IR 05000255/1986035

Insp Rept 50-255/86-35 on 861216-870216.Violations Noted: Inadequate Review of Mod Package,Inadequate Procedures for Conduct of 10CFR50.59 Evaluations & Failure to Identify Modified Breakers as Class 1E

ML20214R882
Person / Time
Site:	Palisades
Issue date:	05/28/1987
From:	Anderson G, Dunlop A, Guldemond W, Norelius C, Reynolds S, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214R879	List: IR 05000255/1986035 ML20214R876
References
50-255-86-35, NUDOCS 8706090041
Download: ML20214R882 (118)

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-255/86035(DRP)

Docket No. 50-255 License No. DPR-20 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name: Palisades Nuclear Generating Plant Inspection At: Palisades Site, Covert, Michigan Inspection Conducted: D ber 16, 86 through February 13, 1987 Inspectors: .D emeN 27 7 Date

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'H. A. Wa Team Me ber J/AP/f)

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A 8M)tdd S. A. Reyn 1 , Team Member $/28M7 Date

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. emond, eam Leader Date Approved By:

.Y NO C. E.'Norelius, Director S/2f/f7 Division of Reactor Projects Date Inspection Summary Inspection on December 16, 1986 through February 13, 1987 (Report No. 50-255/86035(DRP))

Areas Inspected: Special announced team inspection of plant readiness for restart; licensee response to a request for information pursuant to 10 CFR 50.54(f); licensee actions in response to Safety System Functional Inspection Team findings, and licensee action on previous inspection findings.

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Results: In the areas inspected, five violations were identified (inadequate review of a modification package, inadequate procedures for conduct of 10 CFR 50.59 evaluations, failure to identify modified breakers as Class 1E, inadequate emergency response procedures - Paragraph 6, and failure to comply with temporary procedure change requirements - Paragraph 4). Overall the team concluded that the material condition of the Palisades plant had improved sufficiently to support restart and that adequate assurances existed that an acceptable level of material condition would be maintaine :

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EXECUTIVE SUMMARY NRC concerns over the effectiveness of maintenance and the material condition of the Palisades facility were first expressed in the SALP 5 evaluation which concluded that, with regard to maintenance, overall performance declined as evidenced by the increased backlog of maintenance items and the observed condition of equipment. In the most recent SALP Report for Palisades, which covered the period November 1, 1984 through October 21, 1985, the areas of Maintenance, Surveillance, and Quality Programs and Administrative Controls declined from a rating of Category 2 to Category 3 due to a lack of aggressive corrective action by the licensee and poor management controls and attitude The weaknesses identified were reflected in plant performance problems including numerous and repetitive valve leakage problems. As a result of these problems, a management meeting between Consumers Power Company and the NRC was held on March 6, 1986, and, based on this meeting and a subsequent conference call, the licensee elected to shut down and repair these problems on March 8, 198 On April 10, 1986, Palisades again shut down after exceeding the Technical Specification limit for unidentified primary coolant system leakage. During return to power operation on April 11, 1986, the licensee identified a packing failure on Condensate Pump "A." The pump was repacked twice prior to replacement on April 19, 1986, with an onsite spar On May 19, 1986, the Palisades Plant was operating at approximately 97 percent of full powe The unit had been at power for over a month following restart from the forced outage of April 10, 1986. Shortly before 2:16 p.m. (EDT) on May 19, 1986, both primary and secondary Electro Hydraulic Control (EHC) power supplies tripped, allowing the main turbine governor to valves to drift closed and resulting in a reactor trip on high pressurizer pressur Following the trip, numerous pieces of plant equipment failed to function as designed

including the 1/Jrbine bypass valve, a steam generator atmospheric dump l

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valve, a rod bottom light, and a charging pum , _

The licensee notified the Nuclear Regulatory Commission, pursuant to 10 CFR 50.72, of the plant trip and attributed it to a loss of turbine load. Subsequently, licensee determined the initiating reactor trip signal to be pressurizer high pressure and that this required the declaration of an Unusual Event (UE). This clarification was subsequently made to the NRC via the ENS. During each ENS telecon between the plant and the NRC Operations

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Center, the NPC Duty Officer asked the plant if the trip was normal and if everything thactioned properly. Each time the plant responded that the trip was normal and everything functiened properl The plant was stabilized i-n Hot Shutdown pending post trip review and evaluation of equipment failures. The post trip review was completed and the plant taken critical at 3:03 a.m. on May 20, 1986.

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Executive Summary 2 On May 20, the day after the_ trip, the licensee began informing-the NRC of the various equipment malfunctions which occurred following the trip. Based on this information, the recent poor performance of the Palisades Plant as a result of. equipment problems, and the outstanding concerns held by the NRC'

regarding maintenance and lack of conservatism regarding operating decisions, Region III contacted the licensee _and questioned the licensee's decision to restart the plant. During the ensuing discussion, the licensee agreed to take the plant to cold shutdown, investigate fully the causes and implications of the equipment failures following the May 19 reactor trip, and conduct a thorough investigation of plant safety systems and balance of plant systems important to safety regarding operability and required maintenance. Restart was not to occur without Region III concurrence. These commitments were confirmed in a Confirmatory Action Letter (CAL) (CAL-RIII-86-002) dated May 21, 198 In addition to the CAL, on May 22, 1986, Region III dispatched an Augmented Investigation Team (AIT) to the site to review the circumstances surrounding the continuing equipment problems. The following significant facts were

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ascertained by the AIT:

• Significant weaknesses exist in three aspects of the maintenance function

- diagnostics, repair, and post maintenance testin * Plant operators have serious concerns regarding the adequacy of

maintenance activities and equipment reliabilit * Equipment failures and degraded equipment have placed varying levels of additional burden on the plant operators. With regard to the May 19 trip, this burden did distract operators, but did not significantly jeopardize plant safety.

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• There is a lack of communication and coordination for a maintenance activity from the Work Request stage through verification testing and acceptance for operation.

l During the performance of the corrective maintenance activities and the

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augmented testing that was instituted as part of its post trip commitments the licensee found and reported the NRC certain deficiencies in safety system design capabilities. In addition, the NRC conducted a Safety System Functional Inspection (SSFI) of the high pressure safety injection system during September and October of 1986. The findings of that inspection raised questions about compliance with design bases; adequacy of the test program as it relates to the interfaces between safety-related and non safety-related systems; lack of pieve.ii.ive maintenance, especially lubrication of motor-operated valves; and lack of training provided to maintenance craft personnel.

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Executive Summary 3 Because the problems identified by the licensee and the SSFI findings raised questions regarding facility conformance to design bases, on November 20, 1986, Region III issued a request for information to the licensee pursuant to 10 CFR 50.54(f) (50.54(f) letter). Specifically, the licensee was directed to evaluate and address the results of inspections, investigations, maintenance, and testing performed following the May 19 trip; the lessons learned from these activities; and management system, programmatic, and hardware changes made or planned as a result of these activitie The licensee's response detailed those actions taken and planned to ensure that the condition of the plant would support restart, and programmatic changes taken and planned to improve plant performance. Because that response lacked necessary detail regarding corrective action program structure and implementation schedules and because the licensee had not adequately addressed the issue of pre and post-restart testing, on December 23, 1986, Region III issued a request for additional information pursuant to the November 20, 50.54(f) letter. The licensee responded to this request on January 28, 198 Following the December 9 meeting, Region III commissioned a plant restart inspection effort. This effort was broken into two parts. The first part, plant readiness, was performed to independently assess plant performance capability and actions taken to ensure that that capability is maintaine The second part of the inspection effort will focus on staff capabilities, training to support plant operations, and implementation of the restart testing progra The plant readiness inspection focused on the following three questions:

• Have known equipment / material problems been appropriately dispositioned?

• Has the potential for additional equipment performance problems been adequately assessed?

• Have adequate plant demonstrations been completed or are they appropriately planned?

In answering these questions, the inspection team arrived at the following conclusions:

• While some progress has been made in establishing the proper threshold for entering deficiencies into the work request system, desired standards are not being consistently adhered to. In discussions with the plant

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operators, it was clear that management had communicated appropriate i expectations. It was also clear that operators had yet to fully embrace

those expectations. Nonetheless, toward the end of the inspection, the

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• The licensee currently has in place the administrative mechanisms which require that the root causes of equipment malfunctions be determine The inspection revealed that reasonable efforts were being made in this regard.. The licensee also has in place the mechanisms to ensure that corrective action is appropriate and appropriately scope * The licensee had in place the necessary administrative mechanisms to support an effective preventive maintenance (PM) program; however, the PM program is is still in its infanc The licensee does appreciate the value of an extensive PM program and has a goal of a 50% PM-50%

corrective maintenance mixtur * Existing procedures were found to generally contain appropriate information and criteria; however, a number of administrative procedures were found to be not particularly user-friendl In addition, training on administrative procedures was found to be weak or nonexistent.

a * Availability and accuracy of system design information remains suspec The licensee's System Functional Evaluation was a first step in the right direction; however, the product of this evaluation is not a working document for design control purposes nor is it sufficiently scoped for that purpose. The licensee has committed to a Configuration Management Program which, if appropriately scoped and implemented, will resolve this proble * The licensee is implementing a performance based training program for maintenance personnel in accordance with INP0 guidelines. This should resolve the issue of maintenance trainin * Throughout the inspection, management evidenced a consistently conservative approach to plant operations and correcting equipment deficiencies. Operations personnel expressed cautious optimism regarding

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this new attitude.

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Overall, the inspection team concluded that the material condition of the i Palisades facility was sufficiently improved to support safe and reliable plant operations at the time of startup. The licensee has made appropriate long range commitments and established appropriate goals such that the

, material condition should continue to improv .

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DETAILS

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! Persons Contacted F. W. Buckman, Vice President, Nuclear

• J. F. Firlet, Plant General Manager, Palisades K. W. Berry, Director, Nuclear Licensing

• J. G. Lewis, Plant Technical Director

• R. D. Orose, Engineering and Maintenance Manager

• R. M. Rice, Plant Operations Manager

• D. W. Joos, Plant Planning Manager

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R. A. Fench, Operations Superintendent H. C. Tawney, Mechanical Maintenance Superintendent D. Turner, Systems Engineering Supervisor S. T. Wawro, Shift Supervisor M. Sniegowski, Staff Engineer

• C. S. Kozup, Technical Engineer

• R. E. McCalbe, QA Director

• J. M. Storey, Public Affairs Director

• R. A. Vincent, Plant Safety Engineering Administrator

• Denotes those present at the Exit Interview on February 13, 198 Other members of the plant staff were contacted during the course of the inspectio . Introduction and Purpose NRC concerns over the effectiveness of maintenance and the material condition of the Palisades Facility were first expressed in the SALP 5 e evaluation covering the period July 1,1983 through October 21, 1984.

l This report concluded that with regard to maintenance, " . . . the overall performance is lower and the trend in performance declined during this period, as evidenced by the increased backlog of maintenance items and the observed condition of equipment. The failure to correct

, equipment problems in a timely manner is a matter of major concern."

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In response to these concerns, a special inspection of the Palisades maintenance program was conducted during the period February 25 through March 8, 1985 covering a broad spectrum of maintenance related activitie This inspection identified nine violations of NRC requirements and pointed to problems in the following areas:

• Failure to follow procedure * Inadequate corrective actions for identified problems.

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• Inadequate QA/QC reviews and failure to characterize findings appropriately such that responses were require I i

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• Complete lack of machinery history and trendin ,

• Inadequate housekeeping and, in some cases, unsatisfactory conditions being allowed to exist for an extended period of time.

• Inadequate work instructions.

• Failure to perform scheduled preventive maintenance.

• A large backlog of maintenance orders caused, in part, by the complexity of the planning and scheduling organizational structure.

• Abuse of the Temporary Change Notice (TCN) system for making procedure changes such that an excessive number of TCN's remained in place for an excessive period of time.

• Lack of a formal control system to ensure that vendor information used for maintenance activities or testing activities was the latest information available.

• Lack of a documented training program for Maintenance / Technical and Administrative Departments.

The licensee responded to this inspection on June 3, 198 In addition to responding to the specific violations, the following actions completed or in progress were described:

• The Maintenance and Engineering Departments were combined and the

" System Engineer" concept was adopted to provide more engineering support for resolving maintenance problems.

• A Maintenance Administration Task Force was created to review the entire Maintenance Administration Program, define problem areas and recommend improvements

• A Systems Assessment Program was implemented to perform an overall mechanical assessment of 38 systems. The assessment included system walkdowns using P&ID's as a guide; initiation of Maintenance Orders and Engineering Support requests for mechanical and I&C deficiencies; reviews of the Equipment Data Base for completeness; and review of outstanding facility changes, specification changes, and other in"ormation pertinent to the systems. Personnel interviews were also conducted.

• A corrputer based Advanced Maintenance Management System was adopted.

During the period September 30 through October 4, 1985, a followup special maintenance inspection was performed by Region III. The report concluded that while some improvements had been made in the maintenance area, concerns still existed regarding inadequate corrective actions and the number of outstanding maintenance work order On October 30, 1985, Region III issued a Confirmatory Action Letter (CAL-RIII-85-15) to the licensee as a result of the licensee's failure to achieve a significant reduction in the maintenance backlog. In additicn to addressing specific steps committed to reduce the maintenance backlog, the CAL confirmed licensee commitments to aid in the identification of root causes for system and equipment malfunctions, to validate the preventive maintenance program, and to determine the need to replace or upgrade installed equipmen In the most recent SALP report for Palisades, which covered the period November 1, 1984 through October 21, 1985, the areas of Maintenance, Surveillance, and Quality Programs and Administrative Controls declined from a rating of Category 2 to Category 3. The low ratings in these areas were, in part, due to a lack of aggressive corrective action by the licensee and poor management controls and attitude Specifically the following observations were made in the SALP report:

• Two violations occurred in the operations area related to inadequate maintenance on and poor reliability of plant instrumentatio * Management and supervisory decisions did not consistently reflect a conservative approach to plant operations. Two examples were cited. The first involved a decision to increase power from 30%

with a 0.8 gpm unidentified leak and a 0.7 gpm leak from a valve's packing. Subsequent shutdown was required after valve leakage exceeded 3.0 gpm. The second example related to a decision to declare a control rod inoperable rather than exercise it and run the risk of aggravating seal leakage. When a second rod became inoperable, the licensee exercised the first rod to avoid shutting the plant down to effect repair These actions, although technically within the requirements of the Palisades license, were considered imprudent by the NR * The Preventive Maintenance Program at the plant was neither of sufficient scope nor adequately implemented to provide desired reliabilit Additionally, machinery histories were not being maintained in useable form and no trending was being don * A review of certain modifications disclosed that design inputs were inadequate and that licensee reviews failed to identify any of the problems that existed with the design. Required safety evaluations failed to accurately describe the changes nor did they identify that the changes may involve unreviewed safety question * Many of the existing maintenance problems arose from adopting temporary fixes rather than implementing permanent solution t

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A special task force review was conducted by NRC Region III and NRC contractors during the period January 10 through March 7, 1986, to determine if any problem areas existed which had not been previously identified by the licensee or the NRC. This review identified general weaknesses with respect to recurrent equipment problems requiring significant operator attention, procedural adherence, quality of procedures and timeliness of procedure changes, and thoroughness ,

of reviews and scope of corrective actio '

The programmatic weaknesses identified were reflected in plant performance problems. Starting in late 1984 and continuing through calendar year 1985, five separate events occurred related to leaking Safety Injection Tank (SIT) check valves despite maintenance on those valves during the Cycle 5 refueling outage. During the Cycle 6 refueling and maintenance outage, the licensee elected not to perform maintenance on Reactor Coolant Pumps (RCP's) with indications of incipient seal failur When returning to operation from the Cycle 6 extended refueling and maintenance outage, valve leakage problems were identified on a primary coolant system loop check valve on the HPSI injection line, two Safety Injection Tank (SIT) pressure control valves and a manual isolation valve, and the three-way divert valve in the chemical and volume control syste A management meeting between Consumers Power Company and the NRC was held on March 6, 1986, to address these operational problems, and, based on this meeting and a subsequent conference call, the licensee elected to shut down on March 8, 198 On April 10, 1986, Palisades again shut down after exceeding the Technical Specification limit for unidentified primary coolant system leakage. The cause was a failed relief valve in the letdown subsystem for the chemical and volume control system. During return to power operation on April 11, 1986, the licensee identified a packing failure on Condensate Pump "A."

The pump was repacked twice prior to replacement on April 19, 1986, with an onsite spar On April 23 and 29, 1986, existing valve leakage problems in the primary coolant makeup system resulted in primary coolant temperature excursions which, although later determined to be enveloped by the accident analysis values, were initially reported as potentially exceeding primary coolant temperature limitations associated with the main steam line break analysi As of May 16, 1986, the following issues were outstanding regarding the Palisades maintenance and modification program and its impact on plant operations:

i Recurrent equipment problems were challenging safety systems, technical specification limits, and plant operators.

' An excessive backlog of work items was outstanding. Contributing to this problem was an untimely turnaround in completing corrective actions.

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_ _ _ _ _ _ _ _ _ _ _ _ _ Equipment conditions at Palisades were poor and the extent of degraded conditions was not well characterized owing in part to the fact that personnel were living with deficiencies rather than entering them into the work order system. The effectiveness of the maintenance program was marginal in preventing recurrence of problems. Contributing to this weakness were the absence of trending of equipment performance, corrective maintenance, and preventive maintenance; failure to consistently perform scheduled preventive maintenance; deficiencies in root cause identification / correction; and inadequacies in the scope of the preventive maintenance program. Procedural problems existed including compliance, adequacy of instructions, and excessive use of temporary procedure changes. Design inputs to system modifications and reviews pursuant to 10 CFR 50.59 were not consistently adequate, raising concerns regarding availability of design basis information and the quality of plant modifications.

Taken collectively, these issues aggravated NRC concerns regarding a perceived lack of conservatism on the part of licensee management which surfaced as an almost exclusive reliance on technical specification requirements as the standard of expected performance.

On May 19, 1986, the Palisades Plant was operating at approximately 97 percent of full power. Shortly before 2:16 p.m. (EDT) on May 19, 1986, both primary and secondary Electro Hydraulic Control (EHC) power supplies tripped, allowing the main turbine governor to valves to drift close This loss of turbine load resulted in a reactor trip on high pressurizer pressure. Following the reactor trip, the operators initiated post trip response in accordance with Emergency Operating Procedure E0P-1.

During a scan of the control boards the operators noted that the Turbine Bypass Valve (TBV) and one of four secondary system Atmospheric Dump Valves (ADVs) failed to open. These failures caused the lifting of banks of Main Steam Safety Valves resulting in a rapid decrease of steam generator level and a corresponding cooldown of the primary system.

The operators also observed that one of the pressurizer spray valves indicated open. Noting that pressurizer pressure had decreased to a value at which the valve should have been shut, and the continued decrease in pressurizer pressure towards the Safety Injection Setpoint, the operator attempted to manually start the third charging pump. Despite repeated unsuccessful attempts to start the third charging pump, pressurizer pressure bottomed out at 1689 psia, which is above the SI injection setpuint of 1593 psia, and started to recove .. . _ .

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During subsequent plant stabilization and recovery, the operators noticed that control rod 34 rod bottom light was not illuminate Comparison of the primary rod position indication to the secondary indication system determined that all rods had apparently inserte Following return of pressurizer level to above the PCS letdown isolation setpoint, the operators attempted to restore letdown flow. During restoration, the letdcwn orifice back pressure regulator (CV2012) failed shut, requiring the operators to shift to the redundant regulato The redundant regulator functioned properly, although, it had previously been identified as an item needing maintenanc The licensee notified the Nuclear Regulatory Commission, pursuant to 10 CFR 50.72, of the plant trip. During the initial notification at 2:54 p.m. EDT May 19, 1986, the licensee identified the trip initiating signal as loss of turbine load turbine tri Further evaluation by the licensee determined the initiating reactor trip signal to be pressurizer high pressure. This clarification was made to the NRC via the EN Subsequent review by the licensee of their emergency plan resulted in a declaration of an unusual Event (UE). The UE was declared and terminated at 5:45 p.m. EDT. The NRC HQ Operations Center was notified of the UE at 5:52 p.m. EDT on May 19, 1986. During each ENS telecon between the plant and the NRC operations center, the NRC duty officer asked the plant if it was a normal trip and if everything functioned properly. Each time the plant responded that the trip was normal and everything functioned properl The plant was stabilized in Hot Shutdown pending post trip review and evaluation of equipment failures. The post trip review was completed and the plant taken critical at 3:03 a.m. on May 20, 198 As noted above, the initial reports of the trip to the NRC indicated that the plant had responded normally and everything functioned properl However, on May 20, the day after the trip, the licensee began informing the NRC of the various equipment malfunctions which occurred following the tri Based on this information, the recent poor performance of the Palisades plant as a result of equipment problems, and the outstanding concerns held by the NRC n.garding maintenance and lack of conservatism regarding operating decisions, Region III contacted the licensee and challenged the licensee's decision to restart the plant. During the ensuing discussion the licensee agreed to take the plant to cold shutdown, investigate fully the causes and implications of the equipment failures following the May 19 reactor trip, and conduct a thorough investigation of plant safety systems and balance of plant systems important to safety regarding operability and required maintenance. Restart was not to occur without Region III concurrence. These commitments were confirmed in a CAL (CAL-RIII-86-002) dated May 21, 198 In addition to the CAL, on May 22, 1986, Region III dispatched an Augmented Investigation Team to the site. The actions of the NRC Augmented Investigation Team were directed toward a review the circumstances surrounding the continuing equipment problems exemplified

by the failures which occurred during the May 19, 1986 reactor trip, and an examination of the burden these failures placed on the operating staf The investigation proceeded simultaneously along two paths - equipment reviews and opeutions department interviews. The licensee initiated a parallel effort in response to their commitments documented in the CA Although at the termination of the AIT onsite review, root cause determinations for several equipment failures were still in progress, the following significant facts were ascertained: Significant weaknesses exist in three aspects of the maintenance function - diagnostics, repair and post maintenance testin Plant operators have serious concerns regarding the adequacy of maintenance activities and equipment reliabilit Equipment failures and degraded equipment have placed varying levels of additional burden on the plant operators. With regard to the May 19 trip this burden did distract operators, but did not significantly jeopardize plant safet The performance of plant operators and the operation of major or safety-related plant systems were as expected and designed considering the equipment failures that occurre There is a lack of communication and coordination for a maintenance activity from the Work Request stage through verification testing and acceptance for operatio In implementing the commitments made following the May 19, 1986 trip, the licensee initiated a Material Condition Task Force to independently review event related equipment failures and other equipment deficiencies and to assure that problems were resolved promptly and thoroughly. By letter dated July 3, 1986, the licensee submitted a report on the Task Force activities. The items identified were divided into those requiring attention prior to startup, those that would be addressed in a future outage, and those to be completed as scheduled in the five year pla Subsequently, the licensee submitted letters dated August 15, 1986, and September 19, 1986, which reported progress on activities and identified emergent items requiring additional corrective action During the performance of the corrective maintenance activities and the augmented testing that was instituted as part of the Task Force recommendations, the licensee found and reported to the NRC, certain deficiencies in safety system design capabilities. These deficiencies involved insufficient service water flow through containment air coolers, component cooling water flow less than specified in the FSAR, service water capability less than specified in the FSAR, and low pressure safety injection pump flow less than specified in the FSAR. The failure to recognize that certain pump impe11ers had been modified in their original installation and that throttling of heat exchanger valves without determining system flow changes demonstrated a lack of knowledge of system design and of control over system modification i . - - _

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In addition, the NRC conducted a Safety System Functional Inspection (SSFI) of the high pressure safety injection system during September and October of 1986. The findings of that inspection raised questions about compliance with design bases; adequacy of the test program as it relates to the interfaces between safety related and non-safety related systems; preventive maintenance, especially lubrication of motor-operated valves; and training provided to maintenance craft personne Because many of the problems identified by the licensee during the outage following the May 19 trip and the findings of the SSFI raised serious questions regarding facility conformance to design bases, on November 20, 1986, Region III issued a request for information to the licensee pursuant to 10 CFR 50.54(f) (50.54(f) letter). Specifically, the licensee was directed to evaluate and address the results of inspections, investigations, maintenance, and testing performed following the May 19 trip; the lessons learned from these activities; and management system, programmatic, and hardware changes made or planned as a result of these activitie The licensee's response to the 50.54(f) letter was received in Region III on December 1, 1986. This response detailed those actions taken and planned to ensure that the material condition of the plant would support restart, programmatic changes taken and planned to prevent future deterioration of material conditions, and programs planned to improve plant performanc On December 9, 1986, the licensee made a presentation to Region III on the contents of their respons Following the December 9 meeting, Region III commissioned a plant restart inspection effort. This effort was broken into two parts. The first part, Plant Readiness which is the subject of this report, was performed to independently assess plant performance capability and actions taken to ensure that that capability is maintained. The second part of the inspection effort, documented in inspection report 50-255/87005 focused on staff capabilities, training to support plant operations, and restart testin The remainder of this report deals with plant readiness for restar . Disposition of Known Hardware and Program Deficiencies As indicated in Paragraph 2 of this report, since 1984 the NRC has had significant concerns with respect to the ability of the Palisades maintenance and modification program to support plant operation To date, these concerns have prompted the NRC to perform four special inspections, issue two Confirmatory Action Letters, conduct at least one special management meeting resulting in a plant shutdown, and issue a request for information pursuant to 10 CFR 50.54(f) to support a decision as to whether to modify, suspend, or revoke the Palisades operating license. These concerns developed as the direct result of the adverse

impact of material conditions on the reliable operation of the Palisades facility.

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r Over this same period of time the licensee devoted significant effort and resources to resolve these problems. While some of the actions taken by the licensee were prompted by NRC initiatives, a number of other actions were self-initiate What follows is a discussion of the status of these problems. For the purposes of clarity and perspective, the problems are divided into hardware and program issue Work Order Backlog At the Time of the May 19, 1986 Trip As indicated above, one of the major NRC concerns was the excessive backlog of open maintenance requests. This concern prompted the NRC to issue a CAL on October 30, 1985 confirming a licensee commitment to reduce that backlog from 1700 in November 1985 to less than 1000 by January 1,1987. This reduction was to be accomplished by prioritization to emphasize the completion of work most important to the safe operation of the plant and work that may only be completed during a plant outag In an effort at assessing licensee performance in this regard the inspection team reviewed data on the number of outstanding work orders each month between November, 1985 and May 19, 1986 as compared to the licensee's monthly goal (1) By letter dated December 27, 1985 the licensee responded to the October 30 CAL. Included as an attachment to this letter was a work order backlog forecast which showed the anticipated number of work orders on a monthly basis starting in November 1985 and ending in December 1986. On a regular basis the licensee provided to Region III an update on the number of outstanding work orders. This information is presented in tabular form belo Projected Work Orders Actual Work Orders Month Open At Months End Open At Month's End December, 1985 1650 2374 January, 1986 1600 2008 February, 1986 1600 1559 March, 1986 1540 1402 April, 1986 1480 1345 May, 1986 1420 1348 June, 1986 1360 1344 July, 1986 1300 1414 August, 1986 1240 1403 September, 1986 1180 1366 October, 1986 1120 1288 November, 1986 1060 1267 December, 1986 1000 982

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Review of this information shows that the licensee was successful in achieving a significant reduction in the backlog of outstanding work orders. This process was facilitated by the extended refueling outage which ended on March 3, 198 (2) In addition to addressing the overall backlog or work orders, CAL-RIII-85-15 discussed a specific reduction of those control room work orders that directly affect the controls used by operators during emergency, off-normal, and routine operations; result in information relied on by operators being inaccurate or indeterminate; and result in annunciated control room alarms that reflect off normal conditions. In their December 27, 1985 response to CAL-RIII-85-15 the licensee provided projections of outstanding control room deficiencies on a monthly basi Additionally, in Section 2-II.G.A.2 of their 50.54 Letter response the licensee established a goal of fewer than thirty open control room deficiencies. The team reviewed the licensee's progress in reducing the number of control room deficiencie The results of that review are summarized in tabular form below:

Projected Control Room Actual Control Room Deficiencies Deficiencies Month Open At Month's End Open At Month's End November, 1985 63 63 December, 1985 48 47 January, 1986 24 24 February, 1986 30 26 March, 1986 31 25 April, 1986 32 29 May, 1986 33 39 June, 1986 34 32 July, 1986 35 28 August, 1986 36 18 September, 1986 37 18 October, 1986 38 7 November, 1986 39 14 December, 1986 40 7 Licensee projections regarding control room deficiencies were based on the plant being in a refueling outage through January 1986 allowing deficiency work-offs followed by plant restart and continued operation through the end of 1986. The assumption was made that a number of deficiencies would be identified immediately following restart as systems were returned to service followed by the discovery of one additional deficiency per month that would required an outage to correc __ _ _ ___ _ _ __ ._ - -

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In reality, the plant did not restart from the 1985 refueling outage until March 3, 1986. This added window of opportunity allowed the licensee to reduce the number of deficiencies below that expected. However, it is concluded that at the time of the May 19 trip the licensee had made reasonable progress in reducing the backlog of identified control room deficiencies.

b. Work Order Backlog Following the May 19, 1986 Trip (1) Following the May 19 trip, the work order backlog increased somewhat. While system inputs remained relatively constant, the number of work orders completed during this period decreased notably. The declining trend in the backlog established prior to the May 19 trip was resumed in October and continued through the inspection period, despite an increased input to the system to approximately 450 work orders per mont The backlog trends during the May - December time frame can be attributed to outage progress. During the initial phases of the outage the licensee anticipated a relatively short outage (two to six weeks). Consequently there was some reluctance to perform maintenance on the plant which might have extended the outag Additionally, the equipment investigative efforts undertaken early in the outage consumed considerable resource While this work was necessary and productive, it did not immediately contribute to the closure of open work request As the outage continued and some of the emergent issues surfaced, it became apparent that the outage duration would have to be extended. This allowed for longer range planning. Additionally, many of the deficiencies which were identified early in the outage were being closed with the result that the backlog began to dro The substantial progress made in the October - November time frame is partially attributable to post maintenance testing completed during a plant heatup. This testing allowed closure of many items being held open solely for the purposes of testin Further evaluation of the system inputs and tracking methods provides additional insight into the meaning of the numbers summarized abov These numbers represent the total amount of paper work outstanding at any given point in time. As such, they include work orders for which the work has been completed but are being listed as open pending either post maintenance testing or administrative action. While these activities are an integral part of the work order process, they do not directly reflect the material condition of the plan Also included in these totals are preventive maintenance items, many of which had not reached their due dates. Of the 1206 work orders that were open on December 8, 1986, 7C2 required active plant craft work to correct deficiencies, 96 involved active corrective work by other organizations,152 involved preventive maintenance

(PM) items for which work orders had been written, 49 required administrative actions to effect closure, and 147 required post maintenance testing. Based on this breakdown, as of December 8, 1010 work orders were outstanding which required active field wor During the course of the inspection, additional progress was made in reducing the backlog such the number of open items actually requiring field work was reduced to less than 100 Thus, that portion of the licensee's commitment regarding total backlog as documented in Item 1 of CAL-RIII-85-15 has been satisfie Licensee efforts to further reduce the backlog are continuin The present backlog represents approximately two months' work for the maintenance department. The licensee has established a goal of no more than 400 corrective work orders in the backlog by the end of 1987 and no more than 200 corrective work orders in the backlog by the end of 1988 and beyond. If the corrective work order backlog exceeds 400, the licensee has committed to bring additional resources in to reduce the backlog. This goal reflects the recently adopted licensee policy that the total backlog not exceed one month's work for repair personnel (400 items). This, combined with an anticipated increase in preventive maintenance worklrad and the demonstrated ability of repair personnel to complete approximately 400 work items per month forms the basis fo- tte backlog goal. These goals acceptabl (2) With regard to control room deficiencies, following the May 19 trip a significant increase in the number of identified deficiencies was experier.ce The number of deficiencies rose by seven, due in large part efforts expanded following the Pay 19 trip. However, the licensee assigned a high priority to these deficiencies with the result that a substantial reduction was effected by the close of the inspection. This substantial progress was facilitated to a great extent by extended outage periods; however, the licensee has reduced the number of deficiencies to a manageable level and appears to be keeping abreast on new deficiencies as they are identified. Based on this information, Item 2 of CAL-RIII-85-15 is considered closed.

c. Equipment Malfunctions During The May 19, 1986 Trip The following is a list of equipment which malfunctioned during the May 19 trip and post trip transient:

• EHC Power Supplies

• Control Rod Number 34 Rod Bottom Light

• Coolant Charging Pump P-55A

• Pressurizer Spray Valve CV-1059

• Letdown Backpressure Regulator CV-2012

• Turbine Bypass Valve CV-0511

. - . . . - - . --_ --- _ . . _ .

• Condensate Recirculation Control Valve CV-0730

• Air Ejector Pressure Control Valve PCV-0633

• Atmospheric Steam Dump Valve CV-0779 l

• Turbine Stop Valves CV-0571 - CV-0575

'

The team reviewed the licensee's proposed disposition of each of these malfunctions to judge its acceptabilit In addition, post maintenance tests, and, as appropriate, engineering evaluations used to disposition the malfunctions of Coolant Charging Pump P-55A, Spray Valve CV-1059, Turbine Bypass Valve CV-0511, and Atmospheric Steam Dump Valve CV-0779 were reviewed. The following observations were

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made:

1 * EHC Power Supplies: Failure of the EHC primary and backup power supplies on May 19 was the initiating event for the tri The failure occurred when the EHC cabinet cooling fans were unplugged, thereby inducing line noise which caused the power supplies to trip sequentially. Loss of the first power supply went unnoticed by plant personnel as power supply status was not indicated or alarmed in the control room. The preventive maintenance which caused the fans to be unplugged hed not been performed previously with the turbine on lin In response to this problem, the licensee conducted a test which confirmed that unplugging the cooling fans would indeed cause

'

the EHC power supplies to trip on overvoltage. This established the root cause of the problem as susceptibility of the supplies to tripping on minor voltage transients. During this process it was identified that capacitors in the 200 volt power supply had faile The following actions were taken to resolve this problem:

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The failed capacitors were replace The cooling fan power supply was changed to an external source of power unrelated to the power supply for the EHC power supplies.

.

,

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Transient voltage suppressors were installed on the input power supply connection A lock was installed on the power source to the EHC power supplies to prevent inadvertent deenergizatio The outside air cooling duct to the EHC cabinet cooling fans was reconfigured to prevent moisture intrusion into

.

the cabinet.

i

]

i 13

_ _ __ __ - ___ _ -.. . _ . . . - _ - - _ . , _ _ - - - - .

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Following these actions, the system was tested satisfactorily.

In addition, the licensee committed in their response to the 10 CFR 50.54(f) letter to install an audible alarm in the control room for turbine panel trouble to alert operators to failures of this type. This action was completed prior to startup under Facility Change No. 63 These actions adequately address NRC concerns over this

particular failure and this issue is considered closed.

L

• Control Rod No. 34 Rod Bottom Light: Following the trip on May 19, this rod bottom light failed to illuminate, forcing  :

the operators to use a backup means to verify rod insertion.

'

This problem was acceptably resolved by replacing Control Rod Drive Package No. 34. The package installed at the time of the trip was repaired by replacing damaged wires from the terminal blocks to the synchro and limit switch connection * Coolant Charging Pump P-55A: Following the May 19 trip, the operators attempted on several occasions to start variable speed coolant charging pump P-55A to aid in plant inventory

.

control. Each time the pump started, it ran for a short period i of time and then tripped. This problem adversely impacted PCS inventory control and unnecessarily distracted the operators during the post trip plant stabilizatio ~ Subsequent testing identified the cause of the trips to be a

. low lube oil pressure protective trip. In response to this problem, the licensee installed a new lube oil pump and tubing, rebuilt the fluid drive under vendor direction to reduce internal lube oil leakage, and increased the time delay on the low lube oil pressure trip to allow a greater period of time for oil pressure to build up before a trip is initiate Following these activities the licensee successfully tested P-55A. In addition, the licensee committed to initiate a preventive maintenance item on the fluid driv Implementation of this commitment will be tracked as an Open Item (50-255/86035-01).

The licensee also discovered and replaced a failed pressure switch on coolant charging pump P-55B.

'

Approximately one year before the May 19 trip a similar problem occurred on P-55B. At the time, the problem was resolved by replacing the lube oil pump on P-558. The licensee monitors lube oil pressure on all three pumps on a monthly basis using Procedure No. M0-2 Recent data shows steady and acceptable

)

performance.

During the week of January 19, 1987, P-558 failed to start on two sequential attempts. Investigation revealed that the start failures were caused by low lube oil pressure trips. It was found that the time delay on the trip function was set at 10 seconds. At the time, the licensee believed the time delay,

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.- _- -

- _ _ _ - _ _ _ _ _ _ _

which historically had been set at 10 seconds, was set at 30 seconds. Further investigation revealed that a documentation error by the previous System Engineer had been turned over to his relief without verification. The licensee is processing a modification to the relays in the time delay circuit which will allow the time delays to be set in the 30-50 second rang Completion of this modification is required prior to startup and will be tracked as an Open Item (50-255/86035-2).

The actions taken by the licensee regarding the lube oil problems on P-55A which prevented its use on May 19 are viewed as adequat Except for those long term commitment noted above, this particular problem is considered close At the time of the May 19 trip, P-55A was designated as being inoperable but available for emergency use owing to a cracked block. Near the end of the inspection period the licensee received a new block for P %A. Preparations were in progress to install the new block prior to plant return to power as the inspection close This issue is considered close * Pressurizer Spray Valve CV-1059: This valve failed to close fully following the May 19 trip, complicating PCS pressure control. Subsequent investigation showed this condition to be the result of slight residual air pressure on the valve actuato The valve, its actuator, and position switches were disassembled, inspected, cleaned, and cal.ibrated as applicable. Subsequently, the valve was satisfactorily tested with the plant in hot shutdown. Additionally, the licensee satisfactorily tested Auxiliary Spray Valve CV-105 The licensee has committed as part of their 50.54(f) response to replace both CV-1059 and 1057 as part of their five year plan. This commitment will be tracked as an Open Item (50-255/86035-03).

The actions taken by the licensee with regard to this issue are considered adequate and it is considered close * Letdown Backpressure Regulator CV-2012: Following the May 19 trip the primary intermediate backpressure regulator in the letdown system, CV-2012, failed in the closed position, securing letdown flow. Operator action was required to restore letdown flow using the backup regulator. Subsequent investigation revealed that the backpressure control valves had recently become a high maintenance item due to the age of the controllers and failure of the letdown orifices and trim valves to properly limit flow. The licensee replaced the actuators on both backpressure regulators, the letdown orifices, and the trim valves. The control loop was then calibrated and successfully tested during hot shutdow _ - _ _ _ _ _ _ _ _ _ _ _

The actions taken by the licensee with regard to this issue are considered adequate and it is considered close * Turbine Bypass Valve CV-0511: During the May 19 post trip transient CV-0511 failed to open automatically in response to increasing secondary system pressure. Operator attempts to manually open the valve were unsuccessfu This valve has experienced numerous failures since its installation in 1979 despite repeated repair efforts by the license During the last refueling outage, in addition to changing the orientation of the valve, a larger operating spring was installed. Post maintenance testing under cold conditions demonstrated that the valve apparently operated properly; however, hot testing of the valve was unsuccessfu Following the May 19 trip the licensee determined that the spring was significantly oversized and that contributed to the valve's failure to operat The immediate problem was solved by replacing CV-0511 with a valve of a different design. The replacement valve was successfully tested with the plant at hot shutdown. Future operability of the valve will be demonstrated by testing it monthly during turbine valve testing in accordance with Attachment 3 to Procedure 50P-7. The team reviewed this attachment and found it acceptable. This item is considered close * Condensate Recirculation Valve CV-0730: On April 9, 1986, a work request was written on CV-0730 which stated "CV-0730 appears to drif t open when at 100% power." The work request was sent to the I&C department because the description of " drift" indicated the controls operating the valve were malfunctioning. I&C attempted to troubleshoot the problem; however, operations would not allow them to stroke the valve because it would cause a plant tri Instrument air to the valve's flow controller was isolated to prevent the spring-to-close valve from opening agai It was understood that if the plant were to trip, operator action would be required to open the valve to prevent the condensate pumps from deadheading. On May 19, 1986, operator action was required to open CV-0730 following the plant tri Subsequent troubleshooting of the valve revealed internal mechanical binding, plugging of the disk stack, and significant seat erosion. The valve was refurbished, the controller was calibrated, and the system successfully tested. In addition, the licensee disassembled and refurbished the main feedwater recirculation valves which are of similar desig _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _

In order to minimize the potential for recurrence, the licensee, as part of their 50.54(f) response, committed to implement preventive maintenance items to clean the main condensate hotwell each refueling outage and disassemble and inspect CV-0730 each refueling outage. The CV-0730 Preventive Maintenance (PM) item is in place in Periodic Activity Control Sheet (PACS) CDS-00 The PACS for hotwell cleaning is under development. The hotwell was cleaned during the outage following the May 19, trip. Also, the licensee is developing a PACS for feedwater recirculation valve inspection. These actions are considered adequate to support plant restart. Implementation of the PM's for condenser hotwell cleaning and feedwater recirculation valve inspection will be tracked as Open Items (50-255/86035-04; 50-255/86035-05).

• Air Ejector Pressure Control Valve PCV-0633: This valve failed to respond properly to increasing steam pressure following the May 19 trip with the result that the air ejector condenser relief valve lifted. Subsequent investigation revealed that the malfunction was due to a cracked bellows on the valv The valve was repaired. This item is considered close * Atmospheric Steam Dump Valve CV-0779: CV-0779, one of four atmospheric steam dump valves, failed to open in response to increasing steam pressure following the May 19 trip. Upon disassembly and inspection if was determined that the valve operator diaphragm had ruptured due, in part, to prolonged leakage of glycol damping fluid into the diaphragm housin The vendor recommends that the diaphrages be replaced every three to five years. The licensee had not been periodically replacing the diaphragm The licensee's immediate corrective action was to replace the fliled diaphragm on .V-0799 as well as the diaphragms on the other three dump valves. In addition, due to historical problems with packing leaks, the packing was changed on all valves to a live loading configuration. All valves were tested under hot and cold condition For the longer term, the licensee, in its response to the 50.54(f) letter, committed to establish a preventive maintenance program to change the diaphragms on the operators every four years, to visually inspect for glycol leaks on the operators and recharge as necessary every three months, and to inspect the air lines and valve operator casings for air leakage every three month Procedures MSS-037, 040, and 041 have been developed for these activitie The inspection team reviewed these procedures. As originally written MSS-037, which replaced the diaphragms on the dump valve operators, contained only vague instructions regarding the work to be performed, and did not specify any post maintenance test requirement The licensee, in parallel with the inspection

_____-________ _

team, identified these deficiencie During the inspection period, appropriate changes to MSS-037 were processed to address these discrepancies. Detailed work instructions were provided, and post maintenancc valve stroking was specifie The revised procedure was found to be acceptable. MSS-040 and MSS-041 were found to be technically acceptabl Additionally, the licensee added an Attachment 4 to 50P-7 which requires the valves to be stroked under hot shutdown and standby conditions. The testing requirement was reviewed by the inspection team and found to be technically adequate. The administrative mechanism to get one to the test requirement to ensure that it is accomplished is contained in GOP's 2, 4, and The problem with the valve diaphragm is reflective of a potentially broader issue, namely the use of components with limited service life. During discussions on this subject it was apparent that the licensee did not have in place a program to periodically replace such components, but was relying instead on equipment performance history to define the periodicity of replacement. The inspector acknowledged the validity of this approach but suggested that the licensee consider vendor recommendations in this regar Subsequently the licensee agreed to change their guidance for the preparation of PM's to require that limited service life be factored in through review of vendor information and discussions with vendors as appropriat This will be tracked as an Open Item (50-255/86035-06).

This issue is considered closed.

• Turbine Stop Valves CV-0571 and 0575: These valves indicated excessive closure times during the May 19 trip. Initially, the problem was diagnosed as adverse environmental impacts on the valve position limit switches; however, in discussions with the System Engineer on January 20, 1987, it was revealed that the actual cause of the problem was misalignment of the mechanical linkage which actuates the switches. The linkage was adjusted '

and proper operation was verified by test. Given that these switches only serve an indication function, this action is acceptable and this item is considered closed, d. Material Condition Task Force Effort On May 22, 1986, the licensee's Vice President - Nuclear Operations appointed the Palisades Plant Planning Director to head an eleven member Material Condition Task Force (MCTF) to, in part, conduct a through investigation of the status of systems important to safet The systems to be included were defined by the following criteria:

• Systems identified as important to safety in the NPROS system.

• Systems significant to accident sequences as established using the current probabilistic risk assessment (PRA).

• Systems / components which have failed resulting in past plant trips.

• Other systems as deemed appropriate by a licensed Senior Reactor Operator.

Using these criteria the following systems were selected for investigation:

Main Air Ejector and Gland Seal Air Ejector System Auxiliary Feedwater System Instrument Service Air System Component Cooling Water System Condensate and Demineralizer System Chemical Addition System Containment Isolation System Containment Control Rod Drive System Chemical and Volume Control System Circulating Water System Data Logger / Event Recorder Emergency Power System Engineered Safeguards System Fire Protection System Feedwater System Miscellaneous HVAC Main Steam System Neutron Monitoring System Post Accident Sampling System Primary Coolant System Radiation Monitoring System Reactor Protection System Reactor Regulating System Station Power System Service Water System Turbine Generator Systems Heating, Ventilating and Air Conditioning System Having defined the systems which were to be the subject of the MCTF review, the MCTF then set about developing a list of known or potentially significant deficiencies through the following activities:

• The existing work order backlog was reviewed for significant items.

• Recent work orders were reviewed for evidence of repeat problems.

• Recent surveillance tests were reviewed for repeat failure _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

• Other reporting mechanisms such as Engineering Requests, Deviation Reports, Audit Reports, and NRC Inspection Reports were reviewed for equipment related problems.

• Operations personnel and Systems Engineers were interviewed and the Operator Concern List was reviewed to identify any significant equipment problems which may not be on the Work Order List.

• The Operational Readiness review of the Auxiliary Feedwater System performed before the May 19 trip was reviewed.

• Recently completed Work Orders were reviewed to assess the adequacy of post maintenance testing.

The significance of each deficiency so identified was assessed through SR0 review and use of the Palisades Probabilistic Risk Assessment (PRA). This latter tool allowed a determination of significance relative to importance in accident trees. Once so prioritized, the MCTF either recommended repair / testing prior to startup or provided justification for continued operation with recommendations for repair / testing following startup.

The product of this effort was then reviewed by a Joint Executive / Plant Review Committee to establish a resolution and concurrence in or modification to the MCTF recommendations.

The inspection team reviewed both the process employed by and the product of the MCTF. The following observations were made:

• MCTF Process The MCTF team (11 members) possessed a total of approximately 140 years of commercial nuclear experience (12 and a half per member average) and 16 years of Navy Nuclear experience. The commercial experience breaks down to approximately 100 years of equipment performance experience (maintenance, modifications, testing, etc.), ten years of operations experience, and 30 years of other experience (QA, Risk Assessment, etc.). Of these totals, approximately 90% of the equipment performance experience was acquired with Consumers Power, 30% of that coming from Palisade All of the commercial operating experience was acquired with Consumers Power, approximately half at Palisade Overall, the inspection team concluded that the MCTF was comprised of individuals possessing significant nuclear experience; however, the MCTF did suffer from two experience weaknesses. The first weakness was a relative lack of plant operating experience. As noted in Paragraph 2 of this report, two of the major concerns held by the NRC prior to the May 19 trip were recurrent equipment problems challenging plant operators and poor characterization of equipment conditions owing in part to the fact that personnel were living with deficiencies rather than entering them into the system. These

concerns, combined with a perceived lack of conservatism on the part of the plant management with regard to degraded equipment conditions strongly suggests the need to involve personnel with intimate operating experience into a MCTF-type effor The second experience weakness relates to the almost total reliance upon people whose equipment performance experience was gained at Consumers Power. As noted in Paragraph 2, the NRC is of the position that Consumers Power Company has not historically been sufficiently sensitive to the impact of degraded equipment conditions on plant operations. Yet, the vast majority of experience possessed by the MCTF was gained in this environment. Aggravating this weakness is the fact that only two of the ten Consumer Power Company representatives on the MCTF occupy other than supervisory or managerial position Those two are staff engineers. No plant operators or maintenance craft personnel occupied positions on the MCT The criteria used by the MCTF to select systems for review reflected a conservative and conscientious attitude toward plant safety and reliabilit This is reflected by the list of systems finally selected for review. This list includes not only safety systems, but systems that could reasonably be expected to produce challenges to safety systems and operator The factors considered / items reviewed in the development of the list of known or potentially significant deficiencies could, with one exception, be reasonably expected to produce a valid lis The one exception was a lack of system walkdowns. With the exception of the personnel interviews, the items reviewed were based exclusively on existing or previously identified problems. No overt effort was made to validate these lists by directly observing plant conditions and comparing the results of those observations with the lists of known deficiencie While the personnel interviews likely identified some items not in formal reporting systems, it is equally likely that there may have existed many unidentified deficiencies which ultimately were not considered by the MCT As discussed later in this report, the inspection team performed a walkdown of certain systems and compared the results of that walkdown with current deficiency lists. The conclusion reached by the team as a result of these walkdowns was that the deficiency lists reasonably represented plant material conditions. Additional assurance in this regard was provided by the licensee's System Functional Evaluation discussed later in this repor The prioritization criteria applied by the MCTF to the list of deficiencies identified appeared acceptable. Use of the PRA would identify those items significant to accident / transient sequences and provide a good "first cut" on items of major significance. However, the criteria lacked sufficient detail to allow the team to conclude that items of lesser significance,

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taken individually or collectively, would be appropriately prioritized. Application of these criteria is discussed in the next section of this report dealing with the product of the MCTF. Additionally, as discussed later in this report, the inspection team reviewed the status of all outstanding work orders, modifications, and specification changes and independently assessed their prioritizatio Once the MCTF had completed its effort, the product was presented for review to a Joint Executive / Plant Review Committe The stated purpose of this review was to assure proper management visibility and concurrence with MCTF findings and recommendations, and also provide a review for safety significanc The Executive Review Committee consisted of:

F. W. Buckman, Vice President, Nuclear Operations

>

R. B. DeWitt, Vice President, Energy Supply Services Department J. F. Firlit, Palisades Plant General Manager J. G. Lewis, Palisades Plant Technical Director R. M. Rice, Palisades Operations Manager R. D. Orosz, Palisades Plant Operations and Maintenance Manager In addition, D. W. Joos, Palisades Plant Planning Director, and S. T. Wawro, Palisades Plant Shift Supervisor participated in this review so as to provide a quorum of the Plant Review Committee (PRC). Their role was primarily to provide information to the Committee and handle certain administrative matter Based on the committee composition, the team concluded that the objective of management visibility was accomplishe Insufficient information regarding the changes made by the Committee was available to the team to conclude that the Committee accomplished its remaining objectives. However, the inspection team noted that the Committee consisted entirely of licensee personnel and therefore lacked an element of independence which would have lent greater credibility to the Committee's action Overall, the inspection team arrived at the following conclusions regarding the MCTF process: The MCTF appropriately selected safety-related and balance of plant systems important to safe and reliable plant operation for status revie i While all of the sources of information on system status selected by the MCTF for review were appropriate, that selection was predicated on the then unsubstantiated assumption that those sources of information adequately encompassed all system deficiencie _ _

_

f iii. While the MCTF members as a group possessed significant'

nuclear experience, shortcomings existed in the areas of operations experience independent of the license i The stated prioritization criteria employed by the MCTF, while generally appropriate, lacked specificit The Joint Executive / Plant Review Committee which reviewed the final product of the MCTF lacked independence from the issues reviewe It should be noted that as part of its response to the 50.54(f)

letter the licensee committed prior to plant startup to have the Joint Executive /PRC review the status of liCTF issues, approve any issues which will not be resolved prior to plant startup, include a formal justification for continued operation, and review all such issues with the NRC. In addition, the licensee committed to a final Operations Department review of open work orders and control room deficiencies prior to startup to assure that any significant equipment operability problems are addresse The followup Joint Executive /PRC review was co.npleted and the results forwarded to the NRC on August 15, 1986. This review identified and approved ten items which had previously been committed to be completed prior to restart for completion at a later date. These items are as follows: i Place Moisture Separator Drain Tank Valves CV-0608 and 0609 on a quarterly Preventive Maintenance (PM) to verify proper valve operation. Further review indicated that cycling these valves at power could produce a plant transient resulting in a trip. Consequently, the valves will be tested during shutdown only. This change was supported by the fact that valve operating problems are

,

believed to be due primarily to water in the instrument air system, a problem resolved by the installation of a new air drye i Perform leak tests prior to and after modifications to the containment sump level transmitters' bypass valves to eliminate a physical interference. The modifications did not require breaking into the valves or system;

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consequently, no leak test was require iii. Stage and test a replacement valve for 3-way letdown diversion valve CV-2056 as a contingency for leakage problems which may occur during startup. A replacement valve could not be procured. Instead, parts were staged for a complete valve rebuild (except a valve body) if necessar _ - _ _ ,~ __ , _ _ , _ , . _ . .

i Delete the Cooling Tower Basin Pump trip function. The decision has been made to retain the trip function. The cause of previously experienced trips is now believed to be water in the instrument air system impacting the basin level switches. Installation of the new air dryer should resolve this problem. Replace emergency diesel generator frequency and load indication. Parts lead time is such that this is not possible prior to startup. Replacement will occur during the next refueling outage. In the interim, portable instrumentation will be used to supplement normal instrumentation during testing to ensure proper diesel generator operation.

v Remove the 900 R/hr hot spot from the Shutdown Cooling Heat Exchange This requires the establishment of an alternate means of shutdown cooling which is not feasible during the current outage. It will be completed during the next refueling outage. In the interim, a physical barrier will be placed around the hot spot for personnel protection.

vii. Repack SIRW Tank Discharge Isolation Valves CV-3031 and 3057. CV-3031 was replaced in January 1986 and is not leaking. CV-3057 will be repacked prior to startup.

viii Relocate SIRW Tank recirculation flow transmitter upstream of the fast recirculation line to prevent over ranging during fast recirculation. This action requires the tank to be drained and will be performed during the next refueling outage. In the interim, administrative controls will be implemented via Procedure 50P-27 to ensure that the transmitter is valved out whenever the tank is put on fast recirculation. The inspection team reviewed Temporary Change Notice TCN-0-86-205 to S0P-27 and found it acceptable in this regard.

i Insure operability of Fuel Handling Area Monitor No. This monitor is required for fuel movement only and is normally disabled during plant operations. Operability will be ensured prior to fuel movement during the next refueling outage. Obtain the services of an independent authority to assist with the resolution of DC Bus ground alarms. An independent authority could not be located. Operations and maintenance have agreed on lines of responsibility and actions to be taken when a D.C. Bus ground alarm is received. These actions require operations to better document troubleshooting performed prior to requesting maintenance assistance. Prior

.

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to startup from the next refueling outage the licensee committed to have in place a step by step ground isolation procedure. This will be tracked as an Open Item (50-255/86035-07).

The inspection team reviewed these items and their proposed resolution and found them acceptabl The results of the Operations Department review of open work orders and control room deficiencies was reviewed with the inspection team on January 21, 1987. The Operations Department review identified approximately 30 items which were not originally scheduled for completion prior to startup that it felt should be resolved prior to startup. At the time these items were reviewed with the inspection team, most had already been scheduled to be completed prior to startup. The remaining seven involved: (1) three Shutdown Cooling System valves believed to be leaking by; (2) two Component Cooling Water valves to the boric acid evaporators leaking by; (3) erratic operation of the shutdown cooling system flow controller in automatic; (4) unreliable Secondary Position Indication (SPI)

for the control rod drives; (5) sticking check valves on the discharge of the Component Cooling Water Pumps; (6) erratic operations of the steam pressure controller to the boric acid evaporators, and (7) a stuck open valve on a CVCS filter. During discussions with the inspection team the licensee indicated that items (5) and (6) would be resolved prior to startup, item (1)

would be the subject of a special startup test to determine whether leakage in fact existed, item (4) had been worked on to the extent possible and new SPI's would be installed foll6 wing receipt during the next refueling outage, item (3) had been worked on and was believed to be resolved but did not impact plant restart, and items (2) and (7) could be accommodated through use of other valve In addition, two systems concerns were expressed by the operators relating to charging pump starting reliability and atmospheric steam dump operability. Both of these systems were worked on extensively during the outage following the May 19 tri Extensive testing is currently planned during recovery froc. the outage. This testing will be monitored by the NR The licensee's disposition of these items was found to be acceptable.

• MCTF Product The results of the MCTF investigation of the status of plant safety systems and balance of plant systems important to safe and reliable plant operation were provided to the NRC as part of the licensee's response to the 50.54(f) letter. In summary, 222 items were evaluated including 11 generic issued affecting

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=91tiple systems. A total of 554 total action items were generated not including the list of open work orders and control room deficiencic: racommended for completion prior to startu Of these action items the licensee stated that 58 percent would be completed prior to startup, 29 percent would be completed prior to the end of the next refueling outage, and 13 percent would be considered for the five year plan.

. The inspection team reviewed each of the 544 action items and proposed resolution to determine whether it was acceptabl The number of items evaluated by the MCTF by system is shown below:

System Number Items Evaluated Main Air Ejector and Gland Seal 1 AirEjector(AES)

Auxiliary Feedwater, (AFW) 9 Instrument Service Air, (CAS) 4 Component Cooling Water, (CCS) 4 Condensate and Demineralizer, (CDS) 11 Chemical Addition, (CHM) 1 Containment Isolation (CIS) 4 i

Containment (CLP) 1 Control Rod Drive, (CRD) 5 Chemical and Volume Control, (CVC) 28 Circulator Water, (CWS) 2 Data Logger / Events Recorder, (DTA) 2 Emergency Power, (EPS) 10

, Engineered Safeguards, (ESS) 33

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Fire Protection, (FPS) 6 Feedwater,(FWS) 15 Miscellaneous,(MIS) 11

Main Steam, (MSS) 8 Neutron Monitoring, (NMS) 2 Post Accident Sampling, (PAS) 1 Primary Coolant, (PCS) 18

Radiation Monitoring, (RIA) 32 Reactor Protection, (RPS) 3 Reactor Regulating, (RRS) 1 Station Power, (SPS) 4 Service Water, (SWS) 4 Turbine Generator, (TGS) 16 HVAC,(VAS) 2 In making its determination of acceptability the inspection team considered whether the proposed technical resolution of each item was acceptable, whether the proposed schedule for resolution was acceptable, whether generic implications of each

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item were adequately considered, and whether the impact of the total number of items on a given system was adequately considere With regard to schedule, the team focused on those items whose resolution was scheduled after plant restar ,

With the exception of the 11 items presented in Attachment 1, the inspection team found that the licensee's proposed resolution was' acceptable. As discussed in Attachment 1, these items were satisfactory resolve The action: described in Attachment 2 to this report were committed to be comp 4 ced by the licensee as part of the MCTF report prior to startup from the next refueling outag Each of these items will be tracked as an open item which must be closed prior to startup following the next refueling outage, Work Order Review The inspection team performed an item-by-item review of the licensee's open work order (W0) list to determine the acceptability of those W0s schedule to remain open when the unit resumes operation. This review took into account the apparent safety significance of the deficiency noted in the WO, the potential impact on operations if not completed, parts availability, engineering required and necessary plant condition The team had questions concerning the deferral of certain W0s until after plant startu The licensee was able to provide adequate justification for most deferrals though in some cases they elected to complete the WO prior to startup. During the followup to some of the questions, the licensee found several W0s that were duplicates or were no longer representative of an actual problem and had them cancelled. The team had no further questions regarding each individual W0 and concluded that the licensee had appropriately scheduled each item with respect to plant restar Open W0s can have any one of ten statuses and can broadly be grouped into three categories: planning, scheduling and history. During January 1987 one of the largest status groups was Planning Hold with more than 200 W0s (approximately 20% of the total backlog) at a tim This status means that a W0 has been initiated but has not been planned for work. The electrical and instrument and control maintenance groups have the vast majority of those in Planning Hold. This has not led to repairmen waiting idly for the planners-to complete planning but is a bottleneck in that schedulers are not able to choose from all of the W0s that need to be done when scheduling work for the repairmen. Those that have been planned and are ready to be worked are in Available for Scheduling status (approximately 18%). W0s may remain in Planning Hold for months and even years. The oldest WO on Planning Hold noted was dated August 3, 1983 for the fuel pool building crane. Those W0s that Operations feel are important or those that involve personnel safety are planned in less than two week i i

- . - - .-. - -,,.-, - , - - - - , . , - . . . _ . . . , _ _ _ -

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--,,-. , - . . - , ,

The status of Awaiting Parts / Tools contains over 100 (approximately 10% of total) W0s at a time. This indicates that parts must be ordered for these jobs. The licensee is studying the spare parts systems used at the plant to make them more efficient and cost ef fective. As part of that effort, when a part is now ordered it is being assessed as to whether it would be beneficial to procure more and place them in stoc The status of Awaiting Procedures / Engineering may include over 100 W0s at any given time. Some of these require that a Specification Change be written or an Engineering Support Request be resolved (both of these will be discussed later in this report).

As of January 22, 1987, the largest status (approximately 23% of the total) was Awaiting Operability Testing. The physical work is complete for these W0s but they require certain plant conditions such as hot shutdown ir crdcr to run an operability tes Over the latter half of January and first half of February 1987, the licensee reduced the number of W0s in Planning Hold from 222 to less than 15 Temporary upgrades of mechanical maintenance personnel to planners is credited with this reductio Awaiting Engineering Awaiting Parts / Tools and Available for Scheduling remained relatively stable in numbe Facility and Specification Changes Facility Changes (FCs) are those modifications to the nuclear generating plant, both major and minor, that require detailed

- design and become a permanent change to the plant's equipment, systems, or structures. Specification Changes (SCs) are changes required to the design specifications of installed plant equipment resulting from design modifications made by the equipment vendor, material substitutions and/or technical or code requirements needed to support maintenance activities, or minor equipment modifications required to improve equipment / system reliability or efficienc Specification changes are modifications which are non-complex or functionally equivalent to the original equipmen The inspector reviewed all open FCs and SCs to determine acceptability of thecc to remain open when the unit resumes operation. In general, the im pector found that the decisions made by the licensee for those that must be completed prior to startup and those that could be delayed until some time following startup were adequate. Among the reasons for delaying FC and SC implementation were availability of parts, further engineering required, or refueling plant conditions required (i.e., head off and upper guide structure removed).

The inspector found several FCs and SCs which were in the process of cancellation or closure including some from the 1979-1983 time fram Recent efforts by the licensee to status all open FCs and SCs appear to be uncovering some of the FCs and SCs that have been completed in the past or were never neede _ .- . . _. -_ _ . - _ _ _ .-

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As of Jam'% 7,1987, there were 65 open FCs and 412 open SCs. Of these, 29 i~- and 188 SCs were considered operable but the packages were not yet closed out. These may require the vendor file to be updated and the total package to be compiled and sent to Document Control. Ten additional FCs and 32 additional SCs will be declared operable prior to startu When reviewing the open FCs and SCs the inspector took into account the apparent safety significance of the modification, the potential impact on operations if not done, parts availability, engineering required, and necessary plant conditions required. Following review of information and discussions with many system engineers, the inspector has no concerns with the implementation schedule of the open FCs and SC g. Total Outstanding Work Review The inspection team reviewed on a system basis the total outstanding work to be delayed until after the plant resumes operations. This review included Facility Changes, Specification Changes, and Work Orders that were individually addressed above. In general, the inspector agreed that the amount of outstanding work to be done on a system basis did not degrade the system significantl Valves appear to be the component that suffer the most pioclems at Palisades. Numerous W0s are written for packing leakage, bonnet leakage, and leakage through the valve when in the closed positio Approximately one half of the open W0s for Engineered Safeguards and numerous W0s for tha Emergency Diesel Generators concern leakag Numerous W0s require that the primary coolant system be drained to the cold leg level. The licensee informed the inspector that leakages are minor in nature and do not pose an operability concern. Also, numerous SCs are to change valve types to improve reliability and maintainabilit The licensee has recognized that they have a high incidence of valve related problems. As documented in the licensee's submittal to the the NRC dated January 28, 1987, the licensee has established a valve maintenance program to provide assurance that valves and operators will continue to perform their functions, failures are minimized and repairs are done promptly and properl Contained in this program are: Packing Program Improvement; Valve Technical Support Team for Outages; Valve Application Evaluation; Training Program Improvements; Tool Upgrade Program; and Performance Trending and Testing. Some portions of the Valve Maintenance Program are currently being implemented while others will be long term with the expected end result being improved valve condition. It appears that the licensee

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is appropriately evaluating the significance of each valve problem as it is discovered; therefore, the inspector has no concerns regarding valve leakages at this tim _--- , _ . --. .

. - _ . . . . Engineering Support Requests Engineering Support Requests (ESRs) are used by plant departments to request support from the Engineering and Maintenance Departmen The licensee has a significant backlog of ESRs - on the order of six to seven hundred. At this time (February 1987) the licensee is evaluating the validity of the open ESRs and expects a significant reduction in the backlog. ESRs are being closed or cancelled based upon whether or not the condition has been previously corrected by another mechanism such as a Specification Change, whether the condition is being addressed by another program such as Configuration Management, or whether the ESR is worth doing based upon benefits gained versus cost. Some ESRs fall into the category of nice to have items. Other ESRs have been written for use as a " tickler" lis It appears that the ESRs have had a low priority. There are many ESRs initiated prior to 1985. Following the validity review, the licensee will prioritize the remaining ESRs for greater direction to the responsible engineers and prompter resolutions of the issue The licensee did not review ESRs as part of the information available for the Material Condition Task Force. Following discussions with the team, the licensee decided to review the ESRs prior to startup to determine if any need to be done in the short ter The inspector suggested an enhancement to Administrative Procedure 9.10, " Engineering Support Request," to include a reference to Administrative Procedure 3.03, " Corrective Action," to ensure that an ESR is not written instead of a required corrective action document. Plant Material Condition Walkdowns The inspection team walked down accessible portions of numerous plant systems and areas to determine if the Work Order (W0) system was reflective of the actual material condition of the plan The inspector noted numerous packing leaks or evidence of past leakage on valves that were not tagged with a Component Problem Identification Tag (CPIT). The CPIT is used by the licensee to identify a component for which corrective maintenance has been requested, to identify the problem visually to the maintenance crew, and to advise the Shift Supervisor of plant problems. It appears that more problems of smaller magnitude are being identified currently than has occurred in the past. Those deficiencies that fall below this threshold could be taken care of by the individual identifying the conditio For example, it may be within the skills of an auxiliary operator to remove boric acid or chromatic residue with a wire brush to determine if a packing leak still exists and if so to tighten the packing himself. This type of activity must be controlled in some manner to

- - - - - . . - _ _ . - . . . - . -. .- - - - - - - . _ . . - . . I prevent unqualified individuals from doing maintenance that requires a WO with the associated formal controls. Due to the number of leaks that the inspector noted, it appears that the threshold may not yet be at a level consistent with a plant striving for excellenc The inspector identified discrepancies including valve packing leaks, leakage through closed valves, housekeeping, Piping and Instrument Diagram inconsistencies and CPITs without associated W0s. They are being reviewed by the licensee for possible action. During the followup, the licensee identified a procedural inadequacy in that CPITs associated with W0s that have been cancelled may not be removed from the component. The licer.see is considering a procedure change to ensure removal. The licensee has also determined that work had been completed on some components, but the CPITs had not been remove No violations or deviations were identifie . System Functional Evaluation In order for the licensee to gain confidence that the plant can be operated safely following the extended outage and identification of concerns related to the plant hardware, a review was performed to compare the present plant configurations to the plant's design requirements. The methodology of this review was to use Combustion Engineering's (CE) nine generic safety functions that were used to develop the Palisades Emergency Operating Procedure (EOP) resource trees. These safety functions are identified as the following:

Reactivity Control Maintenance of Vital Auxiliaries - Electric Primary Coolant System Inventory Control Primary Coolant System Pressure Control Primary Coolant System / Core Heat Removal Containment Isolation Containment Atmosphere Control Maintenance of Vital Auxiliaries - Water Maintenance of Vital Auxiliaries - Air

From the E0P resource trees, the licensee identified the systems t

necessary to accomplish the safety functions and also systems that directly support their operability. These systems are as follows:

Reactor Protection System

1. Chemical and Volume Control System High Pressure Safety Injection System

• 1. Low Pressure Safety Injection System

• 1. Containment Spray System

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Service Water System Primary Coolant System Auxiliary Feedwater System ,

Component Cooling System

_ . - ._- _ . _______ __ . _ . . __

Containment Systems

- Containment Air Coolers 4 - Containment Isolation

! Emergency Power Systems

,

Shutdown Cooling '

S

Systems that directly support operability:

*High Pressure Air L *# Instrument Air

! Control Room HVAC

, Engineered Safeguards' Controls

• Engineered Safeguards HVAC Hydrogen Recombiner

.

l A report was generated for each system which documented the system 1 functional description, items accomplished during the outage, a list i of system functional requirements, tests performed to verify the system '

j requirement, and a one-line diagram of the system showing the major i

components in the systems safety-related flow path. For any component in the flow path not tested, the importance of the system requirement

was reviewed by the Operations Manager, Technical Director, and the Plant

4 Safety Engineering Administrator to recommend additional testing, as appropriate, or justify why. testing does not need to be performed. The

>

reports were reviewed by the Plant Review Committee (PRC) for thoroughness and acceptabilit ! The NRC raised questions of the thoroughness of the SFE since it did not appear that the accident analysis in the FSAR (or elsewhere), Technical

Specifications, or the Systematic Evaluation Program (SEP) were used in developing these reports. In addition, some of the justifications for not requiring testing were weak. Because of this, the licensee reviewed the SFEs for completeness using additional documents and upgraded the l exceptions / justifications in the SFE. In addition, the licensee included i additional systems which had been part of the Material Condition Task Force (MCTF) review. These additional systems are:

j Station Power System i

' Turbine Generator

Miscellaneous HVAC (0/G Room and Auxiliary Building)

i Shield Cooling System l Circulating Water System i Neutron Monitoring System l

Plant Data Logger

Post Accident Sampling Monitoring System

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Fire Protection System l Reactor Regulating System i # Main Feedwater and Condensate System

Control Rod Drive System  !

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In order to verify the thorough ess of the licensee's review, the inspector performed a sample inspection of the systems listed in the SFE. This review consisted of three parts; adequacy of SFE methodology, independently develop a list of system requirements to compare with those in the SFE, and review the tests listed as verifying the system requirements for adequac The system requirements and testing reviews consisted of sampling five of the systems that were part of the SFE process. Systems identified by an * were part of the system requirement review and those identified by an # were part of the testing review. System Functional Evaluation Methodology The licensee's methodology for developing the SFEs was judged to be adequate. The systems included in the SFE, including the additional systems from the MCTF, are those systems required to operate the plant safely. Source documents used to develop the system requirements were expanded by the licensee to ensure that the SFE was complete. Adequate testing for each system requirement was determined by reviewing Technical Specification Surveillances, Special Test Procedures, Periodic Activity Control Sheets (PACS),

and normal plant operations. In cases where testing had not been performed, source documents were in error, or components did not meet design requirements, a justification or exception was liste This list should ensure that the required testing is performed prior to startup, periodic procedures are implemented, and errors in source documents are corrected. System Requirement Review The inspector independently developed a list of system requirements for the five systems being reviewed. Documents used by the inspector to develop this list included the following:

FSAR (including accident analysis)

Technical Specifications Systematic Evaluation Program Emergency Operating Procedures System Operating Procedures General Operating Procedures Of f-Normal Procedures Standard Review Plan Regulatory Guides The results of this review concluded that the system requirements listed in the SFE agreed with the list developed by the inspecto The review did find some minor discrepancies in the requirement list and in the documents used to develop the lists. The discrepancies are listed by system as follows:

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Containment Spray FSAR Figure 6-2, Sheet IB, shows that the NaOH tank has one open and one closed gate valve in the flow path from the tank to the suction of the CS pumps while Section 6.4.2.1 of the FSAR states that there are two open gate valves in the flow path. The licensee stated that the figure is correct and the FSAR section needs to be revise FSAR Section 6.1.1 states that one containment spray pump has the capacity to maintain core water level if the primary coolant pressure permit This function was not listed in the SFE, The licensee stated that they do not take credit for this function, and as such, intend to delete this statement from the FSA These items will be considered an Open Item (255/86035-134)

pending a revision to the FSA Instrument and High Pressure Air Statements 9.5.2.1 and 9.5.3.1 of the FSAR appear to be in conflict in describing the function of the High Pressure Air System. The first states that all valves can be operated twice, while the later states that all valves can be cycled in one direction and enough air remains available to shift Safety Injection valves to the

recirculation phas FSAR statement 9.5.2.3.4 should be designated as 9.5.2.3. Table 9.9 in the FSAR lists a total of eight nitrogen bottles used as backup instrument air for AFW valves. With the licensee's latest modification, there should be a total of eleven nitrogen bottle These three items will be considered an Open Item (255/86035-135)

,

pending a revision to the FSA FSAR Section 9.5.2.3.1.a states that Instrument Air is able to supply a continuous80-100 psig pressure. This requirement was not listed in the SFE. The licensee intends to add this requirement to the SF Low Pressure Safety Injection Technical Specifications 3.3.1.b states that the Safety Injection Tanks should be maintained at a level of 186 - 198". This requirement was not listed in the SFE. The licensee added this requirement to the SF System Requirement Testing Review The test program developed by the licensee to verify that the system requirements listed in the SFE have been tested consists primarily of ensuring that there are test procedures (Technical Specification i

Surveillances, PACS, Special Tests) to verify the requirement _ _ - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ - _ ____ _ _ _ _ _

._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ . _ _ _ _ _ _ . __ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

For system requirements that are not tested, exceptions were listed to ensure that testing will be performed prior to startup and periodic test procedures written, or to justify why no additional testing is required, as applicable. The procedures that the licensee is taking credit for are those completed since the last refueling outage (December 1985) or as procedures were schedule It was not the 9 intent of the licensee to reperform these procedures after the May 19th event. Procedures were performed to verify functions not previously tested, normally scheduled surveillances and PACS, and maintenance / modification testin In order to review the licensee's process, the inspector reviewed E0Ps, SOPS, completed surveillances, PACS, and special tests to ensure that each function had been properly tested. The tests showed that individual components met their acceptance criteria (valve stroke timing, instrument calibrations, pump performance curves,etc.). In other cases, functions like SIS, RAS, CHP, and CHR were tested to verify that all components that received the signal functioned as required. In some of these cases, valves that received a signal to operate the valve were already in the position required. The test only verified that the valve would not reposition incorrectly, but did not verify that the valve actually received the signal. A generic concern that the licensee discovered was the fact that some surveillances and PACS did not verify annunciator actuations. This is an item that the licensee will be correcting by updating surveillances and PACS. The inspector found that some of the tests listed as verifying a function were incorrect. The licensee was following up on this item to ensure that the correct test is listed or, if required, additional testing performed. In two cases the licensee took credit for PACS that had never been performed and are not intended to be performed until the next refueling outage. The following is a list of inspector comments for the systems reviewe Chemical and Volume Control System The SFE lists PAC CVC-035 as calibrating the low-low alarm setpoint on the Volume Control Tank (VCT). The inspector's review of this procedure concluded that the procedure listed was incorrect. The ifcensee has stated that PAC CVC-024 does this calibration and will update the SFE accordingl The SFE lists surveillance Procedure RR-09L as calibrating Radiation Monitors RIA-0202A and B, although only RIA-0202A is calibrated by this procedure. The licensee stated that only the "A" monitor is required per Technical Specifications. No testing is performed on the "B" monitor, but the licensee intends to periodically test RIA-02028 in the futur The SFE will be updated accordingl _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

The SFE states that 50P-2A establishes the valve lineup to inject concentrated boric acid through the Safety Injection system although the 50P lines up the charging pumps from the VCT and not the Boric Acid Tanks (BAT). The license has tested that this flow path is availabl The SFE lists in several places that Checklist 2.2 veriffes that two charging pumps can be provided with 08 gpm from several source The inspector's review of the checklist revealed that the acceptance criteria was 66 gpm, not 68 gpm. By reviewing copies of completed checklists, the inspector concluded that the flow values obtained were in excess of the required 68 gpm. The licensee committed to changing the checklist acceptance criteria to 68 gpm. TCN-0-87-003 was issued February 3, 1987 to correct the concern. The inspector reviewed Administrative Procedure 10.41, " Procedure on Procedures," and determined that the TCN appeared to be in violations of Attachment 5,Section I.c This section states that a TCN is not permitted when it results in the addition or deletion (altering) of acceptance criteri This is considered a violation (255/86035-136) of the licensee's administrative procedures.

The SFE lists survelliance R0-8 as verifying that all three charging pumps will start on the receipt of a Safety Injection Signal (SIS).

The inspector's review of this procedure determined that only the

"A" and "C" charging pumps would start on a SI The "B" pump would only start if the flow in the charging system was low (less than the flow of one pump). The most limiting accident analysis for the charging pumps is the Main Steam Line Break (MSLB) which requires 68 gpm flow to the core. This is equivalent to two charging pumps running. Technical Specifications require that two pumps be operable, but do not distinguish between the three pumps. If the "A" or "C" pump was inoperable as allowed by Technical Specifications at the time of the SIS, only one pump will start as the charging flow required will be greater than the flow to start the "B" pump. This will not meet the requirement of 68 GPM flow for a MSLB. This will be considered an Open Item (255/86035-137) pending further revie Low Pressure Safety Injection The SFE lists that the Safety Injection Tanks' pressure and level i instruments are tested by surveillances RI-15A and RI-158. However, the inspectors' review showed that both of these procedures tested the pressure instruments only. The licensee stated that the level instruments are tested in RI-15C and have incorporated this

! information into the SF The system requirement stating that "Two check valves prevent 1, primary coolant from entering the SITS," lists only the test which verifles the check valves can pass flow, but does not list testing which verifles that the valves will prevent backleakage into the SITS. The licensee stated that Surveillance 50-9 performs seat

leak tests of the check valves and have incorporated this information

<

into the SFE.

36

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _

The system requirement from FSAR, Section 6.1.2.1, stating that a " SIS also opens certain valves, as shown on P&ID 203, Sheets 1 and 2," is verified by Surveillance R0-8. The inspector reviewed the surveillance and the P&ID and verified that Sheet 2 of P&ID 203 contained four valves that open on a SIS and were tested in R0-8.

Sheet 1 of P&ID 203 did not contain valves and a SIT fill and drain valve that receive a close signal on a SIS. R0-8's initial conditions have these valves in the closed position such that on a SIS the valves can only be verified to remain closed. The test does not verify that the valves received the SIS signal to close. This appears to be a generic concern in that it does not appear that the licensee consistently tests valves which are normally in their required position for receipt a SIS, RAS, CHR, or CHP. This could be a problem if for some reason the valves were not in their normal position. This is considered an Open Item (255/86035-138) pending a review by the licensee. In addition, the FSAR statement also appears to be in error and needs to be corrected. This will be considered an Open Item (255/86035-139) pending a revision to the FSAR.

A similar concern to that stated in the previous paragraph is that of the component cooling heat exchanger service water outlet and component cooling water inlet valves which are normally throttled open, but are to open fully on a RAS. R0-8 does not verify that the valves will fully open. This will be considered part of Open Item (255/86035-138) pending further licensee review.

Containment Spray Two of the PACS, ESS-087 and ESS-088 that are listed in the SFE as verifying the hydrazine and sodium hydroxide tanks level indicators have never been performed and were not scheduled to be performed until the next refueling outage. This will be considered an Open Item (255/86035-140) pending further information from the licensee.

PAC ESS-017 incorrectly lists the hydrazine tank (T-102) as the sodium hydroxide tank. In addition the logic diagrams E17, Sheets 6 and 7, also incorrectly identify T-102 as the sodium hydroxide tank. This will be considered an Open Item (255/86035-141) pending revisions to the PAC and the logic diagram.

The SFE lists a system requirement that stated the hydrazine injection signal can be blocked on spurious signals. The testing listed is that the block feature is addressed in the E0Ps. However, this does not verify that the block logic work This is considered an Open Item (255/86035-142) pending further information from the licensee.

Main Feedwater and Condensate System The SFE listed the testing for the feedwater pump suction and discharge pressure instruments as being PACS FWS-017 and FWS-012 although FWS-012 is for the AFW system and FW5-107 only does the

._

discharge pressure instruments. The licensee has stated that the correct PAC is HED-002 for verifying the suction pressure instruments. The SFE needs to be updated to incorporate this informatio A system requirement exists stating that on a high steam generator level a signal is sent to close the associated feedwater regulating control valve (FRV). The SFE states this is tested in PACS FWS-031 and FWS-030 although it was unclear to the inspector as to how this was accomplished. The licensee is modifying the PACS to verify the auto close feature of the FRVs and will perform the PACS prior to startup. This will be considered an Open Item (255/86035-143)

pending revisions and performance of the PAC In addition to the items discussed above, the inspection team also reviewed the justification for every functional requirement identified during the SFE for which testing was not scheduled prior to startup. In each case, it was concluded that adequate justification for not testing existed and the lack of testing did not impact either safe or reliable plant operatio One violation and no deviations were identifie Conclusion The SFE had not been approved by the PRC at the time of the inspection, but has undergone most of the planned technical review at the time of the inspector's review. Although most of the comments by the inspector are minor in significance, there were a number of errors in the SFE. These errors can be classified into three arcas: (1) errors in source documents; (2) incorrect tests listed: and (3) testing not being adequate. Since the inspector sampled only a small portion (15%) of the SFE, there is some concern over the accuracy of the detail in the SFE. However, the licensee's intent of the program was to ensure that there are not any major prol,lems in their testing program and it appears that this task was accoT-?'shed. Problem areas that were identified are being corrected as required. Prior to the licensee approving the SFE, the licensee should ensure that they have confidence in the SFE's accuracy and completeness.

5. Outstanding Program Issues At The Time Of May 19 Trip The following is a list of programmatic issues outstanding at the time of the May 19 trip:

• Organizational weaknesses in the maintenance department caused inefficiencies in the processing of maintenance work orders, thereby contributing to an excessive backlog of wor * Personnel were not consistently entering deficiencies into the maintenance order system but were informally prioritizing items and entering those which they considered most significan ______ -- _ _ _ - _ - _ _ .-

• Root cause determination for equipment malfunctions was not consistently performed with the result that repairs were not consistently effective and corrective actions were narrowly focuse * The Preventive Maintenance Program lacked sufficient scope and was not effectively implemente * Procedural problems existed including compliance, adequacy of instructions, and excessive use of Temporary Change Notices (TCN's).

• Design inputs to modifications and 10 CFR 50.59 reviews were not consistently adequat * There existed a lack of documented training for maintenance and technical personne * Management and supervisory decisions did not consistently reflect a conservative approach to plant operation The team reviewed the current status of each of these issues, making the following observations: Organization Weaknesses The licensee has taken a number of steps to enhance the efficiency and effectiveness of the maintenance process. Included in these actions were the commissioning of a Maintenance Administration Task Force to review the maintenance process and make recommendations for improvements; the implementation of a system engineer program; implementation of a computer - based Advanced Maintenance Management System; and creation of a new group in the Operations Department to interface with the Maintenance Department on such matters as priorities, schedules, and post-maintenance testin (1) Maintenance Administration Task Force The inspection team reviewed the final product of the Maintenance Administration Task Force which was commissioned by the licensee in December 1984. The Task Force reviewed Administrative Procedures and other controlling documents, maintenance order data, and interviewed 72 employees. From this effort, a list of problems was generated. The problems were assigned as appropriate to one or more of eight major maintenance program

'

areas including initiation and closecut; planning; scheduling

' and interface; parts and services; quality program impact; engineering; performance and training; and management.

Recommendations were then developed for resolving each

'

problem. A common theme of weak personal ownership in the l

!

overall maintenance process was identified by the Task Forc The Task Force went on to conclude that a fragmented work process diluted individuals' overall understanding and stifled sharing of problem solvin With regard to work order initiation, the Task Force found that the most significant problems involved poor descriptions of problems and any troubleshooting performed by the initiator, a confusing work order (W0) form, and a requirement to process a separate WO for each equipment number involved in a particular activit The inspection team reviewed Administration Procedure 5.01, " Processing Work Requests / Work Orders" and determined that this procedure now provides explicit and acceptable directions to initiators regarding the level of detail required in problem and troubleshooting description It further directs the Operations Planner to return all unacceptable WO forms to the initiator's supervisor with comments as a quality feedback mechanism. The current WO form was fcund to be reasonably straight forward, and the procedure now allows one WO to be rised to control the work of multiple discipline With regard to W0 closecut, problems were identified with inconsistent definitions of post-maintenance testing activities and unnecessary duplication of documentation of work performe Review of Administrative Procedures 4.03, " Equipment Control,"

and 5.01 showed that the definition discrepancies have been resolved and that documentation duplication has been eliminate In the area of planning, 11 problems were foentified. The most significant of these were the planning function is understaffed, too many planners became involved in each job (operations, maintenance, chem /HP), the Q-list was incomplete with the result that excessive numbers of W0's required unnecessary QC review, and jobs were not planned to take advantage of equipment availabilit As described elsewhere in this report, during the course of this inspection the inspection team conducted a line item by line item review of outstanding W0's. During this review it was identified that approximately 200 mechanical maintenance work orders were on hold awaiting planning. This number is unacceptably high. In response, the licensee made temporary additions to the planning function. Permanent resolution of

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this issue will be tracked as an Open Item (50-255/86035-144).

As currently written, Administrative Procedure 5.03 requires the Operations Planner to review all newly initiated WO's for effect on plant conditions, Technical Specification involvement, priority, and operability testin After this initial review, the WO is forwarded to the Maintenance Department Work Planner who is responsible for detailed work planning and job interfaces (e.g., RWP's). This process is simple and workable. Based on i

t

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discussions with members of the licensee's Operations Department, the Operations Planner has done much to streamline the planning process by serving as a needed interface between operations and maintenanc The-licensee has yet to finalize their Q-list, although progress has been made. This program still impacts the efficiency of the planning process; however, given that items whose Q-list status has yet.to be determined are considered Q, assurance is provided that necessary quality reviews will be consistently conducte The licensee currently plans to complete the Q-list as part of their Configuration Management Progra Interviews with operations department personnel conducted by the inspection team indicated that coordination of multiple maintenance tasks on a single piece of equipment is still lacking. Existing plant procedures are silent in this regar This is viewed as a program weakness which compromises the efficiency of the maintenance process. The inspection team did note however, that the licensee did perform other work on

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the 1-1 Diesel Generator while it was out of service to repair an exhaust lea In the area of scheduling and interface the Task Force identified four general problems. These were perceived last minute management priority shifts ccmpromising scheduled activities, multiple priority systems, failure to coordinate maintenance / testing on a given piece of equipment or within a given tagging boundary, and untimely notification to HP and QC such that necessary support was not availabl Interviews with operations personnel during this inspection j indicated that priority shifts were still occurring frequently

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and that schedules provided were frequently of marginal use.

,

This, they indicated, not only impacted the completion of maintenance but distracted them from plant monitoring duties

,

while preparing tagouts. As noted above, a lack of I coordination has compounded this problem.

! The issue of multiple priority systems has been resolved by

,

defining a numerical prioritization system and placing the l

prioritization responsibility with the Operations Planner

.

in the Operations Departmen The subject of schedules was discussed with the Administrative and Planning Manager who provided the inspection team with a copy of the plant daily scheduling guidelines which are in the

'

process of being finalized. These guidelines prescribe a two-tier scheduling process. The higher tier portion involves

! preparation of a weekly schedule for each of the next four weeks

,

of known and desired activities. These schedules are updated in i weekly meetings. Activities to be included on the schedule are l

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- - - ,.-,,. ,--,e- . - - - - , , . . , - - --.,~-,--.-r_nr -,-..,.--n.,_ ~ . . - - - , . , - - , - ---w,.. - - . , - -~--m.,w- r.,-- -. v -

significant events that may affect plant resources or operations, plant projects (e.g. , trajor modifications), system of the week corrective and preventive maintenance for the fourth week, outage work preparation, and other work activities. The activities are scheduled on a day by day basis.

The purpose of the weekly planning schedule is to enhance communications by identifying general or significant work evolutions expected for the next four weeks. Representatives from Planning and Scheduling, Operations, Maintenance Planning and Scheduling, Radiation Protection, Quality Control, Engineering, and Projects are required to attend the weekly meetings. Emphasis is placed on department support coordination and work consolidation to take advantage of system / equipment outages to complete as much corrective and preventive maintenance as possible.

The weekly meetings are supplemented by a daily morning status meeting to discuss plant progress and problems. Attendance is required of Operations, Maintenance, Radiological Protection, Quality Control, Engineering, and Projects.

The lower tier of the scheduling process requires the daily development of a 72-hour plant daily schedule. The daily schedule utilizes the weekly schedule as one source of input.

Other inputs include other W0 Maintenance Activities, Technical Specification Surveillance Tests, Operations Activities, and other activities identified by plant personne Daily meetings are held to identify any schedule changes / problems for the rest of the day and to review and finalize activities for the next day. Required attendance includes Planning and Scheduling, Operations, Maintenance, Radiation Protection, Quality Control, Engineering,andProjects.

The inspection team concluded that this two tier scheduling process should provide an effective mechanism for scheduling activities, communicating support needs, and identifying equipment / system availability for consolidated maintenance.

The team did note that it may be appropriate to include Technical Specification surveillance tests on the weekly schedule to provide a better forecast of manpower needs and availability.

The fact that the Operations Department personnel still considered scheduling to be a problem is indicative that either the scheduling process is not being adhered to such that priorities are being changed and/or not effectively communicated or the work planning process is not sufficiently effective in defining work scope, manpower required, or parts neede Given the reactive nature of the current outage, this is not unexpected; however, as conditions become more stable the licensee is encouraged to refine their capabilities in prioritization and plannin . - - _ _ _ .

In the area of parts and services, the Task Force identified four general problem These were lack of immediate access to parts and lack of prestaging, the lack of coordination between store room part identification numbers and plant equipment identification numbers, the incomplete Q-list making it difficult to get certain parts released, and a lack of a comprehensive approach to spare part These issues were discussed with the Administrative and Planning Manage From this discussion it was learned that some improvement in access to consumable parts and prestaging of parts, and in completing the Q-list has been made, but that neither of these problems has been satisfactorily resolve The Q-list is only approximately 80% complete. During the inspection, work was delayed for almost two shifts on a containment spray isolation valve while the worker waited for parts required for reassembly. The Q-list problem has been particularly burdensom The problem with parts identification relates primarily to cross referencing parts from one piece of equipment as being acceptable for use in other pieces of equipment. This resulted in delays in completing repairs to the containment sump isolation valves during the last refueling outage. This situation adversely affects the efficiency with which maintenance can be conducted, and as such, impacts the WO backlog. Several unsuccessful attempts have been made by the licensee to resolve this issue. The licensee now believes it necessary to obtain outside assistance to complete this task and plans on incorporating this in their yet to be developed Configuration Management Program. This will be tracked as an open item to ensure that it appears as an issue to be addressed by the Configuration Management Program (50-255/86035-145).

On the subject of Quality Program impact, the Task Force identified two general problems. The first problem is that jobs which involve QA/QC take longer than those which do no This is a statement of fact and necessity and is not considered a problem by the inspection team. The second problem was that the incomplete Q-list complicated the maintenance proces This is discussed elsewhere in this repor On the subject of engineering, two general problems were identified. The first was that the work load on the engineering staff is excessive with the result that issues do not always receive attention in a timely fashion. The second general problem was that system engineers lack experience and are not fully cognizant of assigned system statu During the course of this inspection the team determined that the licensee's System Engineering Department is fully staffed (approximately 25 engineers) and has been for approximately one

_ _ - - _ _ _ _ _ . . _ _

year. Experience levels vary but are improving and a training program is under development. One key feature of this program is systems training. The licensee has committed to complete this training by December 1987. This will be tracked as an Open Item (50-255/86035-146).

Interviews with Operations personnel indicated that the Systems Engineers are becoming more involved in system oversight and problem resolution. In general, the cooperation between engineering and operations has improve With regard to the engineering backlog, the inspection team identified a problem. At the time of the inspection there were between 600 and 700 open Engineering Support Recuest This system was not being effectively managed at evicenced by the fact that the licensee was unsure of either the status or significance of the outstanding requests. At .1 minimust, the licensee was asked to review the list of open Engineering Support Requests prior to startup to determine if it contained any issues requiring resolution prior to startu '

In the area of performance and training, the most pertinent observations were related to the extent of training provide In this regard, the licensee's program for I&C Technicians has been accredited by the Institute for Nuclear Power Operations (INP0). Mechanical and Electrical Craft training programs based on a Systematic Approached to Training concept have been submitted to INP0 for accreditation. Implementation of these programs is in progress. If appropriately implemented, these programs should relieve outstanding concerns in the maintenance are In the area of management, the most pertinent observation was that goals for WO backlog had not been established. As noted elsewhere in this report, goals have now been established and the licensee has committed to devote the resources necessary to achieve these goals. Progress in this regard is being followed closely by managemen (2) System Engineer Program As discussed above, the licensee's System Engineering Program is now fully staffed. As the engineers have gained more experience their effectiveness has improved. Training programs are being developed and implemented. Additionally, based on discussions with a number of Systems Engineers, morale is goo They now feel that management is fully supporting needed plant improvements and many of the activities that were previously put on hold are now proceedin The inspection team's experience in dealing with the Systems Engineers was generally very good. They were found to be knowledgeable, aggressive, and responsiv _ _ _ _ - _ _ _ _ - . _ _ -

(3) Advanced Maintenance Management System (AMMS)

This system is a computerized data base system which provides ,

ready access to large volumes of information on equipment

~

including performance data and maintenance history. Internal

. cross referencing allows the usrr to rapidly determine if similar equipment is installed ta other locations in the plant by sorting on vendor information. It allows computer generation of work orders and can be used to status work orders. Proper use of this system will permit easy trending of equipment performanc As committed to in response to CAL-RIII-85-15 the machinery history contained in AMMS has been updated to include three years of historical dat This issue is close (4) Operations Department Reorganization As discussed elsewhere in this rep, ort, the licensee has successfully reorganized the Operations Department to improve the operations / maintenance interfac .

With regard to organizational weaknesses, the inspection team i

concluded that the licensee has made significant progres The WO process has been streamlined and simplified, a single prioritization scheme has been adopted, reorganization has improved

,

the operations / maintenance interface, engineering presence and expertise has been strengthened, enhanced training programs have been developed and are being implemented, meaningful goals have ;

i been established for work order backlog and progress is being trended by management, and a ccmputerized equipment data base has been implemented allowing ready access to machinery history and WO status.

,

, Most of the tools and mechanisms to control an effective maintenance program are in place and, as experience is gained, further refinements and improvements are expecte However a number of key weaknesses continuetoexistwhichhavethepotentIa1toadverselyimpactonthe efficiency of the maintenance proces Most notable in this regard are staffing the planning function, the lack of a complete Q-list, coordination of activities to take maximum advantage of equipment /

plant availability, and spare parts availability. Until such time I

as these weaknesses are resolved the licensee will have to devoto extra resources to the maintenance process in order to maintain an acceptable level of material condition, b. Threshold For Deficiency Identification This issue has not been completely resolved. In an effort at statusing this issue the inspection team conducted walkdowns of a 1 number of systems which were operational at the time of the inspectio This effort, described in more detail elsewhere in this report,

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identified numerous minor deficiencies requiring attention. The :

fact that these deficiencies were tolerated is indicative of a

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threshold of acceptability which is too high. This was supported by the results of interviews with operations personnel who acknowledged the existence of minor deficiencies but stated that they hadn't viewed these as problems in the pas '

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Licensee management had identified this problem in the past and, through a series of meetings with plant personnel communicated their expectations regarding deficiency identification and correctio This was reinforced by sending a significant number of plant personnel from various departments, supervisors through workers, to another Region III facility to establish a comparative basi Based on the interviews with operations personnel, it is conc.luded that management did successfully communicate their expectations and that the shortfalls observed represent the time lag in implementing these expectations. It was also concluded that continued reinforcement of management expectations will be necessary as attitudes have not yet changed, c. Root Cause Determination / Corrective Action Scope Licensee Administrative Procedure 5.01, " Processing Work

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Requests / Work Orders," in Section 6.2.11. " Performance of Work l Orders," requires the lead Repairman / Technician to summarize the

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work performed including the root cause of the failure on the WO form. The Maintenance Supervisor is required to review this information. These requirements were added in Revision 7 of this procedure dated September 30, 1986.

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Licensee Administrative Procedure 3.0.3, " Corrective Action," requires

that all conditions adverse to quality be evaluated for cause. The Deviation Report and Event Report forms required to be completed by j the procedure both contain an evaluation section which requires

, designation of both proximate and root cause of non-conforming conditions. Additionally, the procedures require that corrective

"

actions address the root causes in such a fashion such that similar probitms be prevented. These procedures, if effectively implemented, should ensure that the root causes of equipment problems and conditions adverse to quality are determined and that appropriate corrective actions for the identified problem are taken.

1 During the course of the inspection the team reviewed the disposition of many equipment deficiencies and found that root cause was consistently assessed. Corrective actions addressed root causes and, in many cases, were expanded to irclude evaluation of other

, equipment. Most notable in this regard are the pump testing program

'

performed to address concerns identified with pump performance and i

the System Functional Evaluation to determine overall test program adequacy and system performanco capabilities. However, several instances were noted by the inspection team where licensco corrective

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actions appeared to focus narrowly on a specific technical issue and

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not consider the more generic issue which was involved. Notable in this regard were corrective actions for some of the SSFI findings relating to electrical system It is the team's conclusion that the licensee has in place the necessary mechanisms to ensure that root causes of problems are identified and acted upon and that corrective action scope is appropriate. Licensee performance has shown some improvement; however, some examples of shortcomings were identified, indicating that additional licensee effort is warranted.

d. Preventive Maintenance Proaram Inadequacies In the licensee's response to the NRC's request for information pursuant to 10 CFR 50.54(f) it committed to accelerate the development of its preventive maintenance program for equipment important to safe and reliable plant operations. The inspection team did not attempt to evaluate the licensee's progress in this regard but focused rather on more immediate equipment problem resolution. A followup inspection of the licensee's preventive maintenance program will be performed as the program is complete The inspection team did, however, review the licensee's Administrative Procedure 5.03, " Preventive Maintenance Program" to determine program structure adequacy and the adequacy of the criteria employed to decide what equipmr.nt would be the subject of preventive maintenance. This procedure specifies that all equipment important to safe and reliable operation or important to assure public and employee safety is to be included in the program. Every 24 months the Engineering and Maintenance Superintendent is required to have a review performed on a plant system basis of all corrective and preventive maintenance in order to identify whether new preventive maintenance (PM)

activities are appropriate. New PM's, whether generated by the 24 month review or other means, are required to reflect vendor's recommendations as modified by plant experience and applicable codes and standard The PM program is implemented through the Periodic Activity Control Program described in Administrative Procedure 5.14. Review of this procedure revealed two significant weaknesses. The first is that activities which are required by regulatory requirements other than technical specifications are not required to be so identified. The second is that the procedure does not specify who may cancel an activity when it comes due or the criteria to be employed when cancelling the activity. Resolution of these issues will be tracked as Open Items (50-255/86035-147; 50-255/86035 148).

Other than the weaknesses identified in the proceeding paragraph, the team found the procedures controlling the PM program to be acceptabl .- . In addition to accelerating the development of the PM program, in its response to the 10 CFR 50.54(f) letter, the licensee committed that prior to startup an augmented test program would be developed and implemented. This program, which involves inspection, testing, and PM's on plant equipment important to reliable plant operations, is intended to supplement the technical specification surveillance program. Ten systems were identified where additional testing was deemed appropriate. These systems included the Primary Coolant System, the Chemical and Volume Control System, the Feedwater and Condensate Systems, the Auxiliary Feedwater System, the Service Water System, the Instrument Air System, the High Pressure Air System, and the Turbine Generator System. While the team did not specifically review the augmented test program, it was noted that many of the items has also been captured in the MCTF and SFE effort This program will be reviewed during a future inspection. Procedural Adequacy, Compliance, and Use of TCN's As discussed in the section of this report on licensee actions on previous inspection findings, licensee actions on a number of violations regarding procedural adequacy and compliance were reviewe In general, these actions were found to be adequate. In addition, during the course of the inspection, the team reviewed numerous procedures and monitored procedural compliance. With the exception identified elsewhere in this report regarding 10 CFR 50.59 reviews and the Periodic Activity Control System most procedures were found to be generally adequate. Maintenance procedures contained or referenced appropriate information to allow completion of assigned activitie The team did note, however, that the number of TCN's to procedures appeared excessiv To quantify this observation the team reviewed a computer generated list of controlled documents dated January 9, 1987 which included the number to TCN's for each procedure. There were 933 open TCN's for the approximately 1330 controlled procedure The single procedure with the most TCN's was System Operating Procedure 50P-1, " Primary Coolant System" with 13 TCN's. Of 44 SOP's, 30 had at least 1 TCN and the total number of TCN's was 115. The longest period elapsed since the last revision to any S0P was 21 months with an average age since last revision of approximately 11 months. Test Procedures T-202 and T-203 on Auxiliary Feedwater Testing were reviewed. T-202 Revision 1wasissuedonOctober31, 1986 and performed starting on December 1, 1986. Between December 1, 1986 and December 2, 1986, 4 TCN's were issued, two because wrong terminal locations were specified in the procedure and the fourth to correct incorrect information in the first TCN. T-203 Revision 0 was issued on September 18, 1986 and authorized for performance on December 2, 198 On this same date four procedural errors had to be corrected by TC . ..

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From this information the team drew two conclusions. The first was that TCN's are being used as a mechanism to bypass the rigors of the revision process and that this is tacitly accepted by plant management. The second conclusion is that the licensee's procedure review process as defined in Administrative Procedure 10.41, " Procedure on Procedures" is not effective at consistently ensuring the technical quality of procedure Inappropriate use of TCNs is the subject of a violation discussed elsewhere in this report.

6. Followup on Safety System Functional Inspection Items Between September 22 and October 24, 1986 the NRC conducted a Safety System Functional Inspection at the Palisades Plant. This effort involved an assessment of the operational readiness and functionality of the high pressure safety injection (HPSI) system. Particular attention was directed to the details of system design and modification, maintenance, testing, and operations. As a result of that inspection, documented in inspection report 50-255/86029, 15 unresolved items and two open items were identified. During this inspection the inspection team reviewed the status of all but one of the items identified in Report No. 8602 The review included the licensee's response to Inspection Report No. 50-255/86029 dated January 21, 198 The purpose of this review was to determine if the issues had been resolved from a technical standpoin The subject and status of each issue at the close of this inspection is presented below:

• Unresolved Item 50-255/86029-01: Review of the SI system control circuitry revealed that the recirculation actuation signal (RAS)

was not designed with a seal in feature. As a consequence, the water source for the SI pumps may unintentionally shift from a reliable and sufficient source to a nearly empty sourc In response to the issue the licensee developed a modification that added a seal in relay such that upon receipt of a RAS signal the RAS functions will be enforced until the initiating signal is cleared and the circuit is reset. The inspection team reviewed the modification package and determined it to be technically acceptable; however, two questions were identified, the first being whether components resume their pre-RAS configuration upon circuit rese Second, the team identified that the surveillance procedure the licensee intended to use to satisfy post-modification testing requirements did not test two RAS functions identified in the modification package, namely, that the SIRW Tank recirculation valves would automatically close and that a second component cooling water pump would automatically star Regarding the first question, further review of system functioning revealed that the functions affected by RAS would, in fact, resume their pre-RAS configuration upon circuit reset. This is contrary

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to the guidance provided by IE Bulletin No. 80-06; however, the licensee's response to this bulletin is still under evaluation and RAS reset repositioning will be evaluated as part of the bulletin evaluation effor Regarding the second question, review of the RAS circuit diagrams and functional descriptions in the updated FSAR revealed that the SIRW Tank Recirculation Valves do not receive an automatic closure signal upon receipt of a RAS signal. Rather, a permissive in the valve's closure circuit is made up by the RAS signal allowing the operators to close the recirculation valve Closure of the valves is directed in Step 18 of Procedure E0P 4.0. The permissive feature is adequately tested in the post modification / surveillance tes The only reference which could be found for automatic start of a

second Component Cooling Water (CCW) pump in the FSAR was the RAS

Logic Diagram. The RAS circuit diagrams do not show this function.

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The inspection team also reviewed the current revision of the

electrical schematic for the CCW pump start circuit, E-259, and identified no interface with-RAS. Given that all three CCW pumps receive an automatic start signal upon Safety Injection System (SIS)

activation, this discrepancy has no technical significance. The j licensee initiated a change to the FSAR to make it consistent with

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as-built condition I The licensee also revised E0P-4 to address manually realigning components affected by RAS if automatic realignment does not occu The team reviewed these revisions and found them acceptable. In i addition, the licensee reviewed other safety-related automatic

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actuation circuits (approximately 25) and identified only one other as a candidate for modificatio This unresolved item is considered closed; however, the discrepancies identified by the inspection team regarding the failure of the review process to identify that the modification package identified two RAS

> functions which did not, in fact, exist and which were not addressed in the post-modification test procedure is indicative of inadequacies in the modification review process and is considered a violation 4 (50-255/86035-149) of licensee administrative procedures controlling the modification proces ; * Unresolved Item 50-255/86029-02: The HPSI system was not single failure proof in that the minimum flow recirculation Valves CV-3027

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and CV-3056 were both supplied from the high pressure air syste Loss of the safety-related high pressure air system could compromise

the operator's ability to close the valves from the Control Room as

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directed in Step 18 of E0P 4.0. Failure of the valves to close could

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result in the recirculation of highly contaminated water to the SIRW j tank from the containment sump as well as deplete the inventory of water in the containment sump for recirculation. This configuration was part of the original plant design.

) 50

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The licensee's proposed resolution to this issue is to add a backup nitrogen supply for operation of these valves. The inspection team

D 'a s reviewed the Minor Modification / Field Change package FC-722 which

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'31

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accomplishes this addition. This same modification included the 31 , addition of backup nitrogen supplies to other important valves as discussed in the next section of the repor U The modification, as it pertains to CV-3027 and CV-3056 consists of reconfiguring the existing High Pressure Air System supply to each valve by adding a manual isolation valve (normally open) and a check valve to the normal air supply upstream of the air solenoid for each valve, and, between the check valve and the solenoid valves, adding a pressure regulated nitrogen supply consisting of a check valve, a normally open manual valve, two relief valves, a pressure

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regulator, and two nitrogen cylinders, one of which is an installed spar This is illustrated in Figure n l

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J FIGURE 1

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1 ORIGINAL INSTALLATION

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PRESSURE REGULATOR, 175 PSIG B

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FILTER lXI 1 LU3RICATOR @)

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REVERSE FLOW CONTROL VALVE

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. _ . . . _ _ . . _ _ . . . . . , . . _ . . _ _ . _ _ _ . . - . . - . _ - _ _ _ _ . _ . _ _ . _ _ _ _ _ _ . _ . . , _ _ . _ . . .

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MODIFIED INSTALLATION h- l-l A I IXi IXi ; j IXl N To l-l V 1 S0LEN0ID VALVES FOR CV-3027

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l-l 50 NOID VALVES FOR

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Z Z CV-3056 RELIEFS x

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NITROGEN CYLINDERS

The nitrogen backup system is capable of supplying 150 psig nitrogen to operate CV-3027 and CV-3056. The backup is seismically designed and is Q-liste As designed, this system will ensure that a gas supply is available to operate CV-3027 and CV-3056 for all single failures of the High Pressure (HP) Air System upstream of the new check valves installed in that system. A single failure of any single line downstream of the new check valves in either the HP Air System or the Nitrogen Backup System will render only CV-3027 or CV-3056 inoperable. Thus, this modification, which will be completed prior to startup, resolves the technical issue identified in this unresolved item, and at least one valve in the series combination of CV-3027 and CV-3056 will be capable of closing under credible fault conditions provided the backup nitrogen supply remains operable. This item is close * Unresolved Item 50-255/86029-03: Certain safety-related valves rely on the non-safety related instrument air system for motive powe The following examples and consequences of valve failure were cite HPSI subcooling valves, CV-3070 and CV-307 These normally shut / fail shut valves are required to open approximately 20 minutes after a LOCA to ensure that adequate subcooling of the water supply to the HPSI system is maintained, thereby preventing cavitation and pump damag FASR Section 9. states that following a DBA, air operated valves will become inoperable or assume their failed position 1.4 minutes after loss of instrument air. Thus, only approximately 21 minutes are available for operator action to restore instrument air or to manually reposition CV-3070 and 307 i Normally shut containment spray header isolation valves CV-3001 and CV-3002 open in response to a high containment pressure condition er less of instrument air. Under certain accident conditions; however, one or both of these valves is required to be closed to either prevent containment spray pump runout or ensure adequate HPSI pump subcooling. Loss of instrument air could, without followup operator action, defeat these function iii. Instrument Air Containment Isolation Valve CV-1211 fails open on a loss of instrument air and does not receive an automatic containment isolation signal. Failure of instrument air piping inside containment combined with the single active failure of the redundant containment isolation valve could create a post-accident containment vent path into the instrument air system which would require local operator action to effect isolation.

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i Iodine removal tank isolation valves CV-437 and 4378 receive a signal to open on high containment pressure such that the hydrazine solution is delivered to the containment to improve the removal rate of elemental iodine. These valves fail shut on a loss of instrument air and local operator action would be required to open the During review of this item, the team referenced NUREG-0820,

" Integrated Plant Safety Assessment, Systematic Evaluation Program, Palisades Plant" dated October 1982. Appendix A of this document

. establishes topic definitions for. Systematic Evaluation Program (SEP) review. Topic VII-4, " Effects of Failure in Non Safety-Related Systems on Selected Engineered Safety Features" was defined to address the situation identified by this unresolved item; however, action on this issue was deferred until the NRC resolves Unresolved Safety Issues A-47, " Safety Ic:plications of Control Systems," and A-17,

" Systems Interactions in Nuclear Power Plants." When that action is completed,.the NRC will promulgate generic requirements as appropriate on this subjec In response to this issue, the licensee proposed to add a nitrogen backup supply to valves CV-3070, 3071, 3001, 3002, 1211, 437A and 4378. The inspection team reviewed the Minor Modification / Field Change Package FC-722 which accomplishes this addition.

.

For this portion of the modification, the licensee proposed to add four nitrogen delivery subsystems each consisting of nitrogen bottles, a pressure regulator set at 80 psig, a 100 psig relief valve, and manual isolation valves and check valves configured similarly to the

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modification described in the previous section. Each subsystem is seismically supported to withstand the Safe Shutdown Earthquake and components were procured to standards which are safety-related (Q-Listed). The valve assignment by subsystem is as follows:

l Subsystem Valves

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1A CV-0847 Service Water to Containment Isolation 38 CV-0824 Service Water from Containment Isolation CV-HPSI Subcooling to HPSI Pump P66B 4 CV-0437A Hydrazine Tank Outlet l

CV-04378 Hydrazine Tank Outlet '

l 5 CV-3071 HPSI Subcooling to HPSI Pump P66A

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CV-3001 Containment Spray Isolation CV-3002 Containment Spray Isolation CV-1211 Instrument Air Containment Isolation Review of the modifications identified that the addition of the backup systems enhances the availability of compressed gas to operate the subject valves should an an Instrument Air System failure occur. Further, in no case will a single failure of the backup system by itself render any of the subject valves inoperable.

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The original licensing basis for Palisades designated the Instrument Air System as non safety-related. As such single failure criterion restrictions were not applicable to the instrument air system. The backup system proposed are designed to safety-related standards and the components will be Q-Listed. Implementation of the proposed design will adequately address the unresolved item, which is considered close During review of the modification package, the inspector noted that it failed to address necessary changes to Section 5 of the FSAR to describe the quality and seismic categorization of the backup system This was brought to the attention of the license Disposition of this finding will be tracked as an Open Item (50-255/86035-150).

• Unresolved Item 50-255/86029-04: In 1983 and 1985, the licensee performed dynamic voltage regulation studies to evaluate AC system performance under accident conditions. Because of limited computer capacity, a number of loads fed from motor control centers (MCC) had to be combined and treated as a single load. One of the loads which was combined with others for evaluation purposes was cold leg injection Valve M0-3008. While the licensee's analysis concluded that, based on system response, sufficient voltage was available to ensure proper response of the combined and hence individual loads, the SSFI team determined that this conclusion was based e : ..v.i. i na i starting current for M0-3008 of 96 amperes. Vendor information indicated that this starting current could, in a locked rot' or condition, be as high as 140 amperes. This current, combined with the fact that the conductors supplying M0-3008 are AWG No. 12 yields a motor terminal voltage of only 70% of the rated value, approximately 20% less than that required to produce guaranteed torqu Consequently, the valve may stall and not operate during the voltage transient. This situation pointed to inadequate evaluation of individual MCC load response by the license In response to this concern, the licensee performed a transient voltage analysis on the motor control centers (MCC) which supply the LPSI injection valves and on the valve motors themselves. This analysis assumed a 140 amp current at a .25 power factor for each l

valve motor, full load values being 18.8 amps at a .8 power facto This MCC analysis showed that the minimum voltage reached was j approximately 72% of nominal and that the voltage recovered to

! approximately 92% of nominal in 4.4 seconds. Minimum motor terminal voltage was approximately 63% of nominal and recovered to 80% of nominal at 4.4 seconds. Steady state running terminal voltage on the motors was calculated to be approximately 91% of nominal.

I The procurement specification for the motors in question required them to be suitable for operation at 90 to 110% of rated voltag With this information, the licensee contacted Limitorque Corporation, the valve vendor. Limitorque concluded that the valve would stroke slowly at first, and that the excessive currents at the reduced l

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voltage would not damage the motor which is capable of withstanding locked rotor current of 140 amps for ten seconds. In addition, the licensee reanalyzed the valve's stroke times in light of the Limitorque information and concluded that they were acceptabl Based on this information, the immediate technical issue of LPSI injection valve operability is considered resolved. The licensee had not evaluated the issue of the adequacy of their overall dynamic voltage regulation studies by the conclusion of the inspectio This unresolved item will remain open pending licensee review of the remainder of their dynamic voltage regulation study.

• Unresolved Item 50-255/86029-05: Facility change FC-562 modified the load shedding scheme of certain non-Class 1E loads following an accident in order that acceptable voltages could be maintained to certain Class 1E loads when supplied from the startup transforme As stated in Section 8.6.1 and 8.6.2 of the FSAR, circuits that are required for load shedding are considered Class 1E devices. However, the classification of breakers 52-7701, 152-303, and 52-7804 was not appropriately changed, calling into question whether these breakers were of the proper quality and properly maintained. Failure to properly control the quality classification of breakers 52-7701, 152-303, and 52-7804 is a violation of 10 CFR 50 Appendix 8, Criterion III (255/86035-161).

In response to the specific finding, the licensee initiated a Q-List Interpretation for the three breakers affected by the subject modification, designating the breakers as "Q" for the load shed function. The breakers were then tested satisfactorily in accordance with the existing program for Q-Listed breaker Regarding breaker quality, the licensee informed the inspection team that all breakers of this type are procured to the same specifications whether or not the application was designated as "Q" and therefore breaker quality was acceptable. Given that the quality requirements for maintenance and replacement parts are different for Q and non-Q equipment, the team questioned this conclusion. The licensee agreed to review the maintenance history of the breakers to determine if any actions had been taken which could compromise conformance with original procurement specifications. This was completed and it was determined that no corrective maintenance had occurred on nor where any modifications made to the breakers since their original installation other than the load shed function described herei In response to the general concern regarding breaker quality classification, the licensee performed a review of the Station Power System Breakers for Q/non-Q interfaces, breaker overload testing, and inclusion of breakers in the in the PM program. Concurrent with this effort, the PM program for non-Q breakers was upgraded to perform the same PM's as those performed on Q breakers but at a reduced frequenc All Q breakers will be PM'd prior to startu All breakers will be PM'd no later than March 31, 198 Long term corrective action committed to by the licensee consists of revising the FSAR to reflect the criteria which apply to the design of the existing loadshed circuits by the end of 1987. This action will be tracked as an Open Item (50-255/86035-151).

This unresolved item is close * Unresolved Item 50-255/86029-06: Weaknesses were identified regarding the updating of controlled documents following either the completion of plant modifications or the revision of higher tier document Sixteen specific examples were identified including failure to update the Q-List, failure to update the AMMS Data Base, failure to update drawings and schematics, and failure to update a surveillance basis documents. This problem had been identified previously by Region III and corrective actions are being separately tracked. This item is, therefore, being administrative 1y close * Unresolved Item 50-255/86029-07: Three of eight safety evaluations performed pursuant to 10 CFR 50.59 reviewed by the SSFI Team were inadequate. Specifically, the evaluation for removal of a HPSI cold leg injection valve motor operator failed to address line break spillage; the evaluation for a modification changing the method of control of air operated valve stroke times failed to address new failure modes or changes in system reliability and was based in part on design intent rather than final design; and the evaluation for removal of the AFW pump suction strainers failed to address the original reason for installing the strainer The licensee's general response to this item referenced their Administrative Procedure 3.07 entitled " Safety Evaluations."

The inspection team reviewed this procedure to determine whether it should reasonably assure compliance with 10 CFR 50.59, " Changes, Tests, and Experiments," and whether, if properly implemented, it should have prevented the problems identified by the SSFI tea The licensee's procedure requires completion of a four section form (N0DS Form 3104) to determine if an unreviewed safety question exists, and, whether or not an unreviewed safety question exits, if NRC notification of a proposed change, test, or experiment is require Additional guidance on form completion is contained in attachments to the procedur Section I of the form, "10 CFR 50.59 Determination," requires the preparer to provide yes/no answers to four questions in an effort at determining whether the proposed change, test, or experiment is subject to 10 CFR 50.59 requirements. The four questions are:

(1) Is the item safety-related or can it affect another safety-related item? (2) Is the item changed from its description in the FSAR?

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(3) Does the item involve a test or experiment not previously described in the FSAR? and (4) Does the item require a change to Technical Specifications? The procedure specifies that a positive answer to any of the four questions requires that an

evaluation be performed to determine if an unreviewed safety question exists. It further states that a negative answer to all four questions indicates that the item does not require further evaluation for an unreviewed safety question.

The additional guidance contained in the procedure attachments regarding Question 1 focuses almost exclusively on safety-related items, referencing the preparer to the FSAR, Technical Specifications, the Q-List, and procedure matrices to define items that are safety related. The guidance goes on to state that in some cases, a safety-related item may be affected by an activity that does-not appear to affect nuclear safety and that such activities should be considered safety-related.

While not technically incorrect, Question 1 and the associated guidance could be misleadin The requirements of 10 CFR 50.59 are not restricted to safety-related item By focusing attention almost exclusively on safety-related items, the preparer could be misled regarding the scope of items which should be considered for 50.59 review. The specific guidance relative to procedures is particularly prone to misinterpretation as it states . . . "An activity shall be considered safety-related if it affects a procedure identified as safety-related. . ."

This weakness is somewhat offset by the guidance provided regarding Question 2. This guidance identifies the need to evaluate anything which would change a description in the FSAR and explicitly identifies non safety-related items as candidates for review. However, the guidance fails to direct the preparer to review outstanding FSAR changes in the process of determining whether the activity affects FSAR descriptions.

With regard to Question 3, the guidance states that further evaluation is only necessary for tests and experiments not previously evaluated in the FSAR if they result in an unusual or abnormal mode of operation.

This guidance is incomplete ir that it fails to address whether, during the course of a test o, experiment, a condition could arise impacting plant safety in a manner not previously evaluated. The guidance should be eliminated and all tests and experiments not described in the FSAR should be the subject of a detailed review to determine if they involve an unreviewed safety question. Also, as was the case with the guidance for Question 2, the preparer should be directed to review outstanding FSAR changes in the process of determining whether a given test or experiment is described in the FSAR.

Section II of Form 3104 requires the preparer of the safety evaluation to provide answers to three questions for issues resulting in one or more positive responses in Section I. The three quastions are:

(1) Is the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report increased? (2) Is the

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possibility of an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report created? and (3) Is the margin of safety as defined in the basis for any Technical Specification reduced? Further, the procedure requires that a basis-for each answer be provided. Additional guidance on these questions is contained in Attachment 4 to the procedur With regard to Question 1, there is'a subtle, but important difference between the wording of the question and the corresponding criterion for an unreviewed safety question contained in 10 CFR 50.5 Specifically,10 CFR 50.59 states that an unreviewed safety question is deemed to exist if the change, test, or experiment may increase the probability of occurrence or consequences of an accident or malfunction, not if such an increase is explicitly identifie This distinction becomes important when one evaluates failure modes and reliability, for exampl The guidance provided on Question 1 simply serves to reinforce the distinction. The two examples cited in the guidance could be somewhat misleadin In the first example, the conclusion is that replacement of a short pipe with a long pipe does not constitute an unreviewed safety question provided that applicable design and installation requirements are adhered to because the probability of failure was based on installation of pipe in accordance with design criteria, not on the probability of pipe wall failure per foot of pip This example fails to consider the consequences of pipe failure and the susceptibility of failure due to external forces (e.g. missiles). In the second example, it is concluded that a reduction in flow capability of one pump in a two pump system is not an unreviewed safety question provided that the reduced flow still satisfies FSAR requirements. This example fails to consider whether the method of flow reduction affects pump / system reliability, that pump and system performance maybe a function of more than pump flow alone (e.g. discharge pressure, NPSH), and the synergistic effects that the change may have on othec system components (e.g., flow balancing).

With regard to Question 2, the same type of difference exists between the wording of the question and the criterion of

, 10 CFR 50.59. Again, the guidance for this question reinforces

! this differenc Question 3 is an accurate restatement of the associated criterion contained in 10 CFR 50.59. The guidance for this question is acceptabl Section III of Form 3104 determines the appropriate method of I notifying the NRC of the results of the evaluation. The form i and procedure are judged adequate for this purpose; however, it is l noted that neither the procedure nor the form specify distribution

of the evaluation itself, whether or not tha evaluation determines

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that an unreviewed safety question exists. As a minimum, a completed form distribution should be specified to ensure that documentation packages are complete and appropriate internal and external notifications are made.

Section IV of the Form 3104 documents the evaluator and the reviewer.

The procedure specified no qualification requirements for those preparing a safety evaluation. This is viewed as a significant weakness. The reviewer is required to be a designated or alternate Plant Review Committee Member. This is acceptable. Responsibilities of the preparer and reviewer are clearly and appropriately specified in the procedure. While not specified in Procedure 3.07, the Nuclear Safety Board is required by Technical Specification 6.5.2.8.1.f to review all safety evaluations performed pursuant to 10 CFR 50.59 to verify that the associated changes, tests, or experiments did not involve an unreviewed safety question.

In summary, the following conclusions were recched regarding the adequacy of the licensee's procedure for implementing the requirements of 10 CFR 50.59: The procedure and associated guidance are somewhat misleading in that inadequate emphasis is placed on the potential for non safety related changes to create unreviewed safety questions.

i The procedure fails to direct the evaluator to review outstanding FSAR changes which may impact t.ie validity of the safety evaluation.

iii. The procedure establishes an inadequate threshold for defining unreviewed safety questions regarding the probability of occurrence or consequences of an accident or malfunction and/or the possibility for creating an accident or malfunction of a type not previously evaluated.

i The procedure does not specify distribution of safety evaluations, creating the potential that appropriate internal and external notifications may not be made. The procedure fails to specify minimum qualification requirements for personnel performing safety evaluations. This is viewed as a significant weakness.

The inspection team reviewed the three inadequate safety evaluations identified by the SSFI Team to determine whether proper implementation of Procedure 3.07 would have prevented their occurrence. The first evaluation involved the failure to address line break spillage on a modification which removed a HPSI cold leg injection valve operator and blocked the valve open. Given that Procedure 3.07 directs the evaluator to review appropriate FSAR sections, this is viewed as an implementation problem rather than a procedural problem. The fact that the problem was licensee identified and corrected supports this conclusio _

Two deficiencies were identified with the second evaluation judged to be inadequate. This evaluation related to the method of control of air operated valve stroke times. The first of these involved a failure to consider the potential for new failure modes or changes in overall system reliability introduced by the modificatio The second deficiency involved an assumption that seismic analyses would be performed as part of the modification design process. These analyses apparently were not performed.

While it is not clear whether the first deficiency was the result of procedural weaknesses or implementation error, it is an example of the type of problem that could result from Item iii abov It is thus concluded that the existing Procedure 3.07 would have prevented this error. Regarding the second deficiency, Procedure 3.07 implicitly assumes that the configuration and/or process analyzed accurately reflects the final change as implemented. No post implementation verification of as implemented vs as intended condition is required.

At the close of the inspection period, the licensee was in the process of completing the seismic analysis. The reliability issue had been adequately addresse The seismic issue and a new SE will be completed prior to startup.

The third evaluation failed to address why AFW pump suction strainers were installed as part of a modification to remove them. Given that Procedure 3.07 directs the evaluator to review appropriate FSAR sections, this is viewed as an implementation problem rather than a procedural problem. Subsequent review and analysis by the licensee determined that the FSAR contains no design basis for the strainers. A new safety evaluation was performed and concluded that no unreviewed safety question was created by this modification.

In an effort to determine what procedural mechanisms are in place to require initiation of a 10 CFR 50.59 review of a proposed change, test, or experiment the inspection team reviewed the following plant administrative procedures:

9.02 Plant Modifications - Major, Revision 3, 2/11/85 9.03 Plant Modifications - Minor, Revision 3, 10/2/86 9.04 Equipment Specification and Minor Field Changes, Revision 2, 2/11/85 9.05 Modification Procedures and Construction Work Package, Revision 2, 2/11/85 9.31 Jumper, Link and Bypass, Revision 1, 10/13/86 9.34 Special Test Procedure, Revision 0, 9/2/86 5.05 Setpoint Change 10.41 Procedure on Procedures, Revision 8, 6/27/86 Each of these procedures requires the preparation of a formal Safety Evaluation for the identified subject; however, a number of discrepancies were noted. Procedure 9.02 requires that a Safety Evaluation (SE) be performed for all major modifications based on

their conceptual designs, and that the detailed design and all changes thereto be reviewed for their impact on the safety evaluatio It further requires SE's for implementing procedures, testing procedures, and modification scope change Non-Conformance Reports outstanding upon modification completion and testing are required to be reviewed and evaluated against the original SE. However, this procedure does not require that the as-installed modification be evaluated against the conceptual design or the original SE. This is viewed as a significant weakness.

Procedure 9.03 requires an SE be prepared for minor modifications based on the conceptual design and that the detailed design package be reviewed to to ensure that the SE has not been affected by the detailed design. It also requires that changes to the design be reviewed against the SE for Q-Listed modifications. It fails to require a similar review for non-Q-Listed modifications nor does it require a SE for modification installation procedure These items are viewed as significant weaknesses.

It was also noted for both Procedures 9.02 and 9.03 that it is the responsible engineer who reviews changes to the design of a modification for impact on the original safety evaluatio No requirement exists to verify the validity of the conclusions of that review in those cases where no impact on the Safety Evaluation is identified.

During review of Procedure 10.41, it was also noted that no SE is required for cancellation of a procedure; rather the responsible department head must only determine that the justification for cancellation is adequate, N0DS required actions are covered elsewhere, and regulatory requirements are covered elsewher As procedure cancellation is simply a form of procedure change and the criteria for cancellation contained in Procedure 10.41 do not ensure that an unreviewed safety question is not created, the procedure is inadequate.

Regarding the procedures reviewed, it can be concluded that while all require the performance of SE's on the general subject of the procedure, a number of weaknesses and inadequacies exist. Most notable in this regard are failure to ensure that installed modifications do not violate the corresponding SE, and failure to require SE's for certain procedure changes. These inadequacies constitute a violation (255/86035-152). The response to this violation should speak not only to the administrative weaknesses identified, but also to the manner in which technical expertise will be b.ought to bear to ensure the quality of changes and their associated safety evaluations.

To further evaluate the licensee's overall program for implementation of 10 CFR 50.59, the inspection team reviewed the licensee's training program to determine the extent and quality of the training offered.

The only documentation the licensee could provide of recent training

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on 10 CFR 50.59 was a packet of slides used in presentations made to certain members of the plant staff by a member of the licensee's Licensing Department on September 5 and 17, 1985 and an attendance list. A total of 96 people attended the training including representatives from all major onsite organizations from the working level through senior management. However, when the list of attendees was compared to the current list of permanent and alternate PRC members, it was discovered that the current PRC Chairman had not received the training, nor had 17 of 21 Shift Supervisors or Shift Engineers designated as alternate PRC members, nor four of 24 other plant staff members designated as alternate PRC member A review of the slides used for the September 1985 presentations found them generally adequate with the following exceptions: While directing those performing evaluations to consult the updated FSAR when evaluating changes, tests, or experiments the slides failed to address outstanding changes to the FSA i The slides identify qualified technical reviewers and system engineers as the desigrated reviewers of 50.59 evaluation This is contrary to Procedure 3.07 which requires that the reviewer be a designated PRC member or alternate PRC membe Further, in discussions with the licensee's Training Department and Engineering and Maintenance Department, it was determined that not only was no periodic training performed on Safety Evaluators, but that the Safety Evaluations had not been identified as a performance task during the position analyses performed in developing a performance based training program. Completion of upgraded training will be tracked as an Open Item (255/86035-153).

This unresolved item is close * Unresolved Item 50-255/86029-08: Until mid-1986, the licensee had no viable preventive maintenance program to lubricate M0V' Additionally, four environmentally qualified M0V's were lubricated with an unqualified lubrican This item is addressed in detail in IE Inspection Report No. 50-255/86031. This report concludes that actions taken were adequate and this unresolved item is considered closed. Potential enforcement on this issue will be tracked via Unresolved Item 50-255/86032-0 * Unresolved Item 50-255/86029-09: Weaknesses were discovered with the licensee's control of M0V torque switch and limit switch setpoint In particular, instances were noted where torque switch settings either were not recorded following valve maintenance or the values recorded were outside the limits prescribed on the valve data sheets, torque settings did not appear to be based on design differential pressures, and procedural guidance for setting limit switches was inadequat l

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This item is addressed in IE Inspection Report No. 50-255/8603 This report concludes that interim actions taken are adequate to support plant operation until the next refueling outage. Previously made commitments for that time were also judged adequate. This item is considered closed. Remaining actions will be tracked via Inspection Report No. 50-255/86031.

• Unresolved Item 50-255/86029-10: There is a general weakness in ensuring that oilers in the air lines to air valves are properly maintained as evidenced by empty oilers for valves CV-3027 and 3071, dirty oil in the oiler for valve CV-3036, and a leak in the oiler for valve CV-3029. These deficiencies did not impact valve operability as evidenced by continuing successful valve stroke testin During the current outage the licensee completed work orders on all engineered safety system oilers, cleaning and refilling them and checking and repairing any leaks. Action had been taken to initiate periodic oiler inspections / maintenance. Completion of this action will be tracked as an Open Item (50-255/86035-154).

This unresolved item is considered closed.

• Unresolved Item 50-255/86029-11: Some weaknesses were noted in maintenance and calibration activities associated with safety-related switchgear and HPSI instrumentation. Specifically, Maintenance Procedures MSE-E-10, SPE-E-6, and SPE-E-4 did not follow certain vendor recommendations. Surveillance Test RI-18, "SIRW Tank Temperature Indicator Calibration Procedure" used uncalibrated measuring and test equipment in Steps 5.7 and 5.9 to make quantitative measurement With regard to the specific deficiencies identified by the SSFI Team, the licensee has taken the following corrective actions: Maintenance Procedure MSE-E-10 allowed starter / breaker contacts to be dressed with a file contrary to vendor recommendation This procedure has been changed to use Scotch Brite or emery cloth to clean and buff contacts under normal circumstance Use of a file is still permitted to remove burrs, but if filing occurs an evaluation of the amount of silver remaining on the contacts is required to establish whether the contacts can be used as is, need to be resilvered, or need to be replace This evaluation had been performed previously as " skill of the craft," but has now been formalized. This is acceptabl i Maintenance Procedure SPE-E-6 specified the use of Molycoat as a lubricant on ITE 480 volt circuit breakers. The vendor's manual specified Anderol 757 as the appropriate lubrican Licensee evaluations showed the two lubricants to he functionally equivalent; however, the procedure has been revised to require the use of Anderol 75 _ ___ ____ ______________________ ___

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I fii. Maintenance Procedure SPE-E-4 for 4160/2400 volt switchgear specifies in Item 4 of the General Adjustment Sheet that horizontal alignment be approximately 0.02 inches and breaker open position adjustment be 3 11/16 inches minimum. The vendor manual sets values these values at no greater than 0.02 inches and 3 11/16 inches i 1/8 inch respectively. The licensee has agreed to contact the vendor and determine if their specifications are appropriat This will be tracked as an Open Item (50-255/86035-155). No switchgear problems have been identified which are attributable to this proble i Uncalibrated measuring and test equipment (M&TE) is used during the performance of Steps 5.7 and 5.9 of Surveillance Test RI-18,

"SIRW Tank Temperature Indication Calibration Procedures." The licensee reviewed the equipment and procedure and concluded that this is appropriate. The inspector reviewed the subject procedure and equipment and determined that the uncalibrated M&TE called out in the procedure was used only to qualitatively check restored circuit continuity, the Wheatstone Bridge used to check the temperature element was both calibrated and controlled, and that the other equipment was on a five year calibration periodicit Based on this and the fact that the subject M&TE is not used to satisfy quantitative acceptance criteria in RI-18 it is concluded that no further action is required of the license During the followup on this unresolved item, the inspection team reviewed licensee administrative procedures in an effort to determine when maintenance procedures are required to be prepared and whether vendor information is required to be considered. The fol bwing procedures were reviewad:

ADMIN 5.00 Engineering and Maintenance Department Organization and Responsibilities, Revision 3, 12/1/86 ADMIN 5.01 Processing Work Requests / Work Orders, Revision 7, 10/30/86 ADMIN 5.03 Preventative Maintenance Progr .,

Revision 3, 8/27/85 ADMIN 5.14 Periodic and Predetermined Activity Control, Revision 0, 10/24/86 ADMIN 10.41 Procedure on Procedures, Revision 8, 6/27/86 The criteria for when a maintenance procedure is required are contained in Attachment A to Admin 5.01 which states that maintenance which can affect the performance of Q-Listed equipment, structures, or systems must be properly preplanned and performed in accordance with written procedures, instructions, or drawings appropriate to the circumstances. This includes maintenance of non-Q-Listed equipment which affects surrounding Q-Listed equipment 66 _ _ _ - _ _ _ _ _

or which can have significant affect on plant reliability. The last page of the attachment consists of a checklist for documents included in a work package. This checklist identifies vendor prints / manuals, procedures, and temporary procedures as candidates for inclusio Imposition of these criteria is reinforced by review of Work Requests /

Work Order packages by the respective Maintenance Supervisor. Further, Admin 5.0 charges Engineering and Maintenance Department personnel from the Department Manager through the planners and systems engineers with the responsibility of ensuring that procedures are adequate and receive periodic reviews. Admin 10.41 also requires new working procedures to be reviewed by a technically competent individual for technical accuracy and to include a reference section listing those documents establishing procedural requirement With regard to incorporation of vendor information in maintenance procedures, Admin 5.0 specifically requires the Engineering and Maintenance Manager to ensure that department practices are consistent with outside vendor requirements and the Materials Technician with reviewing material and equipment vendor service bulletins to determine functional and/or maintenance problems which {

may occur if not corrected. Admin 5.03 requires the Engineering and Maintenance Superintendent to assure that PM activities are initiated or revised based on equipment history and vendor's recommendation It further states that to assure the appropriateness of PMs, vendor's recommendations modified by actual plant experience and applicable codes and regulations shall be considere It is concluded that the existing licensee administrative procedures adequately define when maintenance procedures are required and the content of maintenance procedure One weakness was noted during the review of the referenced procedures, namely that Admin 5.01, which establishes the requirement to have maintenance procedures, does not reference Admin 10.41 which specifies the content and format for such procedures either in its reference section or its tex It is concluded that the problems identified with maintenance procedures in this unresolved item can be attributed to implementation weaknesses rather than procedural inadequacies; however, the team noted that the adoption of a procedure preparation checklist identifying both technical and administrative references, and requiring a brief written justification for any deviations from those references may aid in preventing problems of the type identified in the future. This unresolved item is close * Unresolved Item 50-255/86029-12: A review of HPSI pump inservice test results for 1986 revealed that the pumps may not be developing the minimum recirculation flow required by Technical Specification Also, it was determined that the licensee had not take steps to demonstrate the adequacy of the recirculation flow when confronted with the evidence in 1984 and again in 1986 that recirculation flow was not sufficien In response to the technical concerns raised by this issue, the licensee performed two special tests of HPSI pump performance, including recirculation flow capability, using Test Procedure T-220,

"HPSI Pump Operability, Performance and Recirculation Line Test and HLI Check Valve Test." The inspection team reviewed this test for methodology and results and found them acceptabl With respect to methodology for recirculation flow, the test involved establishing flow to the SIRW tank through the common recirculation line and flow indicator using a LPSI pump. This yielded approximately

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200 gpm flow which is mid-range on the flow indicator. The HPSI pump was then started in recirculation and the change in recirculation flow measure This test was performed twice for each pump and yielded recirculation flows between 30 and 35 gpm for each pump which satisfies the minimum specification of 30 gpm per pump. This satisfies the technical concern raised by this issue and the unresolved item is close The licensee has committed to modify the HPSI pump miniflow system to allow enhanced pump surveillance testing during the next refueling outage and to improve their testing of the HPSI pumps through a combination of better instrumentation and enhanced procedure These actions will be tracked as Open Items (50-255/86035-156; 50-255/86035-157).

The inspection team also reviewed Emergency Operating Procedure E0P-4.0," Loss of Coolant Accident Recovery." This procedure directs the operators to verify HPSI pump total flow in accordance with a pressurizer pressure vs HPSI flow curve in Attachment 2 to the procedure. After HPSI suction shifts to the containment sump, the operators are required to verify that each HPSI pump has a flow of 30 gallons per minute (GPM). If any operating pump is delivering less than 30 gpm, the procedure directs the operator to secure one charging pump at a time until 30 gpm is achieved. If that is not acceptable, then the HPSI pump with the lowest flow is stopped. This provides adequate assurance that minimum HPSI flows will be maintaine With regard to its lack of timely response to earlier indications of potential recirculation flow problems, the licensee reviewed the referenced test data as well as other test data. From this review, it determined that data was obtained and reviewed by different individuals of varying experience levels such that a historical trend perspective was not maintained. Further, it was noted that test results were significantly influenced by the exact configuration i

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or which can have significant affect on plant reliabilit The last page of the attachment consists of a checklist for documents included in a work package. This checklist identifies vendor prints / manuals, procedures, and temporary procedures as candidates for inclusio Imposition of these criteria is reinforced by review of Work Requests /

Work Order packages by the respective Maintenance Supervisor. Further, Admin 5.0 charges Engineering and Maintenance 9epartment personnel from the Department Manager through the planners and systems engineers with the responsibility of ensuring that procedures are adequate and receive periodic reviews. Admin 10.41 also requires new working procedures to be reviewed by a technically competent individual for technical accuracy and to include a reference section listing those documents establishing procedural requirement With regard to incorporation of vendor information in maintenance procedures, Admin 5.0 specifically requires the Engineering and Maintenance Manager to ensure that department practices are consistent with outside vendor requirements and the Materials Technician with reviewing material and equipment vendor service bulletins to determine functional and/or maintenance problems which may occur if not corrected. Admin 5.03 requires the Engineering and Maintenance Superintendent to assure that PM activities are initiated or revised based on equipment history and vendor's recommendation It further states that to assure the appropriateness of PMs, vendor's recommendations modified by actual plant experience and applicable codes and regulations shall be considere It is concluded that the existing licensee administrative procedures adequately define when maintenance procedures are required and the content of maintenance procedure One weakness was noted during the review of the referenced procedures, namely that Admin 5.01, which establishes the requirement to have maintenance procedures, does not reference Admin 10.41 which specifies the content and format for such procedures either in its reference section or its tex It is concluded that the problems identified with maintenance procedures in this unresolved item can be attributed to implementation weaknesses rather than procedural inadequacies; however, the team noted that the adoption of a procedure preparation checklist identifying both technical and administrative references, and requiring a brief written justification for any deviations from those references may aid in preventing problems of the type identified in the future. This unresolved item is closed.

• Unresolved Item 50-255/86029-12: A review of HPSI pump inservice test results for 1986 revealed that the pumps may not be developing the minimum recirculation flow required by Technical Specification Also, it was determined that the licensee had not take steps to demonstrate the adequacy of the recirculation flow when confronted with the evidence in 1984 and again in 1986 that recirculation flow was not sufficien In response to the technical concerns raised by this issue, the licensee performed two special-tests of HPSI pump performance, including recirculation flow capability, using Test Procedure T-220,

"HPSI Pump Operability, Performance and Recirculation Line Test and HLI Check Valve Test." The inspection team reviewed this test for methodology and results and found them acceptable.

With respect to methodology for recirculation flow, the test involved establishing flow to the SIRW tank through the common recirculation line and flow indicator using a LPSI pump. This yielded approximately 200 gpm flow which is mid-range on the flow indicator. The HPSI pump was then started in recirculation and the change in recirculation flow measured.

This test was performed twice for each pump and yielded recirculation flows between 30 and 35 gpm for each pump which satisfies the minimum specification of 30 gpm per pump. This satisfies the technical concern raised by this issue and the unresolved item is closed.

The licensee has committed to modify the HPSI pump miniflow system to allow enhanced pump surveillance testing during the next refueling outage and to improve their testing of the HPSI pumps through a combination of better instrumentation and enhanced procedures.

These actions will be tracked as Open Items (50-255/86035-156; 50-255/86035-157).

The inspection team also reviewed Emergency Operating Procedure E0P-4.0," Loss of Coolant Accident Recovery." This procedure directs the operators to verify HPSI pump total flow in accordance with a pressurizer pressure vs HPSI flow curve in Attachment 2 to the procedure. After HPSI suction shifts to the containment sump, the operators are required to verify that each HPSI pump has a flow of 30 gallons per minute (GPM). If any operating pump is delivering less than 30 gpm, the procedure directs the operator to secure one charging pump at a time until 30 gpm is achieved. If that is not acceptable, then the HPSI pump with the lowest flow is stopped. This provides adequate assurance that minimum HPSI flows will be maintained.

With regard to its lack of timely response to earlier indications of potential recirculation flow problems, the licensee reviewed the referenced test data as well as other test data. From this review, it determined that data was obtained and reviewed by different individuals of varying experience levels such that a historical trend perspective was not maintained. Further, it was noted that test results were significantly influenced by the exact configuration

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of temporary test instrumentation. Most notable in this regard was line induced gage vibration. Auxiliary operators obtaining the data would sometimes take median gage readouts and on other occasions take minimum value This problem has been resolved by requiring direct system engineer participation in the tes * Unresolved Item 50-255/86029-13: Periodic testing of some isolation check valves between safety-related and non safety-related air supplies to safety-related valves was found to be inadecuat Examples include the check valves between Instrument anc HP Air for valves CV-3223, 3224, 3212, and 3213; the check valves between Instrument Air and the safety-related air accumulators for Component Cooling Water Containment Isolation Valves CV-0911 and 0940; and the check valves between Instrument Air and the safety-related nitrogen bottles for air to the T rings of containment isolation butterfly Valves CV-1813 and 181 With regard to the interfacing check valves for valves CV-3223, 3224, 3212, and 3213, the licensee performed test T-205, "High Pressure Air System Performance Verification Test" in November 1986. This test demonstrated that all of the subject check valves were operable except for the check valve in the low pressure air supply line to CV-3213. This check valve leaked at a rate of standard cubic feet per minute and was replaced. Retest showed the valve still to be leaking. At the close of the inspection, repair efforts were in progress. In addition, the licensee committed to periodic testing of these valves. This will be tracked as an Open Item which must be closed prior to startup following the next refueling outage (50-255/86035-158).

With regard to the check valves for the accumulators on CV-0911 and 0940, the licensee agreed to replace them with new valves which had been satisfactorily leak tested prior to installation. Post installation functional testing will also be performed. Prior to startup from the next refueling outage, the licensee will modify the system configuration to allow periodic testing of the check valve This will be tracked as an Open Item (50-255/86035-159).

With regard to the check valves associated with Valves CV-1813 and 1814, the team determined that these valves no longer contain inflatable seals. This item is considered close * Unresolved Item 50-255/86029-14: Apparent weaknesses were identified in surveillance testing of safety-related batterie Specifically, the licensee was performing an equalizing charge prior to aerforming the 18 month service test; battery service test disc 1arge currents were not corrected for minimum expected l battery temperature; no battery room and cell temperature criterion or action statement was included in the surveillance procedure; and specific gravity readings were not corrected for electrolyte level.

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In response to this item, the licensee contacted the battery vendor and IEEE to determine the appropriate actions to be taken. Based on the information received, the licensee changed their battery surveillance procedure to delete the equalizing charge before performing the refueling service test; however, in accordance with IEEE 450 it will not perform temperature corrections to the load profile discharge rate. Battery performance test FE-5 is performed every five years to demonstrate that the batteries have retained sufficient capacity to supply post accident loads. The results of the test are temperature corrected to 77 F based on manufacturer nameplate dat Minimum battery service temperature is 70 F; however, the licensee's 77 F acceptance criteria were chosen to ensure satisfactory performance at 70 Regarding battery room and cell temperatures, the licensee agreed to add these readings to the auxiliary operators' rounds sheets with a specified minimum value to ensure that action could be taken before temperature fell below 70 F and the batteries had to be declared inoperable. This will be tracked as an Open Item (50-255/86035-160).

With respect to correcting electrolyte specific gravity for electrolyte level, the licensee determined that as long as electrolyte level is maintained between the high and low lines on the cells and specific gravity is within the specified range, the batteries full rated amp-hour capacity is not inhibite Finally, the licensee performed an engineering analysis of current and previous battery surveillance data and has concluded that battery operability had not been compromise This item is considered close * Unresolved Item 50-255/86029-15: Review of normal operating and emergency procedures for the HPSI system and other related procedures identified several weaknesse Specifically, plaques on the control boards contained conflicting information to that of E0P 8.1 regarding operations of SIRW Tank recirculation valves following a LOCA; the 0-400 gpm gage for HPSI pump recirculation flow is of too wide a range to adequately characterize the expected 30-60 gpm recirculation flow required to be verified in E0P 8.1; E0P 8.1 directs the operators to stop the containment spray pumps based solely on containment

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pressure and does not consider the potential need for iodine removal;

Alarm Response Procedure No. 7 failed to direct the operators to shut CV-1211, instrument air header containment isolation valve on a low pressure alarm received post-LOCA; and E0P 2.1 directs the operators to shed the diesel generator control and start circuits on a loss of all immediately available AC power. The issue of the misleading plaques is viewed as significant insofar as it could have adversely affected emergency response. As such, it is considered a

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violation (255/86035-162). Your response to this violation should detail actions you will take to ensure that plaques and other local operator aids are and remain consistent with approved operating and emergency procedure Each of these weaknesses and licensee responses there to were reviewed by the inspection team with the following results: The misleading placard was replace In addition, the licensee took actions to ensure the correctness of other placards providing directions to their operators. In reviewing this matter the team determined that placards and labels which provided status or labelling information were not checked as part of this effor The licensee agreed to review these items, i Following the SSFI, the licensee im)lemented new E0P' E0P 4.0, " Loss of Coolant Accident Recovery" was reviewed and it was determined to contain adequate precautions regarding minimum HPSI flows and requires that the need for continued iodine removal capability be assessed prior to securing containment spra iii. With regard to loss of instrument air, the inspection team reviewed off-normal Procedure ONP 7.1 and determined that it requires operators to isolate instrument air headers, starting with the containment header and valve CV-1211, in an effort to isolate the fault causing the air los i The inspection team reviewed ONP 2.2, " Loss of All Immediately Available AC Power." This procedure replaced E0P 2.1. This procedure directs the shedding of DC loads from the batteries as necessary to reduce the load on each battery to less than 150 amp The last loads to be shed are the diesel generator control, start, and field flash circuit In addition, Step 4.4 of the procedure directs that the diesel generator loads be restored when it is determined that diesel generators can be returned to servic This procedure acceptably resolved SSFI team concerns regarding the diesel generators. A loss of immediately available AC power only occurs if neither diesel generator starts when normal onsite and offsite AC power is lost. Failure of the diesels to start would require an investigation as to cause. During this investigation, battery life is prolonged by shedding the diesel generator DC load This unresolved item is considered closed.

• Open Item 50-255/86029-01: It was the SSFI team's understanding that the selection of thermal overload relay heaters which produce alarms rather than trips on overload for safety-related motor

operated valves will be included as part of a plant-wide design basis assessment of electrical protection devices. The team's understanding was based on the apparent lack of design bases for the selection of particular relay heater In subsequent discussions between the restart inspection team and the licensee, it was determined that the design basis assessment alluded to was prompted by circuit coordination concerns for selective tripping during postulated fire condition As such, the licensee does not intend to include motor operated valve overload alarms in this assessment. Further, the licensee reiterated their long standing philosophy regarding lack of notor operated valve overload protection, namely that under accident conditions valve actuation demands would be maintained to motor operator failure if necessary to ensure that, to the extent possible, post-accident configurations would not be precluded by unwarranted overload trips. This item is closed; however, it is noted that the current configuration will not provide the licensee indication of developing problems during routine valve operation on testing.

• Open Item 50-255/86029-02: In 1983 the licensee conducted a post-modification test of the HPSI system to demonstrate that, for long term post-accident cooling purposes, approximately equal flows

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through hot and cold leg injection paths could be established. While the appropriate hot leg injection valve positions were identified using limit switches, no equivalent controls were established for the cold leg injection valves. Thus, upon entry into this operational condition goperator action would be required by procedure. It was the SSFI team s understanding that testing would be performed to address this proble The licensee reviewed this issue as part of their system functional evaluation and concluded that previous system testing demonstrated thatatleast220gpmcanbedeliveredthroughthehotleginjection path, and that with that flow adequate core cooling and baron mixing is assured. Thus, no further testing is planned. Review of E0P by the inspection team showed that the procedure requires that the hot leg injection valves be opened and that approximately equal flows to the hot leg and cold legs be verified. No direction is provided regardingthrott'ingthecoldleginjectionvalve However, the procedure does direct the operator to E0P 9.0, " Functional Recovery Procedure," if hot leg injection cannot be established in this manne This procedure, in turn, directs the operator to direct and maintain at least 110 gpm HPSI flow from either Train 1 or Train 2 to the pressurizer, while maintaining cold leg injection and hot leg injection. This is acceptable and this item is considered close Four violations and no deviations were identifie ________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

7. Licensee Action on Previous Inspection Findings (0 pen) Violation (255/85003-03(DRP)): Failure to follow procedure Licensee action taken to correct this violation is described in CPCo letter dated June 3, 198 The inspectors reviewed the methods used for maintaining maintenance history. The inspectors were informed that maintenance history for the past three years is maintained utilizing a computer syste Two pieces of plant equipment were selected; maintenance history was reviewed and it appeared to be acceptabl The inspectors reviewed engineering manual Procedure No. EM-20,

" Equipment Performance Monitoring and Trending," Revision 0, issued February 17, 1986. This document requires trending of both preventative and corrective maintenance and the issuing of a quarterly trend report. The quarterly trend reports had not been issued. Licensee personnel stated that due to the current plant outage, which started in May 1986, that sufficient data was not available for determining trends. This item remains open pending review of trend reports, management action to minimize procedural violations and the review of jumper, link and bypass control, (Closed) Violation (255/85003-04(DRP)): Instructions provided for maintenance orders are not adequate. Licensee action taken to correct the violation is described in CPCo letter dated June 3, 198 Two of the maintenance orders were included in this violation because design drawings for the required work were not listed. The above referenced response stated that the required drawings can be identified from the equipment number which is included on the maintenance order. The inspectors selected one of the noted maintenance orders and had license personnel determine the required drawings utilizing the equipment number and the computerized Equipment Data Base. No problems were noted and the inspectors consider this to be an acceptable method for obtaining the necessary design documen The other maintenance order (85-CVC-0016) listed in the violation indicated that inadequate instructions were provided for the replacement of the charging pump discharge accumulator bladde The inspectors reviewed maintenance Procedure CVC-M-9, " Charging Pump Suction and Discharge Accumulator Pressure Check," Revision 2, issued November 19, 1985 and noted that Sections 5.5 and 5.6 of this procedure now provide acceptable instructions for the removal and installation of the charging pump discharge accumulator bladde (Closed) Open Item (255/85003-14(DRP)): Analysis of door closure problems. This item concerned problems noted by the licensee in the improper closing of two vital area doors in the plan Four vital area doors which had not closed properly in the past were investigated; one was determined to be satisfactory; adjustments were made to the second door and it was determined

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to operate properly; the other two doors are to be replace Maintenance orders have been written for the replacement of the two doors and the doors have been ordered. Signs are in place cautioning personnel to ensure these doors close properly and site personnel have been notified of their responsibility to ensure that doors are properly closed after use, d. (Closed) Open Item (255/85033-18(DRP)): Excessive numbers of open work orders on control room equipment. The inspectors reviewed information provided by the licensee on open work orders on control room equipment and noted that the number had been reduced from 165 in 1984 to 65 in December, 1985. Currently work orders on control room equipment are reviewed to determine those that could affect control room operations. A listing of control room deficiencies (those work orders that could affect control room operations) is prepared and provided to the resident NRC inspector every two week A review of the latest report lists only 14 outstanding control room deficiencies. Of these 14, 8 are scheduled to be completed before the end of the current outage. The inspector has no further concerns in this are e. (Closed) Open Item (255/85003-19(DRP)): Administrative Procedure 2.01 " Processing of Maintenance Orders" did not require that maintenance or modifications be preplanned and performed per written procedures. Administrative Procedure 2.01 has been cancelled and has been replaced by Administrative Procedure 5.01,

" Processing Work Requests / Work Orders." The inspectors reviewed Revision 7 of Procedure 5.01 which was issued October 30, 198 This document requires adequate planning as well as work instructions in Attachment 4A which is entitled " Guidelines for Planning Work Order f. (Closed) Open Item (255/85003-20(DRP)): Inadequate corrective action was taken on two "Q-List" related audit findings. The first finding described several discrepancies between the safety related designation on the piping and instrumentation drawings (P& ids) and the component classification in the "Q-List." Administrative Procedure 4.30, "Q-List," Revision 3, issued April 14, 1986 requires that the "Q-List" be used to determine safety related component A drawing change request has been submitted to remove " class" flags from the P& id The second finding identified that superseded copies of the "g'-List" remained in the work areas and were labeled " controlled cop The inspectors reviewed a closed Deviation Report which documents that all controlled copies of the superseded "Q-List" were returned by April 4, 198 g. (0 pen) Violation (255/85003-21(DRP)): Maintenance activity problems were improperly identified in Quality Assurance audits as observations rather than findings. Action taken by the licensee to correct this violation is described in CPCo letter dated June 3, 198 This

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response indicates no action was taken other than to re-review the observations which were questioned by the NRC inspector. The re-review indicated th'e items were properly classified as observation Observations are defined by the licensee as not requiring action to determine and correct the caus In reviewing the violation, the NRC inspectors noted that one of the observations involved the use of non-safety parts in a "Q" listed instrument. This does not appear to be minor and not requiring action to correct. The inspectors reviewed Audit Report No. QT-86-10 which was an audit of Palisades maintenance conducted May 12-28, 1986. This audit lists 8 observations, several of which document procedural inadequacies or violations and should require some action to prevent recurrence. The licensee is requested to re-respond to this violation.

h. (Closed) Unresolved Item (255/85003-22(DRP)): Quality records provided no traceability of a replaced par The inspectors reviewed an RR File status sheet which was included in the M0-85-RIA-0020 file. This record documents the removal and installation of Detector No. 507 and provides the required traceabilit J i. (Closed) Open Item (255/85003-23(DRP)): Lack of control of vendor information. The inspectors reviewed Administrative Procedures No. 10.44, " Design Document Control and Distribution," Revision 3, issued October 10, 1986 and No. 10.45, " Vendor Manual Control,"

Revision 1, issued February 13, 1986. Procedure No. 10.45 requires review and approvals of vendor manuals and information; Procedure No. 10.44 provides for distribution and control after approva Both procedures provide adequate control.

j. (Closed) Open Item (255/85003-25(DRP)): No procedure exists to cover blanket maintenance work requests which are issued for routine non-safety related repetitive maintenance. The inspectors reviewed Administrative Procedure No. 5.01, " Processing Work / Requests Orders,"

Revision 7, issued October 30, 1986. Paragraph No. 6.2.2 of this procedure addresses these blanket work requests. Safety related maintenance is performed using maintenance work orders and this control is described in Paragraph 6.2.3 of this procedure.

k. (0 pen) Violation (255/85024-01(DRP)): Failure to take prompt and effective corrective actio Licensee action taken to correct this violation is described in CPCo letter dated December 27, 198 The inspectors reviewed Engineering Manual Procedure No. EM-20,

" Equipment Performance Monitoring and Trending," Revision 0, issued February 17, 1986. This document requires trending of both preventative and corrective maintenance and the issuing of a quarterly trend report. The quarterly trend reports had not been issued. Licensee personnel stated that due to the current plant outage, which started in May 1986, that sufficient data was not available for determining trends. The inspectors also noted that

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I the licensee's response to the violation failed to address management action to assure that corrective actions are taken promptly and effectively. This item remains o)en pending review of trend reports and management action which has Jeen taken to assure prompt and effective action . (Closed) Open Item (255-85024-02(DRP)): Review of open dummy purchase orders issued before June 15, 1984 for inclusion of appropriate quality requirements. The inspectors reviewed Action Item Record (AIR) No. A-PAL-85-41 which was completed January 28, 198 This AIR required the review of records to determine the open dummy purchase orders issued prior to June 15, 1984, and the writing of non-conforming material reports (NMRs) on the material included in the dummy purchase orders. The writing of the NMRs and the placing of hold tags on the material was completed by January 21, 1986. This will ensure review of these dummy purchase orders for updated quality requirements prior to us (Closed) Open Item (255/85024-03(DRP)): Maintenance personnel working in the vicinity of the fuel pool were not securing loose tools and equipment to prevent them from falling into the fuel poo The inspectors reviewed Administrative Procedure No. 4.04, " Plant Housekeeping," Revision 1 and noted that Paragraphs 8.3 and require that tools used near the fuel pool and the reactor vessel cavity be tethered to allow recover Procedures No. SOP-28, " Fuel Handling, System,"y if they Revision 6 and fal No. FHS0-2,

" Refueling Procedure," Revision 8 also contain similar requirement Work to be performed in the fuel pool or reactor cavity areas contain the statement "All tools shall be secured with a lanyard to user or a fixed object on the platform." Licensee personnel stated that this matter had been discussed with supervision and passed on to personnel assigned to work in these areas. Several signs have been erected on the refueling floor indicating that tools and loose objectsshouldbesecuredinthevicinityofthefuelpooland reactor cavit The inspectors have no further concerns in this are (Closed) Open Item (255/85024-04(DRP)): Tracking and resolution of facility changes (FCs) and specification changes (SCs). The tracking system for FCs has been in place for some time and the tracking system for SCs was recently developed. A facility change index (listing of FCs) and a specification change index (listing of SCs) are issued to specified individuals monthly. Every three months a listing of those FCs and SCs which have been operable for more than three months and are still open is distributed to the responsible superintendent. This system has resulted in a substantial reduction in the number of open FCs and should be effective in reducing the number of open SCs. The inspectors have no further concerns in this are (Closed) Violation (255/85031-01(DRS)): Failure to follow refueling procedures requiring tethering of tools and loose items when working near the refueling cavity. Licensee action taken to correct this violation is described in CPCo letter dated February 10, 198 % IL * n The inspectors performed the reviews described in item "m." The action taken by the licensee appeared to be adequate to correct the problem. The inspectors have no further concerns in this are (Closed) Open Item (255/86003-01(DRP)): Torquing requirements for battery connections were not included in service test Procedure No. RE-83A, " Service Test - Battery (ED-01)," Revision 2 with TCN-T-86-009; No. Re-83B, " Service Test - Battery (ED-02), Revision 2 with TCN-T-86-010; No. FE-5A, " Performance Test - Battery No. ED-01,"

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Revision 2 with TCN-T-86-011; and No. FE-5B, " Performance Test -

Battery No. E0-02," Revision 2 with TCN-T-86-012. All of these procedures now contain the torquing requirements for battery connections, (0 pen) Unresolved Item (255/86003-03(DRP)): Apparent lack of timely resolution of licensee chemical control concerns. The inspectors toured the plant observing chemical control and storage. Five cans of uncontrolled cleaning solvents or paints were noted during the tour. Most areas appeared to be adequately controlled. A substantial improvement appeared to have been made over previous conditions based on pictures of plant areas. The inspectors feel that continued management attention is needed in this area. This item will remain open pending a review of plant conditions related to chemical control on a subsequent inspection, (Closed) Open Item (255/84009-05): Lack of procedure for incorporating vendor information into plant activities. As discussed earlier in this report the licensee has added requirements to its administrative procedures on work orders and preventive maintenance to incorporate vendor informatio (Closed) Open Item (255/85003-24): Provide training for the maintenance department. As discussed earlier in this report the licensee has an INP0 accredited training program for I&C personnel and is implementing a, performance based training program for electrical and mechanical maintenance personne No violations or deviations were identifie . Status of Confirmatory Action Letter (CAL) Items CAL-RIII-85-15: This CAL, issued on October 30, 1985 confirmed licensee commitments to complete the following actions prior to startup from the November 1985 refueling outage:

(1) Achieve a significant overall reduction in the backlog of outstanding work order (2) Reduce the number of outstanding control room work orders that directly affect the controls used by operators during emergency situations, off-normal situations, or routine operations; results in information relied on by operators to take action being inaccurate or indeterminate; or results in an annunciated control room alarm that reflects an off-normal conditio .

(3) Develop and implement trending programs to aid in the identification and assessment'of. root causes for system and equipment malfunctions, to validate the preventive maintenance program, and to determine the need for replacement or upgrading installed equipment.

(4) Meaningful performance milestones are to be developed and a monthly progress / status report will be submitted to the NRC Region III office addressing progress with respect to Items 1-3 above.

Following the outage the licensee was to take the following actions:

(5) Augment the regular plant maintenance workforce with additional maintenance personnel and_ supervisors and submit to the NRC six months following the refueling outage a report defining the optimum work order backlog.

(6) Extend-the machinery history to include three years of data.

(7) Submit a progress report every two months on reducing the work order backlog and control room deficiencies.

As discussed in Paragraph 2a and b of this report, the licensee has reduced the total work order backlog and the backlog of control room deficiencies to a manageable level which does not represent a concern for safe and reliable plant operations. In addition, the licensee has established challenging and acceptable goals for work order backlog. These actions are responsive to Item 1 and 2 above and those portions of CAL-RIII-85-15 are considered closed.

As discussed in Paragraphs 5 and 7 of this report, the licensee has implemented an Advanced Maintenance Management System (AMMS) which contains machinery histories and allows system trending. Additionally, administrative procedures have been established requiring equipment performance trending. These procedures have yet to be fully implemented but are functional. These actions, in combination with Item 1 and 2 above the response to Items 3, 4 and 6 above and those portions of CAL-RIII-85-15 are considered closed.

Item 5 above and in CAL-RIII-85-15 required the licensee to augment maintenance department staffing and define an optimal work order backlog. As discussed above, acceptable backlog goals have been established. During the inspection the team confirmed that adequate augmentation of the maintenance staff had occurred to produce meaningful reductions in the work order backlog. In addition, during the inspection the licensee committed to maintain a maintenance staff sufficient to achieve and maintain its backlog goals. These actions are responsive to Item 5 above and the associated portions of CAL-RIII-85-15 are considered close The only item remaining open from CAL-RIII-85-15 is Item 7 which confirms a licensee commitment to submit a progress report every two months on reducing the work order backlog and control room deficiencies. This item and the CAL will remain open until the licensee has demonstrated their ability to satisfy its backlog goals for three successive months of powar operatio CAL-RIII-86-002: This CAL, issued on May 21, 1986, confirmed the following licensee commitments made in response to the circumstances surrounding the May 19, 1986 trip:

(1) The facility will be taken to cold shutdow (2) The facility will not be restarted until:

(a) A thorough investigation into the causes and implications of the May 19, 1986 reactor trip is completed; (b) A thorough investigation of plant safety systems and balance of plant systems important to safety, with regard to operability and required maintenance, is complete Following receipt of the CAL, the licensee took the plant to cold shutdown where it remained, except for a brief period of hot subcritical testing in November 1986, throughout the remainder of 1986 and this inspection. Item 1 of CAL-RIII-86-002 is close Iicensee actions in response to Item (2)(a) and (b) are discussed in Paragraphs 2 through 6 of this report. Salient aspects of those actions included the MCTF, the SFE, the Augmented Surveillance Program, response to the SSFI, and the Special Pump Test Progra These actions taken collectively resulted in the licensee achieving a thorough understanding of plant material condition, making needed repairs and enhancements to the plant to support restart, and committing to necessary long-term hardware and program improvements for continued safe and reliable plant operatio These actions were responsive to Item (2) above and CAL-RIII-86-002 is close No violations or deviations were identified.

! 9. Status of the Region III Request for Information Pursuant to l 10 CFR 50.54(f)

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l As indicated in Paragraph 2 of this report, because many of the problems

. identified by the licensee during the outage following the May 19, 1986 ( trip and the findings of the SSFI raised questions regarding facility l conformance to design bases, on November 20, 1986 Region III issued a

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request for information to the licensee pursuant to 10 CFR 50.54(f).

Specifically, the licensee was directed to evaluate and address the results of inspections, investigations, maintenance, and testing performed following the May 19 trip; the lessons learned from these

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activities; and management system, programmatic, and hardware changes made or planned as a result of these activitie The licensee responded to this request on December 1, 1986; however, because the licensee's response lacked necessary detail regarding corrective action program structure and implementation schedules and because the licensee had not adequately addressed the issue of pre and post-restart testing, on December 23, 1986 Region III issued a request for additional informatio The licensee responded to this request on January 28, 198 The information requested, major response elements, and inspections performed are presented in Attachment 3 to this repor Overall, the licensee's responses to the 50.54(f) letter and the subsequent request for additional information were judged by the inspection team to be adequate; however, three elements of that response lacked specificity and will be evaluated during future inspections. These elements are the startup testing program, the Configuration Management Program, and the training program for technical, supervisory, and managerial personnel. The startup testing program will be evaluated as part of the Operational Readiness Inspection. The Configuration Management Program and the training program will be the subject of separate special inspections. The 50.54(f) letter and request for additional information will remain open pending the satisfactory completion of these inspection No violations or deviations were identified.

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10. Conclusions As originally envisioned, the plant readiness inspection was to focus on the following three questions:

• Have known equipment / material problems been appropriately i

dispositioned?

• Has the potential for additional equipment performance problems been adequately assessed?

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• Have adequate plant demonstrations been completed or are they j appropriately planned?

In the course of answering these questions the inspection team also addressed eight programmatic issues outstanding at the time of the l

May 19, 1986 trip. These issues were:

l l * Organizational weaknesses in the maintenance department caused

inefficiencies in the processing of maintenance work orders, l thereby contributing to an excessive backlog of work.

• Personnel were not consistently entering deficiencies into the maintenance order system but were informally prioritizing items and entering those which they considered most significant.

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• Root cause determination for equipment alfunctions was not consistently performed with the result that repairs were not consistently effective and corrective actions were narrowly focused on the immediate problem with the result that similar problems on other equipment were not prevented / identifie * The Preventive Maintenance Program lacked sufficient scope and was not effectively implemente * Procedural problems existed including compliance, adequacy of instructions, and excessive use of Temporary Change Notices (TCN's).

• Design inputs to modifications and 10 CFR 50.59 reviews were not consistently adequat * There was a lack of documented training for maintenance and technical personne * Management and supervisory decisions did not consistently reflect a conservative approach to plant operation In accomplishing these objectives, the inspection team performed the following activities:

• A line item by line item review of the Material Condition Task Force report was conducted to determine if the proposed resolution for each issue was acceptable and the schedule for implementing that resolution was appropriat * Every outstanding work request and modification was reviewed to determine if closure was appropriately scheduled with regard to startup. This review considered not only the individual impact of a given item, but the integrated impact of all items on a given syste * The disposition of each of the equipment failures which occurred coincident with the May 19, 1986 trip was reviewed for adequacy and generic consideration * Limited walkdowns of operating systems were performed to assess their material condition.

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• The resolution of the SSFI findings was evaluated for adequacy and l timelines * Interviews were conducted with two operating shifts from auxiliary

operators through shift supervisors.

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l * The licensee's System Functional Evaluation was reviewed from four I perspectives. First, the methodology was reviewed. Second, five

! systems were selected and a list of system functional requirements I was independently developed and compared with the list developed by the licensee. Third, an overlapping set of five systems was

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selected and the testing identified by the licensee was evaluated for adequac Finally,thejustificationfornottestingcertain functions prior to startup or at all was reviewed for adequacy for each function where testing was not planned prior to startup.

• Licensee administrative controls for organization, processing work requests, preventive maintenance, periodic activities, modifications, preparing and controlling procedures, Q-list, safety evaluations, and corrective actions were reviewed.

• The licensee's responses to the last three SALP's, the last two confirmatory action letters, the three special maintenance inspections, the 50.54(f) letter, and the request for additional information pursuant to 10 CFR 50.54(f) were reviewed. During this process the inspection team also reviewed the licensee's Maintenance Administration Task Force Report.

Based on these efforts, the following conclusions were reached by the inspection team:

• The licensee has made necessary organizational changes to facilitate the timely processing of work requests. In the Operations Department this involved the creation of an organization to interface with the maintenance departmen This organization assigns maintenance priorities and facilitates work plannin Maintenance planning and engineering have been integrated into the maintenance department to ensure accountability and readily available engineering support. As part of the change, a System Engineering concept has been adopted whereby a single engineer is cognizant of the status of all maintenance on or changes to a given system. Additionally, the number of permanent crafts personnel assigned to the maintenance department has been increase Three facts demonstrate the effectiveness of these changes. First, the number of backlogged maintenance items dropped from approximately 2400 in December 1985 to approximately 800 now with a relatively constant rate of input to the system. Second, plant operators feel that the material condition of the power block is as good as it has ever bee Finally, plant operators now feel that they have a meaning-ful input into the work prioritization process and ready access to engineering suppor Some problems do, however, remai Most notable in this regard are three weaknesses in the planning and scheduling function which create inefficiencies in correcting deficiencies in expeditious manne The first weaknesses is an understaffed planning organizatio This situation results in a backlog of identified deficiencies whose correction is awaiting the generation of paperwor During the inspection the licensee temporarily increased staffing in this area. The second weakness is the failure on the part of schedulers to consistently take advantage of system or or equipment outages to complete all outstanding maintenance on that system or componen This necessitates taking the system / equipment out of service several

times and is particularly disconcerting to the operators. The third weakness is the incomplete Q-list. The Q-list defines which equipment is subject to stringent QA/QC requirements. If a component is not Q-listed, it must be treated a Q. This unnecessarily delays generationofpaperworkandslowsdownthejobprogress.

• While some progress has been made in establishing the proper threshold for entering deficiencies into the work request system, desired standards are not being consistently adhered to. This was indicated by the limited system walkdowns performed by the inspection team. However, none of the deficiencies were major. In discussions with the plant operators, it was clear that management had communicated appropriate expectation It was also clear that operators had yet to fully embrace those expectations. Nonetheless, toward the end of the inspection, the team noted that deficiencies were being entered into the system at a much lower threshold. It should be noted that this change in sensitivity will likely produce an upward perturbation in the work order backlog.

• The licensee currently has in place the administrative mechanisms which require that the root causes of equipment malfunctions be determined. The inspection revealed that reasonable efforts were being made in this regard. Systems Engineers are becoming more involved. However, the licensee appeared to be significantly weaker in the identifying the root causes of people problems. Two examples illustrate this poin The first involved inadequacies in 10 CFR 50.59 evaluations. The inspection team, not tne licensee, identified that no training had been given in that area since 1985 and that no periodic training was planned in that area. The second example involved a SSFI finding regarding failure to Q-list certain breakers. While the licensee did ensure that all breakers are now properly Q-listed, it did not explore why the error occurre As in the case of root cause determination for equipment failures, the licensee has in place the mechanisms to ensure that corrective action is appropriate and appropriately scoped. The computerized Advance Maintenance Management System adopted by the licensee is a powerful tool for interrogating the equipment data base to determine if similar failures have occurred before and/or if similar equipment is used elsewhere in the plant. While some improvements have been made in this regard, this system is not consistently being use In addition, the licensee has yet to implement fully an equipment trending progra Corrective actions for other than equipment failures continues to be somewhat narrowly focused. This was illustrated by the licensee's response to the SSFI Report. However, there are signs that efforts to improve in this are are having an effect. Examples include the expanded pump testing program implemented during this outage, the Augmented Surveillance Program, and the expanding preventive maintenance progra Regarding corrective actions generally, it is concluded that the licensee finally understands what is necessary and is taking the necessary first steps; however, significant effort remain * The licensee has in place the necessary administrative mechanisms to support an effective preventive maintenance (PM) program. The Periodic Plant Activity Control System computer software will effectively support the PM program. However, the PM program is still in its infancy. The licensee does appreciate the value of an extensive PM program and has a goal of a 50% PM 50% corrective maintenance mixture. One program weakness does exist, namely that definitive criteria regarding who can approve not performing a given PM have not been develope * With regard to procedures, the team noted only one instance of a failure to comply with procedures. Personnel do, based on interviews, appreciate the necessity of complying with procedure Existing procedures were found to generally contain appropriate information and criteria; however, a number of administrative procedures were found not to be not particularly user-friendl In addition, training on administrative procedures was found to be weak or nonexistent. The licensee did not perform a job and task analysis for managerial, supervisory, or technical personnel with the result that administrative knowledge requirements are not well define * Until the licensee applied extensive restrictions on the use of Temporary Change Notices (TCNs) at the very end of the inspection, the team found that the licensee was abusing this system. The problem that this created was the procedure changes were not receiving comprehensive reviews and some of these changes were clearly inadequate / inappropriate. Further evaluation by the inspection team determined that the abuse of TCN's was encouraged by the fact that virtually all of the licensee's administrative procedures and working level procedures are Q-listed. The revision process for Q-listed procedures is time consuming and burdensom Consequently, for convenience purposes, temporary rather than permanent changes to procedures were consistently pursue * Availability and accuracy of system design information remains suspect. The licensee's System Functional Evaluations was a first step in the right direction; however, the product of this evaluation is not a working document for design control purposes nor is it sufficiently scoped for that purpose. The licensee has committed to a configuration management program which, if appropriately scoped and implemented, will resolve this problem. In the interim, the licensee must remain extremely cautious regarding system modification Regarding 10 CFR 50.59 reviews, weaknesses continue to exis As discussed above, this is largely attributable to training weaknesse However, the design information weaknesses contribute to this problem.

i

• The licensee is implementing a performance based training program for maintenance personnel in accordance with INP0 guidelines. This should resolve the issue of maintenance training. The training program for technical personnel is still suspect as noted abov However, the licensee is implementing a systems training program for System Engineers. This will produce positive result * Throughout the inspection, management evidenced a consistently conservative approach to plant operations and correcting equipment deficiencies. Operations personnel expressed cautious optimism regarding this new attitud Whether attitudes have, in fact, changed can only be determined by monitoring management performance during future plant operation Overall, the inspection team concluded that the material condition of the Palisades facility should be sufficiently improved to support safe and reliable plant operations at the time of startup. The licensee has made appropriate long range commitments and established appropriate goals such that the material condition will continue to improve.

11. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 3, 4, 5, and 6.

12. Management Interview A management interview was conducted on February 13, 1987, at the conclusion of the inspection. The scope and findings of the inspection were discusse The inspectors also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietar ATTACHMENT 1 MCTF ITEMS OF CONCERN Proposed NRC Concern /

Item N Subject Resolution Action AFW-03 AFW Pumps are Pum)s to be tested Review test results not tested at lot shutdow to confirm adeguacy near the of test condition conditions where the system is expected to operate during a transient.

AFW-05 AFW won't Develop a structure No schedule for control at integrity maintenance plan implementation low flows, plan for the AFW piping was provide Operating the syste pumps in an on-off fashion adds to thermal fatigue of th AFW nozzles.

AFW-08 There is a The overvoltage trip The common power common power point was raised and supply may render supply for the performance trending the systems flow control initiated. A periodic susceptible to a valves in the inspection / calibration common mode failur discharge of program is to implemented AFW aumps P-8A by the end of the next and )-8B and refuelin for the low suction trip A number of failures have occurred recently due to overvoltage trips.

CAS-01 Instrument air System walkdowns didn't System adequacy has compressors are identify inordinate not been demonstrate under designed leakage. Before the Also, the addition and the addi- end of the next re- of loads via modi-tion of air fueling outage improved fication is not loads through preventive maintenance addresse This has modification is to be developed, a generic implications have increased baseline system per- for other air systems system demand formance test is to be and electrical

_ - ._- .- . - - - - - - - - . . - - - . _ - - - .

d

, Proposed ~ NRC Concern /

Item N Subject Resolution Action

,

such that a performed and one com- systems, particu-

-single compre- pressor is to be larly D.C. Systems ssor will not replaced with one of '

provide an higher capacity.

adequate suppl ! CVC-16 Concentrated None. The Pumps are Pump reliability /

, Boric Acid operating acceptably operability / main-Pumps need to now tainability is '

be overhauled challenged by so that old obsolete part obsolete parts New parts should

can be replaced be expeditiously

! with new upgraded procured.

,

parts.

.

CVC-18 Failures of th The valve will be The resolution fails letdown heat rebuilt following to address why the j exchanger inlet CVC testin valve is repeatedly relief valve to challenged during F reseat following plant startup, a multiple operations 1 during startu ,

.,

~

ESS-06 SIRW tank outlet Packingadjusted Quarterly visual valves have a and leaks stoppe inspections should a history of packing Before the end of be implemented

>

leak the next refueling immediately, outage quarterly i

,

. visual inspections '

for leakage will be

. initiated.

i ESS-16 HPSI Pump seal None The leakage should I leakage leads to be captured to pre-a contamination vent unnecessary problem, contaminatio '

ESS-24 Containment spray The valves will be The impact of the i valves leak through repaired or repla:ed valves leakage on requiring manual prior to startup from multiple ESS systems

! isolation of LPSI the next refueling out- suggests repair or and Containment ag replacement this

,

Spray Pumps during outag monthly surveillanc !

t i

i Attachment 1

,

Page 2

--- - . . _ . . - . - - . - - - - ...-- - - _, Proposed NRC Concern /

Item N Subject Resolution Action MIS-01 Control Room Chart Prior to startup all No effort such as Reorders are high recorders are to be increased preven-maintenance items, made operabl By the tive maintenance is end of the next re- suggested to enhance fueling outage a list reliability until of recorders to be replacement can be replaced will be effecte develope Recorders will be replaced as part of the five year pla RIA-01 Frequent failure As part of the five This action does of the Stack Gas year plant the sensing not address Flow Recorder due lines will be modified immediate problems to condensation / by adding drains or now that cold freezing of flow traps / heat tracing or weather has set i transmitter eliminating low points sensing line These items were discussed with the licensee with the following results:

MCTF Observation N Resolution ESS-16 Excessive leakage of HPSI seals leading to a general contamination problem was resolved by implementing vendor recommended modifications to the seals during the outage following the May 19 tri This modification eliminated the lea < age. This resolution is acceptabl CVC-16 Discussions with the system engineer indicated that both pumps are operating properly and an adequate sup)1y of new spare parts is availabl T11s resolution is acceptabl CVC-18 The root cause of this )roblem was malfunctioning of tie letdown backpressure regulator (separate MCTF issue). This has been resolved and the relief valve is no longer being repeatedly challenged. This resolution is acceptabl Attachment 1 Page 3

- - - - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ ._ ___ _ __ ____ _ ___ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _

MCTF Observation N Resolution CAS-01 Further review of the FSAR performance requirements indicates that the system is performing essentially as designed with two compressors runnin Replacement of one compressor with one of higher capacity is a system enhancement. The system engineer is currently trending air usage as a measure of system performanc Given that the system is performing acceptably, this resolution is acceptabl Regarding the more general concern of the addition of loads which may compromise a systems' ability to perform its function (e.g., air, electrical),

licensee procedures 9.02, " Plant Modifications - Major," and 9.03,

" Facility Change - Minor," each require that a Design Input Checklist be completed. There are specific line items in each checklist speaking to system loading effects resulting from modification activities. This issue is resolve ESS-06 In discussions with the licensee it was determined that the quarterly inspections are currently being performed by the System Enginee In parallel, actions are in progress to add this activity to the Plant Periodic Activity Control Syste This issue is resolve ESS-24 The leaking containment spray values were repaired during the outag This issue is resolve RIA-01 The licensee has instituted a Plant Periodic Activity Control Sheet (PPACS)

to blow down the sensing lines on a monthly basis to remove any accumulated wate Installation of temporary heat tracingwasconsideredbutrejected based on the length and location of Attachment 1 Page 4

__ -_ __

MCTF Observation N Resolution the sensing lines. Monthly line

'

blowdown has been a successful-interim resolutio Final resolution will be tracked as an Open Item (50-255/86035-08).

MIS-01 The licensee has developed a PPACS to, !

. on a 40 day interval, clean, inspect, and lubricate recorders. This is ,

acce) table until replacement recorders can se installe AFW-05 Operation of the AFW pumps in an on/off fashion during periods requiring low ,

feedwater flows creates the aotential for thermal fatigue in the AFW system, i In reviewing this item with the licensee the inspection team was provided copies ,

, of two internal correspondences on this l 1986 and

subjectdatedAugust.11,itemsconclude August 21, 1986. These

'

that based on engineering analyses,

theIntegrityofAFWpipingcanbe

'

assured for two fuel cycles by virtue

'l of operationally induced thermal fatigue, and that modifications should

'

be installed during the next refueling outage to establisi constant low flow capability. In this regard, the licensee had committed, as part of the original MCTF report, to evaluate

modifications to establish AFW low flow capability and inspect the AFW nozzles

~

by the end of the next refueling outag !

.

The internal correspondence cited above I indicates that it is not the AFW nozzles l which are of primary concern but rather

!' the piping itself. Consequently, in a MCTF report status update the licensee ,

1 indicated that an AFW structural '

integrity maintenance program would be develope This was discussed with the licensee on January 14, 1987. Given thelimitedprojectedpotentiallifeof j the AFW piping 1t was concluded by the inspection team that this program should

'

be developed and implemented prior to i

1 l

i Attachment 1 l Page 5

_ - . .

MCTF Observation N Resolution startup following the next refueling outage regardless of whether low flow modifications are implemented and irrespective of the results of the nozzle inspections, and, that the results of this program be reviewed by Region III prior to startup following the next refueling outage. These actions will be tracked as an Open Item (50-255/8635-09).

AFW-08 The common power supply for the discharge flow control valves and low suction pressure trips on P-8A and 88 AFW pumps renders them susceptible to a single mode failure. This item had been previously identified by the licenseeandisthesubjectofan open engineering evaluation. P-8A and 8B are both part of the same train of AF P-8C, a third, motor driven, AFW pump is powered and controlled inde)endently of P8 and 8B and is capa)1e to providing adequate AFW flo Based on this, this concern is considered resolved; however, the licensee is encouraged to continue their evaluation of the common power suppl AFW-03 The inspection team reviewed test Procedures T-201, " Auxiliary Feedwater Pump P-8C Performance " T-202,

"AuxiliaryFeedwaterE-8AandP-8C System Flow Characteristics," and T-203, " Auxiliary Feedwater Turbine Inlet Pressure Control" and the results obtained therefro Based on these results it is concluded that the pumps are capable of delivering FSAR required flow Attachment 1 Page 6

, , . . . .. .. .. ..

ATTACHMENT 2 MCTF ITEMS TO BE COMPLETED PRIOR TO STARTUP FROM THE NEXT REFUELING OUTAGE MCTF Observation N Issue NRC Open/ Item N AFW-05 Evaluate the internals of 50-255/86035-10 AFW flow control valves FCV-0736A, 0737A, 0727, and 0749 for replacement to improve flow control below 100 gp Inspect AFW flow nozzles 50-255/86035-11 AFW-06 Replace AFW valve CV-0521 50-255/86035-12 AFW-08 I&C to recommended a 50-255/86035-13 program for periodic inspection / calibration for important AFW power supplies CAS-01 Revise existing preventive Completed maintenance activities to correct recurring problems with the instrument air compressors and implement a periodic inspection program Establish a baseline 50-255/86035-14 compressed air performance tes Replace one air compressor 50-255/86035-15 Evaluate instrument air Complet Currently compressor feeder breakers system operation for adequacy under frequent does not produce cycling, frequent cyclin Add instrument air flow Complete indicatio CAS-04 Evaluate the instrument 50-255/86035-16 air system for the addition / deletion of drain trap . _ _ ___________ _ __ - ________~

MCTF Observation N Issue NRC Open/ Item N Blow down the instrument 50-255/86035-17 air system including disassembly / inspection of random components.

CCS-02 Evaluate the effectiveness 50-255/86035-18 of placing an 0-ring on the tapered end of the shaft sleeve of the Component Cooling Water (CCW) pumps to eliminate seal leakag Evaluate replacing CCW 50-255/86035-19 pump mechanical seal Inspect and repair CCW 50-255/86035-20 pump internals.

CDS-02 Investigate putting in a 50-255/86035-21 seal trough or new condenser expansion join Investigate a better 50-255/86035-22 method of condenser expansionjointleak detectio Review the study performed 50-255/86035-23 of the last expansion jointreplacementand renew recommendations.

CDS-03 Rebuild and install the 50-255/86035-24 spare condensate pump for P-2 Test condensate pumps for 50-255/86035-25 groundwater leak Repair cracks in condensate 50-255/86035-27 pump bas Modify oil coolers on 50-255/86035-25 condensate pump Attachment 2 Page 2

.

MCTF Observation N Issue NRC Open/ Item N CDS-05 Establish a yearly 50-255/86035-28 Preventive Maintenance (PM) to overhaul the hotwell sample and radwaste caustic injectionpump Establish a procedure 50-255/86035-29 for installation of internal parts in the hotwell sample and radwaste caustic injection pumps and methods to prevent piping / fitting leak CDS-06 Evaluate removal of the 50-255/86035-30 condensate hotwell makeup valve CV-073 CDS-07 Evaluate the need to 50-255/86035-31 upgrade or replace the positioner and controller and implement shutdown PM's on the Moisture Separator Drain Tank Valves CV-0608 and 060 CDS-9 Purchase / replace main 50-255/86035-33 air ejector jets and establish a PM to replace main air ejector jet CHM-01 Initiate a PM on the Complete Chemical Addition Pump CIS-03 Implement LLRT program 50-255/86035-33 enhancement CIS-04 Pursue a technical 50-255/86035-34 specification change to reduce testing frequency on containment hydrogen monitoring system valve CRD-02 Replace autoclave gaskets 50-255/86035-35 on 19 CRD' Attachment 2 Page 3

MCTF Observation N Issue NRC Open/ Item No.

CRD-03 Evaluate use of protective 50-255/86035-36 coatings on CRD thermocouple exposed terminal block Evaluate replacing CRD 50-255/86035-37 thermocouple Evaluate replacement of CRD 50-255/86035-38 thermocouple chart recorder.

CRD-04 Replace CRD secondary 50-255/86035-39 position indications.

CVC-01 Evaluate the need to 50-255/86035-40 replace / repair check valves CK-2114 and 2116.

CVC-03 Evaluate development of a 50-255/86035-41 test procedure to determine letdown orifice stop valve leakage.

CVC-07 Replace / modify that 50-255/86035-42 portion of CVCS containing CV-2056 (3 way valve) to eliminate leakage and facilitate maintenance.

CVC-13 Replace CVCS valves 50-255/86035-43 CV-2153, 2155, and 2165.

CVC-14 Repair and restore boric 50-255/86035-44 acid heat tracing to original as-built condition.

CVC-15 Replace the block on Complete charging pump P-55A.

CVC-26 Replace the hydrazine Complete metering pumps.

CVC-28 Remove or replace 50-255/86035-45 boronometer and associated instrument Attachment 2 Page 4

MCTF Observation N Issue NRC Open/ Item No.

CWS-01 Refurbish Cooling Tower 50-255/86035-46 Pumps P39A and 39B.

DTA-02 Complete plans for 50-255/86035-47 replacement of the sequence-of-events monitor and data-logger system.

EPS-01 Replace diesel generator 50-255/86035-48 frequency and load indicatio Incorporate diesel 50-255/86035-49 generator reflash capability.

EPS-04 Provide a crossite between 50-255/86035-50 diesel fuel tanks T-10 and T-29 Procure a spare fuel oil 50-255/86035-51 transfer pum Consider providing a 50-255/86035-52 secondary containment for T-10.

EPS-05 Implement a permanent 50-255/86035-53 solution to diesel generator lube oil temperature switch problems.

EPS-06 Replace Appendix R 50-255/86035-54 emergency lighting units.

ESS-01 Develop and implement 50-255/86035-55 electrical and mechanical PM's that will ensure reliable HP air compressor and system operation.

ESS-02 Develop a plan to replace 50-255/86035-56 all safety injection check valve Attachment 2 Page 5

MCTF Observation N Issue NRC Open/ Item N ESS-03 Replace SI fill and drain 50-255/86035-57 valves CV-3003, 3004, 3039, and 304 Evaluate SI pressure 50-255/86035-58 control valves PCV-3038, 3042, 3046, and 3047 for replacemen ESS-04 Develop a plan to provide 50-255/86035-59 alternate shutdown cooling to allow repair / replacement of LPSI shutdown cooling heat exchanger inlet, b pass Ch-3005,andcrossovervalves 3025, and 305 Add manual control air 50-255/86035-60 operation capability on CV-3025 and 305 ESS-05 Replace shutdown cooling 50-255/86035-61 heat exchanger valves CV-3212, 3213, 3223, and 322 Establish an inspection 50-255/86035-62 and rebuild PM for valves CV-3212, 3213, 3223, and 322 Permanently shield the 50-255/86035-63 shutdown heat exchanger and remove existing hot spot ESS-06 Install new packing 50-255/86035-64 configuration on SIRW i

Tank Outlet Isolation i

Valves CV-3031, 3057.

! ESS-07 Relocate FT-0404 upstream 50-255/86035-65

,

on the fast recirc line.

'

ESS-11 Implement a modification 50-255/86035-66

! to prevent temperature l swings on SI bottles.

.

.

,

Attachment 2 l Page 6 i

_ _ _ _ _ _ _ _

MCTF Observation N Issue NRC Open/ Item No.

ESS-12 Investigate deletion of 50-255/86035-67 the requirement for chemical addition to the containment spray system.

ESS-20 Replace DBA/ Normal 50-255/86035-68 shutdown sequencers.

ESS-22 Evaluate the effectiveness 50-255/86035-69 of live load packing and block off the leak-off lines on Shutdown Cooling Inlet Isolation Valves M0-3015 and 3016.

ESS-23 Repair SIRW Tank leak 50-255/86035-70 ESS-24 Repair or replace 50-255/86035-71 containment spray valves CV-3001 and 300 Revise LPSI and containment 50-255/86035-72 spray surveillance procedure so as not to render the systems inoperable.

ESS-25 Evaluate removal of T-103 50-255/86035-73 iodine removal makeup tank.

FPS-01 Replace diesel fire pump 50-255/86035-74 flywheels.

FPS-04 Replace /repairinoperable 50-255/86035-75 fire doors.

FPS-06 Replace sprinkler fire 50-255/86035-76 alarm panel C-47.

FWS-02 Correct P&ID's to show the 50-255/86035-77 FWRV bypass valves are fail as is on loss of air.

FWS-03 Establish a PM for the 50-255/86035-78 positioner seals and 0-rings on the FWRV block valves CV-0742 and 074 Attachment 2 Page 7

MCTF Observation N Issue NRC Open/ Item No.

FWS-04 Evaluate calibration 50-255/86035-79 frequency of feedwater regulating circuitry MIS-01 Prepare a list of control 50-255/86035-80 room chart recorders that need to be replaced.

MIS-02 Ensure sufficient spare 50-255/86035-81

) arts are available for

arris relief valves.

MIS-06 With the assistance of an 50-255/86035-82 outside agency develop and implement a valve packing program and a corresponding training program.

MIS-08 Develop and implement a 50-255/86035-83 hanger and restraint inspection program.

MIS-09 Identify and repair non-EC 50-255/86035-84 solenoid valves with fiel wiring terminated inside the solenoid valve body housing.

MIS-10 Rebuild all plant 50-255/86035-85 limitorque valve operators.

MSS-02 Review the stroke time 50-255/86035-86 requirements of AFW pump steam supply valves CV-0522A and B.

NMS-01 Join the CE owner's group 50-255/86035-87 to address neutron instrumentation concerns.

MNS-02 Return spare power range 50-255/86035-88 to the channel vendor for (s/n106)ishmen refurb Attachment 2 Page 8

. _ _ _ _ _ - _ _ _ _ _

MCTF Observation N Issue NRC Open/ Item N PCS-01 Establish a packing 50-255/86035-89 adjustmentPMfor pressurizer spray valves CV-1057 and 105 PCS-09 Replace pressurizer 50-255/86035-90 pressure SI "A" channel with a variable high power tri PCS-10 Investigate replacement 50-255/86035-91 or modification to pressurizer PORV and safety discharge temperature

! indicator terminations to eliminate connector corrosio PCS-11 Disassemble and PM a 50-255/86035-92 primary coolant ) ump moto Repair tie associated motor bearing temperature indicato PCS-12 Review the primary 50-255/86035-93 coolant pump impeller  ;

cracting problem with Byron-Jackson and determine whether an inspection is appropriate.

4 PCS-13 Reevaluate pressurizer 50-255/86035-94 heater component specifications. Replace ,

'

> components as necessar ,

Reevaluate mode of 50-255/86035-95 operation to determine j if continuous heater i energization is appropriat RIA-02 PerformQ-list 50-255/86035-96 interpretation regarding Engineered Safeguards room monitor sample pump.

l I

l

'

Attachment 2

)

Page 9

- _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

MCTF Observation N Issue NRC Open/ Item N RIA-04 Replace Off Gas Radiation 50-255/86035-97 Monito RIA-05 Replace the Liquid Radwaste 50-255/86035-98 Discharge Process Monitor packag RIA-08 Perform a Q-List 50-255/86035-99 Interpretation on the Controlled Lab Monitor RIS-230 RIA-09 Perform a Q-List 50-255/86035-100 Interpretation on the Containment Purge Room Monito RIA-10 PerformaQ-List 50-255/86035-101 Interpretation on the Personnel Air Lock Monito RIA-11 Perform a Q-List 50-255/86035-102 Interpretation and Replace the Stack Gas Monitoring Syste RIA-13 Perform a Q-List 50-255/86035-103 Interpretation on the S/G Blowdown Tank Vent Monitor RIS-232 RIA-20 Perform a Q-List 50-255/86035-104 Interpretation and complete replacement of the Radwaste Addition Ventilation Monitor RIA-571 RIA-21 PerformQ-List 50-255/86035-105 Interpretation on and complete replacement of the Fuel Handling Ventilation Monito RIA-571 RIA 22 PerformQ-List 50-255/86035-106 Inter)retation on the Flat 3ed Filter Room Radiation Monitor, RIA-825 Attachment 2 Page 10

. . .

.

.

. _

, ._ ___ ______ - __ _ _ __ _- ______ __ _ _ _ _ _

MCTF Observation N Issue NRC Open/ Item N RIA-23 Ensure o)erability of 50-255/86035-107 Monitor lIA-2316 prior to fuel movemen RIA-25 Replace the S/G Blowdown 50-255/86035-108 Monito RIA-29 Perform a Q-List 50-255/86035-109 Interpretation of the Radwaste Ventilation Monito RIA-30 PerformaQ-List 50-255/86035-110 Interpretation of the East and West Engineered Safeguard Radwaste Isolation Vent Monito RIA-32 PerformaQ-List 50-255/86035-111

,

Interpretation of the J

'

Auxiliary Building Addition Monito RPS-02 Complete modification of 50-255/86035-112 the variable high power tri I RPS-03 Ensure adequate critical 50-255/86035-113 i spare parts are available

for the reactor protection syste SPS-04 Change operating procedures 50-255/86035-114

,

to eliminate bus transfers to

station power.

SWS-01 Rebuild all Bettis actuators 50-255/86035-115 on SWS valve Inspect all SWS valves for 50-255/86035-116

' erosion. Clean as rebuild as necessar Develop a PM to inspect SWS 50-255/86035-117

valves and actuator SWS-02 Evaluate sources of SWS 50-255/86035-118 vibration using signature i analysis.

i

~

Attachment 2

Page 11 i i

. . ~ . - . - - . - . . . _ - - - . - _ - . - -.

.

l MCTF Observation N Issue NRC Open/ Item No.

) Place the SWS pumps on a 50-255/86035-119 l periodic inspection progra !

l

SWS-04 Implement a program to 50-255/86035-120 ,

!

inspect all heat exchangers '

cooled by the SW '

, Place critical SWS equipment 50-255/86035-121

.

and serviced components in

the PM program.

'

TGS-01 Upgrade EHC piping and 50-255/86035-122

! fittings per Westinghouse '

recommendation ,

t TGS-02 Repair generator end bell 50-255/86035-123 hydrogen leakag TGS-05 Test and Rebuild Moisture 50-255/86035-124 Separator Reheater Safety Valves RV-0530 through RV-055 TGS-07 Replace Main Stop Bypass 50-255/86035-125 -

)1 Manual Air Pilot valve with '

t a solenoid and pilot valve.

I TGS-08 Develop a plan to fix the 50-255/86035-126 turbine turning gear timing gear.

4 TGS-09 Install temaerature control 50-255/86035-127 j valves on t1e turbine seal i oil system.

i TGS-14 Recommend modifications to 50-255 J-128

the turbine building sump i pumas P-45A and B to correct i

hig1 maintenance and reduce the

volume of water going to the i sump.

'

Evaluate the installation 50-255/86035-129

of a permanent sump pump

! in the AFW pump roo '

!

i

!

i Attachment 2 j Page 12

.

. - . - -- - - - . - . - - - - -

.

MCTF Observation N Issue NRC Open/ Item N TGS-16 Install an audible alarm- 50-255/86035-130 o in the control room for turbine panel troubl i!

(

Evaluate replacing the aging 50-255/86035-131 turbine EHC power supplie VAS-01 Investigate the sources of 50-255/86035-132 vibration in control room air conditioners VC-10 and VC-11 and propose

, modifications to resolv .

VAS-02 Evaluate the feasibility 50-255/86035-133 of isolating individual Engineered Safeguards Coolers during power operations to facilitate maintenance.

)

.\

Attachment 2 Page 13

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ATTACHMENT 3: 50.54(f) RESPONSE MATRIX Information Requested Response Elements Inspection Adequate Comments Methodology employed to MCTF PR Y Paragraph 3.d identify and disposition Pump Test Program' RI Y deficiencies SFE PR, OR Y Paragraph 4 Status of disposition of MCTF PR Y Proposed disposition all issues identified SFE PR, OR Y adequat Final dispo-from the above sition pending pre and post restart testing Emergent Issues Corrective Action RI Y Paragraph 5 Program NRR Y TS Change This item relates to service water system performance deficiencies Listing of deficiencies List Provided PR, RI Y Encompassed in MCTF, SFE.

reflective of a failure TS Changes NRR Y These items relate to to maintain design bases 50.59 Evaluations NRR Y Service Water System and Component Cooling Water System Deficiencies Listing of Deficiencies List Provided PR, RI Y Encompassed in SFE.

not identifiable through existing test programs and why List of Deficiencies to 50.59 Evaluations NRR Y These items relate to be carried beyond current TS Changes NRR Y Service Water System and outage and JC0 Component Cooling Water System Performance Defi-ciencies

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____ Information Requested Response Elements Inspection Adequate Comments Extent of reviews done MCTF PR Y Paragraph on B0P to ensure reli- SFE PR, OR Y Paragraph 4 ability Extent to which pro- PR Y Paragraph 5 grammatic weaknesses contributed to conditions where design bases were not satisfied Describe changes made or Paragraphs 3 and 5 planned to the work pro-cess in:

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Deficiency Identification PR Y Deficiency Evaluation PR Y Root Cause Determination PR Y Prioritization PR Y Post Work Testing PR Y Describe changes made or Pump Test Program RI Y planned in routine Augmented serveil- No -

testing program lance SFE PR Y Paragraphs 3, 4 and 5 MCTF PR Y PM Program PR Y Describe training program Implementing a No N At the time the inspec-changes as a result of performance based tion closed the licensee deficiencies identified training program had yet to develop the during this outage for maintenance training program for technical personne This will be reviewed in the futur ATTACHMENT 3 Page 2

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Information Requested Response Elements Inspection Adequate Comments Describe any changes Administrative 'PR Y Paragraphs 5 and 6 planned or made to the- procedures stren- -

plant modification gthened for reviews control program and trackin Enhanced tech PR N Paragraph 5 The program

& admin. trainin had not been finalize Configuration -N Unknown The Program had not been-Management' developed by the close 2 of the inspection.

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Describe those mgt Mgt trending of PR Y- Paragraph 7

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systems which will be _33 parameters.

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employed as a mechanism Equipment per- PR Y to assess plant perform- trending.

j ance.

!

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Describe short & long MCTF' PR Y Paragraph 3 term modifications in-

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tended to ameliorate

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design deficiencies discovered during this outage.

, SSFI Issues Plant modifica- PR Y Paragraphs 5 and 6 tions Procedure changes PR Y

- Training PR Y

ATTACHMENT 3 Page 3 i

a

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J Information Requested Response Elements Inspection Adequate Comments Provide a detailed' Configuration Mt No Unknown The program had not been description & implement- Program developed by the close of ation schedule for all the inspectio corrective action pro-grams to be implementation after restar Comprehensive PR Y Paragrah 3 Valve Program INP0 Accrediation No Unknown of Craft Training Systems Training PR Y Paragraph 5 for Sys Eng Mtg Development PR N This program was not-Training developement by the close of the inspection and will be inspected in the futur Implement an PR Y Paragraph 5 enhanced PM Program System Functional PR Y Paragraph 4 Evaluation Deferred Testing Integrated Start- No -

This program will be up Test Program inspection during the Operational Readiness Inspection Q

<

ATTACHMENT 3 Page 4

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Information Requested Response Elements Inspection Adequate Comments Provide a listing of .. MCTF PR .

Y Paragraph'3

< MCTF items & emergent SFE PR .Y Paragraph 5 issues whose resolution Work Order PR Y Paragraph 3 is scheduled after Backlog restart TS Changes (SW) NR Y These issues relate to 50.59 Evaluations NRR Y the. Service Water, Com-ponent Cooling Water Systems For each system for SFE PR- Y Paragraph 4 which a SFE was per-formed, provide reference to the source of the criteria against which system performance was evaluated, provide justification for use of other than current oper-4 ating data to support

operability / function-

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ability, & provide the basis for any system which does not explicitly a satisfy the operability /

! functionability criteria i

Provide a summary Integrated tests OR Unknown This program will be description of any of CVCS evaluated during the testing planned or per- AFW Operational Readiness formed above the compon- Main Steam Inspection ent level for each system CCW which was the subject of SW

. the MCTF or SF Feed & Condensate Include power ascension

hold point ATTACHMENT 3

Page 5-

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Information Requested Response Elements Inspection Adequate Comments Provide a description of Existing correc- PR, OR Y Paragraph Implemen-the program for test tive action tation relative to discrepancy resolution program restart testing will be evaluated during the Operational Readiness Inspectio ATTACHMENT 3 Page 6

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Docket No. 50-255 Consumers Power Company-ATTN: Dr. F. W. Buckman Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:

This refers to the special plant readiness team inspection conducted by Messrs. W. Guldemand, H. A. Walker, S. A. Reynolds, A. Dunlop and Miss C. D. Anderson of this office during the period of December 16, 1986, through February 13, 1987, of activities at the Palisades Nuclear Generating Plant authorized by NRC Provisional Operating License No. DPR-20 and to the

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discussion of our findings with Mr. J. F. Firlit at the conclusion of the inspection. The purpose of this inspection was to determine whether the licensee had made sufficient progress in improving the material condition

.of the Palisades facility and solving design issues to support restart and

.whether adequate assurances had been provided that an acceptable level of material condition would be maintained to support continued safe and reliable operatio The enclosed copy _of our inspection report with its three attachments identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne It was the conclusion of the inspection team that upon completion of

. outstanding prestart commitments, the material condition of the plant would be adequate to support plant restart. Further adequate commitments have been made to reasonable maintain an acceptable level of material condition-to support continued safe and reliable plant operatio During this inspection, certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice. A written response is required. In addition, your previous response to violation 255/85003-21 was judged to be inadequate as discussed in Paragraph 7.g of the enclosed report and you are requested to submit an additional response to this violatio ,

In accordance with-10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC Public Document Room.

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Consumers Power Company 2 The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 We will gladly discuss any questions you have concerning this inspectio

Sincerely, Charles E. Norelius, Director DivisionofReactorProjects Enclosures: Notice of Violation Inspection Report with Attachments No. 50-255/86035(DRP)

cc w/ enclosure:

Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Nuclear Facilities and Environmental Monitoring Section RIII RIII Norelius/1ms Guldemond l

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