Text

SALP Rept 50-255/88-01 for May 1987 - May 1988
	ML18053A513
Person / Time
Site:	Palisades
Issue date:	08/15/1988
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML18053A512	List: IR 05000255/1988001; ML18053A511;
References
	50-255-88-01, 50-255-88-1, NUDOCS 8808240132
	Download: ML18053A513 (39)
	v • d • e

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SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION

REGION III

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-255/88001 Inspection Report N Consumers Power Company Name of Licensee Palisades Nuclear Gene-rating Station Name of Facility 8808240132 880815 PDR ADOCK 05000255 Q

PDC May 1, 1987 to May 31, 1988 Assessment Period

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SALP 8

SUMMARY OF RESULTS The licensee's overall performance continued to improve as demonstrated by the ratings of Category 1 for the functional areas of Surveillance, Emergency Preparedness, Security, and Outage The functional area of Plant Operations received a Category 2 with an improving trend based on improved event response and enforcement history coupled with a decline in Operational Event However, a Category 2 with a declining trend was given in the area of Licensing due to insufficient detail provided in routine license amendment submittal Additionally, the functional area of Fire Protection received a Category 3 solely due to Appendix R def i ci enci e Rating This Functional Area Rating SALP 7 Period Plant Operations

2 (improving) Radiological Controls

2 Maintenance

2 Surveillance

1 Fire Protection

3 Emergency Prepareaness

1 Security

1 Outages

1 Engineering/Technical Support

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2 Licensing Activities

2 (declining) Training and Qualification Effectiveness

2 Quality Programs and Administrative Controls Affecting Quality

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New functional area for SALP I PERFORMANCE ANALYSIS Plant Operations Analysis Evaluation of this functional area was based on the results of 13 routine resident inspections and one special inspection of the loss of offsite power event of July 14, 198 Enforcement history in this area was very good during the 13-month evaluation period and improved over the previous assessment perio One Severity Level IV violation was issued for a valve lineup error where the check sheet was incorrect and had not been identified during seven previous lineup check Other valve lineup errors were also identified as a result of licensee audits and routine reviews by operator Licensee corrective actions were appropriate and extensive; incorporating human factors improvements that resulted in the dedication of individuals to revising and walking down the checklist The number o~ operational events that occurred during the assessment period was reduced from the previous perio Five reactor trips from power occurred this period, four of which were manually initiated after recognition of deteriorating plant conditions by licensed operator An example of outstanding reactor operator response involved the July 14, 1987 loss of offsite power event during which a manual trip was initiated prior to the imminent automatic trip, thereby reducing the extent of primary and secondary plant transient However, other operational events occurred that indicate operators were not consistently aware of changing plant condition This resulted in plant conditions that approached operational limits and are discussed in the paragraph relating to licensee event report Overall, operator action, knowledge, and coordination during operational transients and events was observed to be appropriate, adequate and timely and in addition, operator error accounted for only one outage which occurred when a feed pump discharge was inadvertently isolate A review of the licensee event reports (LERs) identified three reports related to critical operation below 525° Two were caused by operator inattention and one was due to equipment failur Of the six LERs that reported unintentional safety feature actuations, three were related to operational activities, one of which (diesel generator start) could have been eliminated by more timely corrective action Otherwise, corrective actions were timely and effectiv None of the events involved significant safety concern Although not reportable events, a number of licensee identified internal deviation reports indicated a general problem with equipment control and status taggin +,

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Management involvement in ensuring quality in this area continued to improve from the last evaluatio Personnel changes have been made to ensure that appropriate personnel are in critical position Clear communication between operations, maintenance, and engineering personnel to obtain needed support is provided both verbally and by a revised priority syste A daily report of plant status is furnished to the Vice President, Nuclear Operations and is utilized to track long-range equipment concerns, items currently receiving priority attention, and Technical Specification Limiting Conditions of Operation (LCD) item Operations management continues to be invoived in training and also provides a high level of visibility to operators by conducting daily tours and routine face-to-face communication Management is also involved in redesigning equipment control methods to reduce the number of events that are related to equipment contro A rigorous review of equipment status is now performed prior to each restart by the Plant Review Committee, wi.th involvement by the Vice President of Nuclear Operation This level of involvement and support by corporate management has impacted favorably on all areas of operation The achievement of control room 11blackboard 11 conditions during this period is viewed as a significant enhancement to the operator 1s ability to identify abnormal conditions and respond properl Plant availability was 66.6% for the period, reflecting the outage time taken to make improvements and repair plant equipmen Management responsiveness to NRC initiatives in this area was good, as demonstrated by the corrective actions taken by the licensee in addressing concerns raised by the NRC during this and previous assessment period As an example, management response to the loss of offsite power event was conservative, well thought out and appropriately planne Although the current offsite configuration meets General Design Criteria, the licensee initiated efforts to enhance the offsite power reliabilit The licensee 1s approach to resolution of technical issues from a safety standpoint was mixe The decision to shut the plant down when a small fraction of the allowable steam generator tube leakage was indicated, reflected a conservative approac Resolution of other issues was less conservative; one example was the addition of ineffective administrative controls instead of the submittal of new Technical Specifications regarding the shutdown cooling and offsite power requirements during plant shutdow Staffing in this functional area was maintained at sufficient levels to support five shifts with adequate reserve and to conduct operations with an average of 7% overtime which is a significant improvements over previous period ~.

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,.,,.*:. Cone l us ions The licensee's performance is rated Category 2 in this area, with an improving tren The licensee was rated Category 2 in the previous assessment perio The Board noted a general improving trend in performance that is primarily due to improved event response, decrease in operational events, and improved enforcement histor.

Board Recommendations Non Radiological Controls Analysis Evaluation of this functional area was based on the results of five inspections performed during this assessment period by regionally based specialists and observations by the resident inspector Enforcement history in this area was adequate and was about the same as the previous assessment period with two Severity Level IV violations in the current 13-month assessment period, as compared to one Severity Level IV violation identified during the previous 18-month assessment perio The two radwaste shipping violations cited during this assessment period were not indicative of significant programmatic weaknesse Seven events attributed to activities in this area required the submittal of LERs. *Five of these concerned waste gas releases that did not meet Technical Specification release requirements and were due to a variety of cause Three resulted from operator personnel/procedural errors, one was a maintenance personnel error, and one was due to defective equipmen The other reports involved liquid effluent samples not being taken, and one special report was submitted because of the extended inoperability of the high-,range noble gas effluent monito None of the events were in themselves significant from an environmental release standpoint, but the number of inadvertent or improperly monitored releases may indicate programmatic weaknesse Staffing levels and qualifications were adequate to implement the radiation protection and chemistry program A declining turnover rate has improved the overall radiation protection technician (RPT) experience leve The radiation protection staffing level was increased by the addition of two professional staff members and a crew of seven radwaste/decontamination workers and by the return of the Senior Health Physicist and Staff Health Physicist from the Material Condition Task Forc.-:

The licensee's augmentation of the radiation protection staff by contracted personnel appears to be adequat The chemistry staffing was improved by reorganization toward the end of this period, with several new but experienced staff placed in upper level positions, including the group leader (Plant Chemical Engineer).

The radiation protection and chemistry technician training programs were accredited by the Institute of Nuclear Power Operations (INPO) during this assessment perio The continuing training program for radiation protection technicians has been improve Courses in job coverage, radioactive material, and ALARA engineering have been developed to enhance the radiation protection progra Management involvement in this functional area was extensive, with mixed result Management initiated improvements included increased instrument maintenance, improved valve maintenance that reduced contamination levels, a new job-coverage training course, meetings with worker groups in other departments to encourage good radiation worker practices, a hot spot reduction program, addition of radiation worker performance appraisal elements for.appropriate plant workers, establishment of a Technician Task Force to review radiation protection (RP)

practices, broadening experience levels of first and second line supervision by attending conferences and special training courses, establishment of a special dedicated decontamination crew, implementation of a RP practices 11coach 11 for on-the-job training and assistance, and a boric a~id addition program for the secondary water syste The secondary water chemistry program generally conforms to the Electric Power Research Institute (EPRI) Steam Generator Owners Group Guidelines but is not mandated by a corporate policy statemen Steam generator chemistry holdpoints were routinely waived during startup when improving trends were evident, the effect of which over the long-term has yet to be determine Although implementation was slow, the licensee plans improvement and/or modifications of access control, laundry facilities area, and the cold and 11gray 11 (low level counting facility) laboratorie In addition, correction of problems concerning control rod drive mechanism leak-off, volume reduction system, and highly contaminated tanks are also planne Also, the licensee has been slow to make needed ventilation improvements in the hot laboratory and main counting room and to alleviate overcrowding in the hot laborator Licensee audits and responses in this functional area have been generally satisfactor Licensee responsiveness to NRC issues has been adequate, with occasions of weak as well as good performanc Responsiveness was weak early in the assessment period, particularly with regard to correction of NRC-identified problems in the chemistry Quality Assurance/Quality Control (QA/QC) program; but responsiveness improved substantially later in the perio The licensee has been slow to correct weaknesses identified concerning implementation of actions

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needed to prevent future flooding of the south radwaste building, poor frisking practices, controls for analytical measurements, and resolution of liquid effluent radiation monitor concern Examples of good performance.included an aggressive program to improve radiological work practices, improved control of extreme high radiation areas, procurement and installatfon of high sensitivity personnel contamination monitors, and efforts to reduce auxiliary building and personnel contamination event The licensee 1s approach to resolution of technical issues was generally satisfactor Examples of good performance included impiementation of a hot-particle control program, dosimetry readout and dose-control computer interface improvements, a leak reduction program to eliminate a noble gas problem in the auxiliary building, and numerous ALARA program improvement Examples of poor performance included recurrence of problems regarding implementation of the solid radwaste process control program and inadvertent gaseous radwaste release Personnel radiation exposures of approximately 650 and 450 person-rem for 1986 and 1987, respectively, are comparable to the licensee 1s annual average of approximately 600 person-rem for the previous five year This reflects the extensive outages which have been necessary to improve plant material condition The licensee has implemented a comprehensive five-year exposure reduction plan and an aggressive ALARA program to significantly reduce personnel exposures in future year Gaseous and liquid radiological effluent annual releases declined during this assessment perio The licensee continues to make progress in reducing the volume of solid radwaste generate Radiological confirmatory measurements were fair, with 60 agreements in 75 comparison The discrepancies were related to the calibration standards and some incorrect library entries (software deficiencies).

The licensee 1s performance in nonradiological confirmatory measurements was also fair, with 38 agreements in 57 comparison These problems reflected deficiencies, which the licensee has agreed to correct, in the QA/QC of the measurements progra.

Conclusion The licensee's performance is rated Category 2 in this are The 1 i censee was rated Category 2 in the previous ass.essment perio.

Board Recommendations Non *~

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.:,;.-,...... :.. :.. ~. Maintenance Analysis Evaluation of this functional area was based on the results of routine inspections by the resident inspectors and three special inspections of outage planning, outage maintenance activities, and actions on a NRC Bulletin 85-03 pertaining to Limitorque valve operator Enforcement history in this area was quite good, with only twc Severity Level IV violations being issued as compared with the five issued during the previous perio One violation concerned an untimely corrective action with regard to charging pump operability and contractor contro The second violation was for inadequate work planning related to preventive maintenanc Although these violations did not represent programmatic problems, the failure to review and act in a timely manner on the charging pump issue which had been deleted from the licensee's action tracking system, reflects unfavorably on the licensee's responsiveness to NRC issue Four LERS were issued, three of which were maintenance personnel error One resulted in a loss of shutdown cooling and related to contractor control (the same issue as the second violation noted above).

The second involved an inadvertent low pressure safety injection (LPSI) pump start during sequencer contact cleanin The third resulted in a Technical Specification violation of waste gas holdup requirements when the wrong relief valve was remove The fourth event also involved the waste gas system and required preventive maintenance on diaphragm valve Because the licensee identified violations received prompt review and corrective actions, no citations were issue No reactor trips from power resulted from maintenance activitie Overall, performance in this functional area improved considerably compared to previous assessment period Management continued extensive involvement in ensuring quality by making resources available to deal with the corrective maintenance issues and develop an effective preventive maintenance progra Steady progress has been made in reducing the corrective maintenance backlog from 750 at the start of the period to about 400 at the end, while the percentage of man hours expended in preventive maintenance has increased from 43% to about 60% at the end of the perio Of the 422 corrective work orders, 65% of them were initiated during the first four months of 1988 indicating a good reduction in the age of the backlo Further, overdue preventive maintenance items average

.around 2%, below the licensee's goa *.

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Another initiative was the development of the Valve Improvement Program, which has not only increased the knowledge, skill, and ability of the operations and maintenance workers to properly operate and maintain valves, but has provided valuable engineering support resulting in a substantial improvement in valve conditio Evidence of this is provided by a reduction in the primary coolant system unidentified leak rate from an average of 0.3 gpm two years ago to a current average of less than 0.1 gp Other management initiatives include the conduct of a Maintenance Self-Assessment with INPO, establishment of a detailed system trend program, the instrument upgrade program, and the Configuration Control Projec Overall, the achievement of a 11 blackboard 11 condition is attributable to extensive management involvemen Aside from the charging pump issue noted above, maintenance management continues a trend of good responsiveness to NRC initiatives, and in some instances has gone beyond requirements, an example of which was the licensee's response to the NRC Bulletin involving Limitorque valve operator Technical issues were approached from a safety standpoint, with improvements noted in the quality of review given to issues brought to the Corrective Action Review Boar Licensee management continues to take a conservative approach to resolution of technical issue For example, as a result of repairing a body-to-bonnet leak on a f~edwater regulatory valve, internal erosion of the body was note In spite of the delay in plant startup, the valve and its companion in the other train were repaire Two planned maintenance outages (one accelerated due to a steam generator tube leak) resulted in significant improvement in the operability and reliability of the plan The unit forced outage rated for this assessment period was about 30%,

a significant improvement when compared with the previous assessment perio However, during the last three months of the period, it further improved to a level of 3%, significantly better than the licensee's previous performanc Nevertheless, forced outage continues to be a NRC concer Staffing was adequate for the performance of the assigned tasks, with contractor support utilized, as needed, to meet goals and expectation Organizational changes were made that enhanced the functionality of the maintenance organizatio No problems were identified associated with staffing during this evaluation perio Overtime attributed to plant maintenance during this assessment period was controlled at a remarkably low leve This coupled with a reduction in the maintenance backlog and its age is indicative of improved overall maintenance managemen.

Conclusion The licensee's performance is rated Category 2 in this are The licensee was rated Category 3 in the previous assessment perio This improvement was the result of continued extensive management involvement in improving maintenance programmatic aspects and the material condition of the plan In addition, it is due to the reduction in the maintenance backlog and an improved preventative maintenance effor.

Board Recommendations Non Survei 11 ance Analysis Evaluation of this functional area was based on the results of 13 routine monthly inspections by the resident inspector Enforcement nistory in this area was considerably improved from the prior assessment period in that one Severity Level IV violation was issued involving the failure to schedule a local leak rate test. This compares favorably with the five violations, including a Severity Level III violation, issued during the previous assessment perio Considering the unique nature of. the violation, corrective actions were exceptionally comprehensiv Two other licensee identified violations that were reported in LERs involved the performance of chemical analysis and are not considered to be significan Of the four LERs identified as being associated with this functional area, two involved the aforementioned licensee-identified violations and the remaining two were related to procedural and licensed operator errors that caused the

inadvertent actuations of the auxiliary feedwater syste * Strong management emphasis in this area continues to be provided by the Surveillance Program Coordinato The computerized scheduling program has resulted in only one scheduling error out of approximately 1400 scheduled surveillances and has proven to be a valuable aid in the scheduling of the surveillance activities for eight outages (six forced, two planned) during this perio Some procedural weaknesses were identified and are being addresse The surveillance group is actively involved in the improvement of testing procedures, participates in daily and outage planning, maintains the Technical Specification implementation matrix, and reviews completed tests to ensure validity* before input to the scheduling progra The surveillance program has been effective in predicting incipient pump bearing failure and the results were used several times to accelerate preventive maintenanc *

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The licensee's responsiveness to NRC issues and approach to resolution of technical issues pertaining to this functional area was good, as demonstrated by the voluntary preparation of a submittal in response to Generic Letter 87-09 (pertaining to applicability of LCOs for operability and surveillance requirements), which will result in a more conservative requirement than currently exists in the Technical Specification In addition, during the outage caused by steam generator tube leakage, a conservative management judgement was made to implement a steam generator tube inspection program more extensive than that required by the Technical Specification Staffing is more than adequate for accomplishment of the assigned responsibilities in this functional are.

Conclusion The licensee's performance is rated Category 1 in this are *The licensee was rated Category 2 in the previous assessment perio This improvement was the result of strong management attention to the overall surveillance progra.

Board Recommendations Non Fire Protection Analysis Evaluation of this functional area, including safe shutdown capability, was based on the results of one regionally based inspection to review actions taken on previous inspection finding These findings pertained to the facility's post fire safe shutdown and alternate shutdown methods, and emergency lighting sections of 10 CFR Part 50, Appendix In addition, a review of fire brigade training records, participation in a halon fire-suppression system training class, and the witnessing of an unannounced fire brigade drill were also performed during this inspectio Routine inspections by the resident inspectors were also considere Enforcement history in this area indicated improvement in performance since the last assessment perio Three Severity Level IV and one Severity Level V violations were issued during the previous assessment perio During this assessment period, one issue, which was identified prior to this assessment period, was determined to be a potential escalated enforcement issue of Appendix This issue regarded three examples of inadequate associated circuit analyses pertaining to a lack of breaker coordination for required circuits, a lack of high/low pressure

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interface analysis for the letdown interface, and a lack of spurious signal analysis for the volume control tank (VCT)

outl~t valve. The licensee 1s corrective actions included completing a breaker coordination time current study and additional procedural revisions to resolve the above inadequacie Also, during the region-based inspection, a deviation was identified in that one fire brigade member failed to participate in the required number of fire drills during calendar year 198 T ;ron~o..o.~~ "'~~nnn~.o +n nno.W"~+;nn~1 6\\.1.oni+c w~c nono.~.:::rill\\1 Ill-I '"°'-11...,....,._

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~-**-*-* IJ adequate as evidenced by their response to the fire main ruptur Operators were misled by inadequate drawings of the system, bu corrective actions were found to be generally adequate, although not particularly promp Other minor events received good attention by the Fire Protection Supervisor, along with adequate followup corrective action Management involvement.in this area was generally adequate to assure quality~ Presently, there are numerous fire protection improvement initiatives in progress, but they were started late in the period and the results are not yet availabl A concern noted near the ~nd of the previous assessment period regarding the number of inoperable fire protection doors and flow switches that required compensatory measures has been addressed successfully, as evidenced by a decrease in such occurrence A large increase in the numbei of fire protection deviations related to preventive maintenance efforts occurred over an approximately one month perio This may indicate an uneven level of attention given to fire protection equipment over the perio Management involvement in assuring quality in the Appendix R (safe shutdown capability) areas appeared to need improvemen For example, t~e completion of a portion of the associated circuit analyses (letdown high/low pressure spurious signal interface analysis) was documented in April 1988, just prior to the announced regional inspection conducted in May 198 This concern was raised during the previous Appendix R inspection in July 198 Further, it was determined that discrepancies in the table of contents of the post-fire safe shutdown procedure could have potentially hampered the ability*

of the operators to use this procedure under emergency condition Additionally, not all required emergency lighting units had been installed and the licensee had incorrectly taken credit for having the plant D.C. lighting system in place for Appendix R emergency lighting purposes without having analyzed this lighting system 1s acceptability for us...

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The licensee's approach to the resolution of Appendix R technical issues from a safety standpoint appeared to be incomplet The licensee's evaluation -for the VCT outlet valve, M0-2087, indicated that if this valve spuriously opened due to a fire on its control cables, this valve could be manually close NRC review determined that protection to prevent 125-VAC hot shorts on this outlet valve's control cables was not provided as require The licensee's proposed actions and the postulated hot short could have caused the valve to spuriously reopen and ultimately could have affected the hot shutdown makeup capability uf the facilit The licensee's responsiveness to NRC initiatives for Appendix R appeared to be narrowly focused, but generally adequate for distinctive fire protection subject area With regard to Appendix R, the licensee appeared to narrowly focus on NRC identified issues without taking actions to address these issues in a broader manne An example of this is the emergency lighting area in which action had been taken to install lighting units in certain NRC-identified locations, but not in plant wide locatio~ identified by the license Staffing in the fire protection area was adequat The licensee maintained a full-time fire protection supervisor*

during this period who provided direct management oversight and contribute to the general improvement in the area of fire protectio The supervisor was active in performing inspections during the period, as illustrated by the issuance of several deviation reports documenting his finding A review of the fire protection organization included 'the witnessing of an unannounced fire brigade dril The fire drill was determined to be satisfactor The licensee's control of facility combustibles and cleanliness were observed to be adequate during plant tour.

Conclusion The licensee's performance is rated Category 3 in this are The licensee was rated Category 2 in the previous assessment perio The decline in performance is primarily due to deficient management involvement in Appendix R issues, licensee responsiveness to NRC initiatives and approach to resolution of Appendix R technical issue.

Board Recommendation Increased licensee attention to resolution of Appendix R issues is warrante *.

... :......... *_:: Emergency Preparedness Analysis Evaluation of this functional area was based on four inspections conducted by regional inspectors during the assessment perio These inspections consisted of one routine inspection, one special inspection, and observations of both the 1987 and the 1988 annual emergency exercise The 1987 exercise had one weakness; an unacceptable medical dril The 1988 exercise had no identified weaknesse The special inspection was to evaluate the repeated medical drill, and it was found to be acceptabl No violations were identified in this assessment period, as were none in the previous perio The 1987 exercise scenario was uniquely different and challenging in that it included a resin cask spill outside a buifding with the resin flowing toward a lake, which at that point could pollute the local drinking water suppl The 1988 scenario, also unique, included a plant security officer takeQ hostage by a disgruntled employee on the turbine building floo Shift augmentation in the 1988 exercise encountered actual snow-packed roads and fog for those reporting to the plant, and in spite of this, all required positions were filled within the times specified in the Emergency Pla Management involvement in assuring quality performance has been strong in this peri.o Shift augmentation has been _

strengthened by the purchase and installation of an automatic dialing telecomputer system, which was tested successfully in the off-hours, unannounced exercise held in February 198 Management approval was obtained to create a new emergency response position, entitled 11TSC/Security Liaison, 11 which also was well demonstrated in the February 1988 exercis This technical/security interface was a weak point in the 1986 exercis The independent audit program has been improved to include more surveillances, interviews with emergency response personnel, and more in-depth review of the adequacy of the licensee's interface with state and county government agencie The quality of the independent audits has continued to improv They were complete, timely, and thoroug Staffing at the management level has been well maintaine A new Emergency Planning Coordinator (EPC) was appointed June 1, 198 The former EPC will work with his successor and will be available for counseling if neede The new EPC was an emergency preparedness training instructor prior to assuming this positio Responsiveness to NRC initiatives has been aptly demonstrated through cooperative and coordinated efforts between corporate management, plant management, and staff to further improve the

quality of the emergency preparedness progra Management agreed to conduct two additional shift augmentation drills in 1987 as interim measures to demonstrate shift augmentation capability until the new automatic dialing telecomputer system was operabl Plant management has approved the expenditures needed to upgrade the emergency alarm system in the support buildin Corrective actions have been taken promptly on open items, and improvements have been made in other areas of the emergency preparedness program as neede ~"--.t+..._ __.:_.; __ h-...

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successful exercises held within nine month Interviews and walkthroughs with those having emergency response positions have shown that they have good emergency response skills and capabilities to perform in emergency situation The number of lesson plans in the training program are being* reduced to improve training effectivenes These more efficient lesson plans and a revised training matrix should be implemented by January 1, 198 Practice drills and 11table-top 11 training sessions have been increased as part of the emergency training progra Al~o, offsite training for the State of Michigan, as well as VanBuren, Allegan, and Berrien Counties has been conducted by the licensee on a satisfactory basi The Federal Emergency Management Agency (FEMA) has evaluated the February 1988 exercise for the responses of the State of Michigan, and Van Buren, Allegan, and Berrien Counties to the simulated plant emergenc No deficiencies were identified by FEM One item identified for corrective action was that rumor control could have been better demonstrated by the licensee in coordination with the state and the three countie.

Canel us ion The licensee's performance is rated a Category 1 in this are The licensee was rated Category 2 in the previous assessment perio This improvement was.the result of improved exercise performance, management involvement, staffing, training, and interface with offsite emergency response official.

Board Recommendations Non Security Analysis Evaluation of this functional area was based on the results of two routine and one material control and accountability inspection by region-based inspectors and on frequent observatfons of routine security activities by the resident inspe:tor One special inspection was conducted at the

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beginning of the period, but the inspection results were discussed in the SALP 7 repor One allegation involving personnel access control was also reviewed during the period; the allegation was unsubstantiate The licensee also participated in a special headquarters NRC Fitness-for-Duty (FFD) inspectio The purpose of the inspection was to survey a sample of FFD programs nationwide, and therefore the inspection results were not considered in this assessmen Enforcement history was goo One Severity Level IV and one Severity Level V violation were identified compared to six Severity Level IV violations during the previous perio Neither violation had any safety significance, although an example of a personnel access control violation had been identified in the previous assessmen Licensee management initiated aggressive and effective corrective action that resulted in the elimination of access control violations over the last seven months of the perio In the previous assessment period, a concern surfaced regarding the protection of safeguards information (SI).

The licensee effectively eliminated.SI violation~ d~ring this perio Management involvement in assuring a quality security program was goo Management support was evidenced through resource allocations and management accountability for security infractions of subordinate Security equipment (search, intrusion detection) was upgraded and is well maintaine Additional personnel resources were assigned to the security organization enhancing the program's proactivit Security errors committed by plant personnel were dramatically reduced because of plant management support that was obtained, in part, from the inclusion of a requirement in senior site managers* 1988 performance objectives that mandated a 50%

reduction in the number of security errors committed by their personnel in 198 Concerns identified in the previous assessment were effectively addressed by the licensee. Guard force morale continued to improve as a result of efforts by the licensee to integrate security personnel into plant employee activities, benefits, and trainin The lack of a security force contract, another contributing factor to low morale, was eliminated when a new union contract was accepted in August 198 The licensee's approach to security related technical issues was good and improved since the previous assessment perio The licensee's progress in resolving improperly secured security doors was adequate in the pas During this period, however, the licensee implemented a comprehensive resolution that included management support, employee awareness, analysis of door events, and hardware fixes to effectively address the

. security door issu The licensee has also enhanced local law

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.. ~...... ' :. enforcement agency (LLEA) response to security events through increased liaison, LLEA plant familiarization, and contingency plannin The licensee's responsiveness to NRC initiatives was good and demonstrated significant improvement since the previous assessment perio The Property Protection Supervisor was very responsive to resident and region-based inspector concern The licensee efficiently and effectively addressed concerns regarding improperly secured security doors and personnel access contro A1though one personnel access control violation was identified in the previous assessment period, the licensee's corrective action, which was phased into operation beginning in October 1987, was innovative, and effective, and should reduce future occurrences significantl Licensee reporting of security events was goo The licensee revised the security event reporting procedures in October 1987 to address the changes in 10 CFR 73.71 reporting requirement One reporting violation was identified during the previous assessment period, however, all security events this period were reported accurately and in a timely manne The licensee has adopted a conservative approach in analyzing security events and keeps the NRC Well informe Similar analysis should, however, be applied to operational events to assess security implications in a timely fashio The security implications of one event were not considered for 75 days after the event's occurrenc Licensee staffing is goo Positions and responsibilities within the security organization are well-define The licensee added one temporary position to the Property Protection Staf The individual is responsible for collecting, analyzing, and disseminating security dat The analysis has enhanced the proactiveness of the security program through the early identification of potential problems and the efficient.

allocation of security resource The position provides a significant contrib_ution to overall program effectivenes Security force training is goo The training staff is innovative and flexibl They have developed and provided specialized training to improve plant employee compliance with security requirement The licensee is now producing a training video that emphasizes employee awareness of security requirements by high-lighting past compliance problems and discussing appropriate security practice.

Canel us ion Licensee's performance is rated Category 1 in this are The licensee was rated Category 2 in the previous assessment perio This improvement is the result of improved security systems, responsiveness to NRC initiatives, improved enforcement history, and reduction in personnel error.... _*..

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. *.. ** *.::.. _ Board Recommendations Non Outages Analysis Evaluation of this functional area was based on the results of inspections conducted by the resident inspectors and three special inspections of outage planning. outage activitie and followup of the loss of~offsite power even Comments on radiological controls during outages are contained in the paragraph relating to that functional are No refueling was performed, although the spent fuel pool storage system was modifie Enforcement history in this area indicated performance that generally conformed to NRC regulation No violations were identified related to modifications or outage-related activitie No operationcrl events or LERs were identified to be associated with this functional are Outage planning has continued to improve as it receives close management attentio Routine planning meetings are conducted twice daily during plant operation and shutdown. and an update of the forced outage schedule is prepared weekl Outage planning commences over a year in advance and is finalized four months in advanc This advance planning allowed the licensee to move up a recently scheduled maintenance outage by two months to coincide with the forced outage for steam generator tube repair and to complete the outage on schedul This was due in part to well-planned and executed scheduling of work and manpowe In addition, critical path items and post outage testing were adequately addres*se Implementation of the "system window

concept for work was enhanced both by the operational control of equipment as well as outage efficienc However, management involvement with contractor training and supervision of work activities was noted to be wea Good management involvement was evident in the assignment of 11onshift 11 managers who were given authority to make decisions, in place of the Plant Manag~r and were also held responsible for keeping the outage on schedule by resolving issues that affected productivity, while maintaining requisite qualit The licensee's approach to resolution of technical issues from a safety standpoint continued the improvement evide.nced at the close of the previous assessment perio Considerable management attention is devoted to the review of technical issues with appropriate documentation for deferral of any issues before plant startu An excellent example of licensee initiative was the redesign and early scheduling of modifications to the offsite power system after a loss of offsite power during this perio ~.

-;-

.

... **... --~-,_.: :..

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

~~-,~... *.:...

Licensee responsiveness to NRC issues in the area of outages was very goo Continued progress in resolving Material Condition Task Force and System Functional Evaluation items was note Plant restart has continued to receive detailed reviews by senior management to assure reliable plant operation upon return to powe Staffing levels were adequate for all tasks, but plant-wide outages required approximately three times more overtime than normal during non-outage peri~ds. Nevertheless, Palisades use of overtime consistently was below the national averag ne licensee is planning to utilize additional contractor resources during upcoming outage For example, refueling is being contracted to Combustion Engineerin.

Conclusion The licensee 1s performance is rated a Category 1 in this are The licensee was rated Category 2 in the previous assessment perio This improvement was the result of improved outage planning, imp_rovement in resolution of technical issues, and responsiveness to NRC issue.

Board Recommendations Non Engineering/Technical Support Analysis This is a new functional area and consequently was not rated in previous SALP Evaluation of this functional area was based on the results of two inspections conducted by region-based inspectors, one Augmented Inspection Team (AIT) formed as a result of a loss of all offsite power event, observations during routine resident inspections, and evaluation of licensee technical submittals by NRC headquarters technical reviewer Activities examined during these reviews included review of the loss of offsite power event after Startup Transformer 1-2 failed, implementation review of the Salem Anticipated Transient without scram (ATWS) initiatives of Generic Letter 83-28, and review of the licensee 1s Configuration Control Project (CCP).

Enforcement history during the current assessment period was good, with one Severity Level IV violation identified for failure to properly implement ASME Secti.on XI testing for certain valves because the Section XI Engineer was not aware that the valves required active closure during ~n acciden This violation was not of major significance programmatically, and licensee corrective actions were adequate after the violation was issued; however, this item had been brought to the attention of licensee management in February 1987, but no action was taken until the violation was issued in June 198 ~---~~~--------------

.

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Management involvement in assuring quality was goo The licensee had embarked on a CCP to ensure accurate plant drawings and develop a central design bases for several plant system The activities associated with the CCP demonstrated consistent prior planning and assignment of prioritie Assignment of management responsibility and decision making were at a level that ensured adequate management revie Progress to date indicated that the purpose and objectives of the CCP were being met~

The licensee's engineers and manag~ment personnel contacted during the AIT were receptive, solution oriented, and open-minde Although the offsite power distribution system in place at the time of the event met General Design Criterion 17, the licensee initiated modifications to enhance offsite power supply reliabilit Continuing the positive trend in resolving technical issues, the licensee pursued solutions to numerous long-standing problems, most of which were original design deficiencies, such as the reliability of the electrohydraulic control system on the turbine, the safeguards air compressors and air system, the safety injection tank and other instrumentation, the diesel generator, the shutdown and design basis event sequencers, remote shutdown panel design and installation errors, offsite power distribution, and primary coolant pump motor oil leakag Effective action to redesign or upgrade the above problems have either been completed or scheduled for completion in the licensee's five year pla Management response to the loss of offsite power event, both short-and long-term was excellen Engineering support staffing continued to receive periodic management review to ensure adequac Staff reassignments were made when necessar The onsite availability of system engineers assigned to specific systems permits daily involvement in system maintenance and operation This concept was providing good results and was supported by management with adequate resources, improved training, and rotational opportunitie Several former or active licensed senior reactor operators are among the cadre of system engineer As discussed under Maintenance, the Valve Improvement Program was well supported with consultant and in-house engineering expertise and had resulted in a significant improvement in valve conditio The key positions, both in engineering and on the CCP, were clearly identified, with authorities and responsibilities well-define Expertise was usually available within the staff, and when required, appropriate use was made of consultant Coordination between consultants and staff appeared to be effective. Weaknesses were noted in the level of support given to licensing issues and issues associated with Appendix R; however, overall staffing levels were acceptabl... :***. -.:.-... :.

The approach to resolution of technical issues from a safety standpoint was goo Engineering support was involved in detailed studies of check valve, relief valve, and control valve applications as part of the progra CCP personnel and technical personnel demonstrated clear understanding of the issues and provided technically sound and thorough approach in almost all case Conservatism was routinely exhibite Design issues were usually reviewed and resolved in a timely manne However, safety evaluations performed by the site reflected a wide range of quality, with some barely providing sufficient information to determine the bases for conclusions stated in the evaluatio The quality of the evaluations tended to be directly related to the individual who performed the evaluatio The licensee revised the safety review

procedures to correct this proble Responsiveness to NRC initiatives was very goo The CCP represented a viable and expanded approach in response to NRC request The scope of the CCP, the timely action on the elements of design basis review, plant electrical as-built walkdowns, an_d resolution of problems, were all examples of responsiveness to previously recognized areas of concern.*

There were eight LERs attributed to this area resulting from equipment related failure Half of these were considered preventable by prior engineering attention when precursors to the failure created the opportunity for corrective actio These four included a forced shutdown due to loss of oil from a primary coolant pump motor, a reactor trip after electrohydraulic flexible hose ruptured, operation outside the design basis for charging pumps, and failure of the diesel fuel oil tank level instrument. These issues did not collectively represent significant weaknesses in the licensee's engineering*

support, but were considered benchmarks on the learning curv.

Conclusions The licensee's performance is rated Category 2 in this are Because this is a new area, the licensee was not rated for the previous assessment perio.

Board Recommendations Non Licensing Activities Analysis Evaluation of this functional area was based on the licensee's performance in support of licensing action These actions consist of license amendments, including changes to the Technical Specifications, exemptions, reliefs from commitments

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or Code requirements, responses to generic letters, TMI action items, and other multi-plant issue There were 19 such actions completed during this assessment perio The licensee's management has generally been supportive of and involved in the licensing activities for Palisades, particularly the major items; however, the anticipated progress in working on the backlog of Technical Specification changes has not occurre Management's influence and participation in actions of immediate concern are evident and very effectiv The more routine licensing actions do not appear to get sufficient management attentio For example, by letter dated March 5, 1986, the licensee asked that six of their applications for Technical Specification changes be placed on "hold 11 because they i n_tended to *revise the proposals, but no revised proposals have been submitte These.include some changes in Technical Specifications in response1 to NUREG-0737, "Cl arifi cat ion of TMI Action Pi'an Requirements."

I In a couple of instances, planning and scheduling of licensing actions were not satisfactor The reactor protection system modificationsubmittal is one of thes A draft submittal was sent by letter dated December 23, 1987, but it did not include the accident and transient reanalysi A March 25, 1988 submittal was then made to complete the application; however, because all of the supporting technical information was in documents to be withheld from the public, there was insufficient information for a member of the public to participate in the determination of whether a significant hazards consideration was involve The licensee then provided non-proprietary versions by submittal dated May 4, 198 These were inadequate to meet the criteria of 10 CFR 2.79 The issuance of a notice was unnecessarily delaye The other instance was not submitting an amendment request to delete secondary water chemistry requirements from the Technical Specifications until it was needed in a very short time frame, forcing an exigent notice to be issue The licensee is presently considering a broad scope revision to improve all the Technical Specifications and has scheduled a meeting with the NRC Technical Specifications Improvement Program management to pursue this proposa This effort, if agreed to, may include the backlogged items that do not have to meet an early schedul This interest indicates management's active involvement in attempting to assure quality, provided a timely schedule for completion can be me The licensee's approach to resolution of technical issues from a safety standpoint was technically sound and very thoroug The licensee demonstrated an understanding of the issues, exhibited conservatism, and provided viable, sound and thorough approache The evaluations for determining whether a significant hazards consideration is involved in an amendment

f'

application have improved considerably to the point that they are used without change by the NRC in the Federal Register notice of the preliminary determinatio The licensee's analyses and submittals for augmented inspection of the steam generators, control of heavy loads, and spent fuel storage expansion were very good examples of detailed, thorough, and conservative approache The communications between the licensee's engineers and the NRC technical staff were excellen The licensee is generally responsiv This is especially true nf ;nfnrm:::il ron11oc:+c: m::itio h\\I i-ho 1.;rone.;nn.,,-t-.,-f'-f'*

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appears to be a lack of timely technical support in some area As previously stated, the proposed amendments put on 11 hold 11 on March 5, 1986, have not been resubmitte A commitment made in 1982 to resolve a containment isolation valve deviation from FSAR criteria has not been accomplished and, in a few instances, responses have to be delayed because the responsible engineer was working on another issu Otherwise, the responses have been timely, accurate, and of proper scop There appear~ to be a lack of staffing to support work on backlogged changes to the Technical Specification The major actions and those that might impact plant availability are handled very well, but this leaves no resources for the items of less significance. It is questionable, therefore, as to how the broad scope revision to improve all the Technical Specifications, being considered by the licensee, will be supported and how that could impact the schedules for individual Technical Specification changes that are neede.

Conclusion The licensee's performance is rated Category 2 in this area, with a declining tren The licensee was rated Category 2 in the previous assessment perio The declining trend is due to insufficient details in routine license amendment submittal.

Board Recommendations The board recommends that increased licensee management and technical resources be applied to both the backlog of licensing actions and the proposed effort for Technical Specification improvement if an acceptable action plan for the latter can be agreed to by the licensee and the NR It is noted that if the Technical Specification improvement effort is undertaken, the need to address certain items of the backlog will no longer be necessar However, if the improvement effort is not undertaken, resource commitments must be applied to the backlog and any new items that may aris... *:, *1.;.' :..*.. :. ',...... -~.*. ::.. ~:* **.. :.:.:;.;...., --~\\.. ~... *. Training and Qualification Effectiveness Analysis Evaluation of this functional area was based on resident, regional, and headquarters inspections evaluating the effectiveness of training and qualification of specific program areas and licensed operator replacement exam One inspection was conducted to audit the licensee's INPO accredit~d tr~ining program Enforcement history in this area was acceptabl No violation of training program requirements were identified during this assessment perio One violation involving performance of a surveillance test appeared to be due, in part, to inadequate training which had trained technicians in performance of only a selection of the test Licensee corrective actions are not complete but appear to be well directed toward procedure, training program, and human factor improvement A sample of twelve operational events involving personnel error were reviewe Of these, the licensee determined that four events were a result of training deficiencie Corrective actions appropriate to the circumstances were taken in each cas Management involvement in ensuring the quality of the training program was generally adequate, but varied by departmen Instrument and Controls training was considered weak (based on the violation referenced above), while Operations and Maintenance were notably strong and improvin As discussed in the previous assessment period, maintenance training facilities and training programs have been added and enhanced on an as-needed basi The licensee's training and qualification program for technicians and engineering staff includes hands on training in the licensee's local training facility using plant-replicate equipmen In addition, the plant technical staff is able to use this equipment to dry-run complicated or ALARA-related task Palisades computerized work order system has the unique requirement printed on work orders for the job supervisor to verify the training and qualifications of each person assigned to that work order to document the verification of the work orde Operations management continues to attend *

operator simulator and off-shift training to reinforce expectations and maintain consistent perforn:iance among all shift The licensee continues to make good use of its plant-specific simulator by using it to train engineers and auxiliary operators on system In an effort to improve the incorporation of industry experience into the training programs, a standing committee was organized to review industry and NRC communications regarding potentially generic information for incorporation into the various training program Management involvement to assure quality was also evident based on the

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results of operator licensing exams and an NRC requalification exam administered during the perio All candidates passed their exams and the facility licensed operator requalification program was declared satisfactory. This success rate is an improvement over the previous assessment period and demonstrates a strong commitment by the licensee to operator trainin In response to a series of findings related to inadequate 10 CFR 50.59 reviews, a formal training program was conducted under contract to AVCA Corporatio The training was of good quality and incorporated several aids that 5houlct, along with a revised licensee procedure, improve the quality of reviews and evaluation However, the effectiveness of this training is in question as discussed in the Quality Program Sectio Good responsiveness was also shown in correcting identified emergency plan training deficiencie Final full accreditation by INPO of all training program areas was received during this perio The Mechanical Maintenance and Licensed Operator training programs were reviewed against NRC 1s 11Training Review and Criteria and Procedures 11 (NUREG-1220 June 1986). lhe utility has made good progress in imp 1 ement irig the five essential elements of performance-based trainin There is clear management supprirt for the Training Department and the accreditation effor Interviews with operations staff confirmed that training has improve During the audit conducted after INPO accreditation, several problems were identified in the maintenance training program Because skill training is conducted at multiple locations, retrieval of records is difficul In addition, some of the criteria dealing with compromise of examinations were not fully met (that is, insufficient variation in test questions, students grading their own quizzes.) However, the audit determined that the training facilities at Palisades were adequate and training materials were well-developed for the two programs reviewe Although Palisades has a plant-referenced simulator located at Midland, licensed operators have indicated that* its distant location to the plant has limited its full usefulness as a training too The training programs and the implementation of a systematic approach to training are well-supported by detailed procedure Training department personnel are well-qualified to carry out their various function On the average, Palisades has made satisfactory progress in meeting its commitment to performance-based trainin Staffing was adequate for all functions performed and no deficiencies were identified in this regar,\\.

Conclusion The licensee's performance is rated Category 2 in this are The licensee was rated of Category 2 in the previous assessment perio.

Board Recommendations Non Quality Programs and Administrative Controis Affecting n.. _,..:..._,...

1:,!UQ I I ".l Analysis The evaluation of this area addresses two related, but separate function First, it assesses the licensee's management activities aimed at achieving quality in overall plant operation This assessment in great measure is a reflection of the quality of licensee activities in individual functional areas addressed in other sections of this repor Secondly, thi~ section assesses the licensee's internal, independent quality oversight activities such as those performed by the quality control/quality assurance organization With respect to the evaluation of management's effectiveness in achieving high quality in operation of the facility, a wide range of subjective and objective performance measures and compliance history in all the functional areas were assesse This evaluation revealed that over the last several assessment periods, licensee management's approach to plant operations, while acceptable in considering nuclear safety, emphasized minimal expenditure of resources necessary to satisfy regulatory requirements or initiatives. This trend was seen to be reversing during the last and most recent periods when increasing resources were committed to improving plant material conditio Management support and involvement from the corporate level was evident in most SALP areas as illustrated by the results discussed in the functional area Specifically, the

Configuration Control Project (CCP) is viewed as an excellent initiative, for which continued support is encourage Improvement is noted in the reduced number of enforcement actions taken this period, a positive indicator of general improvement in the quality of activities. Other performance improvements noted include outage planning, security equipment enhancement with an overall reduction in personnel errors and improved emergency preparedness as demonstrated in exercise response, training, staffing, and interface with offsite official Indicators of licensee initiative include taking early action in the development of a fitness-for-duty program, a pipe wall thinning inspection program that had already been developed when the Surry event occurred, and planning a major

. ~ _

. -* '_... :,:..:.,_,, '..... __ *... ~* *-.

offsite power modification prior to the NRC issuance of a blackout rul Corporate management was instrumental in the establishment of policies and incentives that reduced the employee turnover rate to one third of the 1985 rat Management support has not only reduced this rate, but given plant personnel confidence in their ability to carry out plans and meet goal Generally comprehensive and timely actions are taken by management when problem areas are identifie Examples of this include contracting a training course for 10 CFR 50.59 change evaluations and initiating changes to improve procedure qualit Weaknesses identified during this period include a poor effort in resolving certain engineering issues such as Appendix R, revising LERs (only one of ten revised by the end of the period),

and support of licensing action The NRC perceives that most of these weaknesses are a result of limited staffing to support the many improvement initiative Lack of procedural adequacy,

.accuracy, and compliance were responsible for a number of events at Palisades during this perio Corrective action (adequacy and timeliness), root cause determination, and evaluation/review comprised another trouble spot that intersected numerous functional area With respect to evaluation of the licensee 1s internal and independent quality oversight activities, results of routine inspections conducted by the resident inspectors were considere The enforcement history in the Quality Assurance Program area indicates that performance was in conformance to regulatory requirements, with the exception of the 10 CFR 50.59 Severity Level IV violation cited late in the perio Management involvement in the Quality Program area was generally effective in directing resources to focus on problem areas in most functional area~. Audit plans were appropriately tailored and surveillances were conducted that were effective in bringing improvements in a number of area Technical audits utilized appropriately qualified personnel (SROs and engineers) where appropriat Goals set by management for reductions in various backlogs were generally met or exceede The procurement and receipt inspection area was reorganized this year to facilitate material support for plant activitie The licensee 1s approach to resolution of technical issues from a safety standpoint improved during the assessment period, specifically in the quality of review given to issues by the Corrective Action Review Board and the Plant Review Committe Generally, timely reviews are conducted of identified issues that are evaluated for potential impact on operation Key issues are assigned for resolution before appropriate deadline Conservative management judgement was exhibited in the prompt proposal for extensive modifications to offsite power sources to increase reliability following the lengthy loss of offsite power that occurred in July 198 The proposed modifications

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went well beyond the m1n1mum measures needed to alleviate the concerns at the-time and should put the plant in a favorable position for meeting the stations blackout rul Responsiveness to NRC issues was evaluated by the inspectors review of licensee actions and recommendations made in response to NRC bulletins, information notices, and generic letters by the Safety Engineering Grou It was found that the generic communications that do not require a response received a 1esser level of review, which in some cases would have been unsatisfactory, had other outside organizations not requested a more rigorous revie The lack of adequate 10 CFR 50.59 reviews was a continuing problem are The evaluations of changes to the facility and procedure required by 10 CFR 50.5 were audited and found to have a wide variation in scope, completeness, and adequac The procedures for doing these evaluations have been revised and should correct the inadequacies identified. Training was conducted for all onsite and offsite personnel involved in performing or reviewing these evaluations and was judged to be of very good qualit Events involving quality activities were largely self-identified by the licensee and minor in natur Corrective actions were generally adequate and timel Staffing in the quality program area appeared to be satisfactory for accomplishment of the assigned responsibilities and management initiative As mentioned previously; the realignment that established the Material Services Group should have a positive effec.

Conclusion The licensee's performance is rated Category 2 in this are The licensee was rated Category 3 in the previous assessment perio This improvement is due to increased management emphasis on quality and the overall enhancement of plant material conditio.

Board Recommendations Non _,

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- - -*~* _*....... :....... :........... :_._,.:.~........... -:.. >)..,;:;~.. --- }.. SUPPORTING DATA AND SUMMARIES Licensee Activities During the first five months of this SALP 8 assessment period, Palisades operated routinely at various power levels as a result of a number of forced outages and power reduction Two scheduled maintenance testing outages were conducted during this assessment perio The plant engaged in normal operation until the end of the assessment perio The next refueling and maintenance outage is scheduled for September 198 Significant Outages/Major Events May 16-20, 1987 - The unit was shutdown because a pressurizer spray valve was stuck partially ope I May 22, 1987 - The unit was manually tripped due to an operator error that blew the rupture disc on a feedwater pum..

June 20-25, 1987 - The unit was rapidly taken offline due to an electro-hydraulic control (EHC) leak on the No. 4 governor valv A 2/3 circumferential thru-wall EHC tubing crack was found, and the unit remained shutdown to perform dye penetrant tests, replace the carbon steel manifolds, and add fine mesh air filters for two feedwater regulating valve.

July 10-13, 1987 - The unit was manually tripped due to a primary coolant pump motor oil lea The unit remained shutdown to replace a cracked primary coolant pump backstop oil piping, adjustment of the closing stripping preload on the 11A 11 main feed pump (MFP) trip and throttle valve, rebuild the MFP recirculation valve, and capping off the No. 4 governor valv.

July 14-26, 1987 - The reactor was manually tripped when the plant lost all offsite power as a result of a ground fault in one of three startup transformer Offsite power was lost for approximately seven hour An Augmented Inspection Team (AIT)

was dispatche.

August 15, 1987 - The turbine was taken offline to fill the 118 11 primary coolant pump oil reservoi.

August 17-19, 1987 - The unit was manually tripped due to an EHC leak on the governor valv The unit remained shutdown to correct generator voltage control problem.

August 23-25, 1987 - The unit was out of service after a trip to repair the voltage regulator on the main generator whose failure had caused the tri.. ;.*..... ::..\\*

.*. "********"'" October 1 through November 13, 1987 - The unit was shutdown for a scheduled maintenance/testing outage in response to an unisolable steam leak on a moisture separator reheater vent lin This was the first specific maintenance outage for Palisades, and it reflected the licensee's decision to accelerate their improvement program for the plant material conditio Major activities included valve work, local leak rate testing, tendon tests, replacement of the atmospheric dump valves, and turbine EHC fluid upgrad.

December 4, 1987 through January 27, 1988 - The unit was shutdown due to a primary-to-secondary system leak in the 118 11 steam generato The licensee began a scheduled maintenance/testing outage immediatel Major activities included steam generator eddy current and leak testing, sludge lancing and tube plugging, fuel handling system upgrade, cooling tower work, valve improvement, Limitorque valve maintenance, and local leak rate testin.

April 27 through May 2, 1988 - On April 27, 1988, the unit was shutdown foll.owing Control Rod No. 6 dropping into the core due to the failure of the control rod drive mechanis The licensee decided to remain shutdown to replace the control rod drive assembl Palisades experienced seven engineered safety feature (ESF) actuations and five reactor scrams from power (four manual and one automatic).

Two of the reactors scrams were the result of personnel errors and six of the ESF actuations were due to personnel errors or procedure defi ci enci e Inspection Activities Thirty-seven inspection reports are addressed in this SALP report (May 1, 1987 through May 31, 1988) and are listed in Paragraph 1 of this section, Inspection Dat Table 1 lists the violation's Severity level per functional are Significant inspection activities are listed in Paragraph 2 of this section, Special Inspection Summar.

Inspect ion Data Facility Name:

Palisades Docket No. 50-255 Inspection Reports No. 87009 through 87032 (excluding 87013),

88002 through 88015

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TABLE 1 Number of Violations in Each Severity Level Functional Areas I Plant Operations Radiological Controls Maintenance Surveillance Fire Protection Emergency Preparedness Security Outages Engineering/Technical Support Licensing Activities Training and Qualification Effectiveness Quality and Program and Administrative Controls Affecting Quality II III IV

2

1 4**

1

.... _..... *.....

v DEV

1 TOTALS I

II

III

""*"

IV

v I

DEV T

A violation has not been issued, but escalated enfor~ement is being considered for 255/88012 in Fire Protectio **Three of these violations were discussed in SALP 7, Section.

Special Inspection Summary An emergency preparedness exercise inspection was conducted during May 18-20, 1987 (Inspection Report No. 255/87012). An AIT inspection was conducted relating to the loss of all offsite power resulting from the failure of an insulator on a star~up transformer during July 14-16, 1987 (Inspection Report No. 255/87019). A Fitness-for-Duty team inspection was conducted during August 24-28, 1987 (Inspection Report No. 255/87021). A special team inspection of the continuing progress of the material condition of the Palisades facility was conducted during October 26-30 and December 17, 1987 (Inspection Report No. 255/87027). An emergency preparedness exercise was conducted during February 16-18, 1988 (Inspection Report No. 255/88002).

~-.... A special inspection was conducted on fire protection issues during May 9-18, 198 This is a potential escalated enforcement case, but no violations were issued during this assessment period (Inspection Report No. 255/88012). Investigation and Allegations Review Five allegations were reported during this assessment perio All of the five allegations, and one previously reported allegation were close No allegations remained open at th~ end of the assessment perio Escalated Enforcement Actions No escalated enforcement actions were issued to Palisades during this assessment period (that is, no Severity Level III violations were issued, no proposed/imposed civil penalties were issued, and no civil penalti~s were paid to the NRC by Palisades). Licensee Conference Held During Assessment Period On July 8, 1987, a management meeting was held at the site with licensee representatives to discuss the license~'s current plan activities including the configuration management program and preventive maintenance progra.

On July 21, 1987, a management meeting* was held in.the Region III office with licensee representatives to discuss the July 15, 1987 loss of offsite power even.

On August 25, 1987, a management meeting was held in the Region III office with licensee representatives to discuss general concerns regarding the configuration management program and plant events relating to several deficiencies found in components and system The licensee provided a status report of their activities and commitm~nts associated with a 10 CFR 50.54(f) CAL, dated May 21, 1986, regarding equipment conditions at Palisade.

On October 1, 1987, a management meeting was held with licensee representatives at the site to discuss the findings of the

__ Systematic Assessment of Licensee Performance (SALP 7) for November 1, 1985 through April 30, 198.

On December 4, 1987, a site tour was conducted for Commissioner Rogers and a management meeting was held with license representatives at the site to observe and discuss general operating concern.

On February 17, 1988, the licensee presented the proposed reactor protection system modification to the Office of Nuclear Reactor Regulation in the Headquarters offic ~. *.. :. *.*..

'... -....,,... *,.

~- On March 1, 1988, a quarterly management meeting was held at the site with licensee representatives to discuss general plant events and the status of the configuration management progra.

On March 31, 1988, a quarterly management meeting was held at the site with licensee representatives to review the status and progress of the Palisades plant, and to discuss the status on the licensee's corrective action plan to restore the original design margin to the component cooling water and service water systems, the scope of wo1k planned for the 1988 refueling outage, and summary of the last INPO evaluation.

On April 11, 1988, a meeting was held in the Region III office with licensee representatives to discuss the proposed plan to centralize onsite procurement and material processing responsibilitie Confirmatory Action Letters (CALs)

No Confirmatory Action Letters were issued during this assessment perio A Review of 10 CFR Part 21 Reports and Licensee Event Reports (LERs)

Submitted by the Licensee CFR Part 21 Reports Three Part 21 reports were filed by the licensee: An ITE circuit breaker was identified as having been improperly assembled by a subcontractor to Brown Boveri Electric which resulted in an operating failur A Malinkrodt boron standard was found to be inaccurate during us Ashcroft gauges were failing repeatedly in the diesel generator field oil system, apparently due to manufacturing defect.

Licensee Event Reports (LERs)

Thirty-five LERs were issued for Palisades for events occurring during this assessment perio Docket No. 50-255 LER Nos. 87015 through 87040 and 88001 through 8800 A comparison table of cause code evaluations for Palisades SALP 7 and SALP 8 is shown below:

Cause Code Personnel Error Procedure Deficiency Design Inadequacies Component Failures External Cause Other/Unknown Frequency of Issuance (18 Mo)

SALP 7 41. 0% (25)

8.2% ( 5)

14.8% ( 9)

16-4% (10)

1. 6% ( 1)

18.0% (11)

100 % (61)

3.4/Mo (13 Mo)

SALP 8 51. 4% (18)

14.3% ( 5)

8.6% ( 3)

25.7% ( 9)

0% ( O)

100 % (35)

2.7/Mo NOTE:

The above information was derived from reviews of Licensee Event Reports performed by NRC staff and may not completely coincide with the unit or cause assignments which the licensee would mak In addition, these tables are based on assigning one cause code for each LER and does not necessarily ~orrespond to the identification of LERs addressed in the Performance Analysis Section (Section IV) where multiple cause codes can be assigned to each even NRR Activities NRR Site Visits and Meetings with Corporate Management June 24, 1987 - at Palisades - Corrective measures for equipment failure July 6, 1987 - at Palisades - Review 50.59 evaluation August 25, 1987 - at Region III - Quarterly management meeting with license October 29-30, 1987 - at Palisades - Maintenance inspection exit meeting and licensing meeting with plant managemen.

Commission Meetings - Non.

Schedule Extensions Granted - September 17, 1987 - Schedule of Appendix J ILRT extende.

Reliefs Granted - Non.

Exemptions Granted - September 17, 1987 - Exemption to schedule requirements of Appendix.

Orders Issued - Non......

i *** Emergency/Exigent Technical Specifications - February 1, 1988 - Delete water chemistry requirements for secondary side of steam generator.

License Amendments Issued Amendment N Description Spent Fuel Storage Expansion Steam Generator Inspection Interval Deletion of Snubber Tables Administrative Controls Tendon Surveillance Deletion of SIG Water Chemistry Limits Controls of Heavy Loads Steam Generator Augmented Inspection SiT Sampling

Date 07/24/87 nn l'>C IOI UO/ ~U/ UI 10/20/87 10/21/87 10/28/87 02/01/88 03/01/88 03/24/88 03/24/88

v t e Inspection Report - Palisades - 1988001
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
1988 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 9(0) 10(0) 11(0) 12(0) 13(0) 15(0) 16(0) 17(0) 18(0) 19(0) 20(0) 21(0) 22(0) 23(0) 24(0) 25(0) 26(0) 27(0) Security Operator Exams Emergency Planning Other

IR 05000255/1988001

Text

REGION III

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