed.
c.
Containment:
new, smaller purge lines and valves (capable of operating against design basis pressures) installed.
f.
Block Walls: miscellaneous re-inforcements found necessary under review per IE Bulletin No. 80-11.
g.
Class 1E Electrical System:
new, larger capacity station batteries installed.
Additional modifications begun but not completed during the period included:
auxiliary building addition (Technical Support Center and air handling equipment); miscellaneous TMI post-accident sampling and monitoring systems; and an asphalt-base liquid radwaste solidification system.
3.
Systematic Evaluation Program Palisades was the first of the plants involved in the NRC Systematic Evaluation Program (SEP) to complete the "integr-ated assessment" review. The SEP evaluations were essentially completed during the SALP 3 period; such that the effort on SEP has shifted from evaluation to resolution of identified discrepancies. This will include procedure and Technical Specification changes and some plant modifications.
i
f
.
D.
Inspection Activities One major team inspection, the Emergency Preparedness Appraisal, was performed, resulting in a substantial increase in inspection effort in that functional araa.
In other areas the increased inspection effort of SALP 2 continued at approximately the same or slightly reduced levels during the SALP 3 assessment period in response to previous SALP findings.
E.
Investigations and Allegations Review One investigatio..
as conducted during this SALP period, to review allegations regaraing the Palisades security program.
Instances of inaccurate records and irregularities in the performance of some security activities were identified, as were two items of non-compliance. Concerns relating to supervision of the contract security force and compliance with established procedures were brought to the licensee's attention for appropriate action.
F.
Escalated Enforcement Action 1.
Civil Penalty A Civil Penalty in the amount of $16,000.00 was imposed in 1982 for noncompliances involving:
misassembly of a control rod drive seal housing, and a brecch of containment integrity via opening of the inner personnel airlock door and a manual valve through the outer airlock door frame.
2.
Orders Previously issued orders (November 9, 1979 and March 9, 1981)
remained in effect with minor modifications. Compliance was routinely verified by the resident inspectors. No new enforcement Orders wcre issued.
G.
Administrative Actions l
.
1.
Confirmation of Action Letters j
l A Confirmation of Action Letter was issued October 7, 1981, following the Emergency Planning Appraisal to confirm licensee short-term actions in response to significant Appraisal
,
findings.
2.
Management Conferences a.
July 9, 1981 (Glen Ellyn, Illinois):
Status meeting on licensee implementation of program for regulatory performance improvement.
,
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25 l
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O
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b.
September 22, 1981 (Palisades Plant site):
Same as above - attended by NRC Commissioner Victor Gilinsky.
c.
December 17, 1981 (Glen Ellyn, Illinois):
Enforcement Conference for discussion of noncompliances identified December 11 (CRDM misassembly) and December 14 (containment integrity violation).
d.
February 17, 1982 (Glen Ellyn, Illinois):
Status review of licensee's Regulatory Improvement Program.
c.
March 31, 1982 (Palisades Plant site): Evaluation review of December 1981, noncompliances.
f.
April 14, 1982 (Jackson, Michigan): Systematic Assessment of Licensee Performance (SALP), July 1, 1980 to June 30, 1981.
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