IR 05000255/1989001
| ML18054B090 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/03/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054B089 | List: |
| References | |
| 50-255-89-01, 50-255-89-1, NUDOCS 8911150217 | |
| Download: ML18054B090 (30) | |
Text
SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-255,f~
Inspectio~ Consumers Power Company Name of Licensee Palisades Nuclear Generating Plant Name of Facility June 1, 1988, to August 31, 1989 Assessment Period SALP 9
- SUMMARY OF RESULTS Overview Ov~rall performance remained essentially the same as the previous SALP perio The areas of Operation & Maintenance/Surveillance received Category 2 ratings with improving trend The 2 rating for Maintenance/Surveillance was weighted toward the maintenance area due to weakness in maintenance training combined with poor controls established during work on containment isolation valve The areas of t.n "n
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The performance ratings during the previous assessment period and this assessment period according to functional areas are given below:
Functional Area Plant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Safety ~ssessment/Quality Verificaticn N/R - Not Rated Other Areas of Interest None *
Rating Last Period 2 (improving)
2/1
1
N/R Rating Th.is Period Trend
improving
2 improving
1
2
III. CRITERIA Licensee performance is assessed in selected functional area Functional areas normally represent areas significant to nuclear safety and the environmen Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were used to assess each functional area: Assurance of quality, including management involvement and control; Approach to the identification and resolution of technical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement history; Operational events (including response to, analyses of, reporting of, and corrective actions for); Staffing (including management); and Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have been used where appropriat On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categorie The definitions of these performance categories are as follows:
Category 1:
Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirement Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieve Reduced NRC attention may be appropriat Category 2:
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are goo The licensee has attained a level of performance above that needed to meet regulatory requirement Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieve NRC attention may be maintained at normal level Category 3:
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficien The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirement Licensee resources appear to be strained or not effectively use NRC attention should be increased above normal level *
The SALP Report may include an appraisal of the performance trend in a functional area for use as a predictive indicato Licensee performance during assessment period should be examined to determine whether a trend exist Normally, this performance trend should only be used if both a definite trend is ciiscernable and continuation of the trend may result in a change in performance ratin The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving during the assessment perio Declining:
Licensee performance was determined to be declining during the assessment period, and the licensee had not taken meaningful steps to address this pattern.
I PERFORMANCE ANALYSIS Plant Operations Analysis Evaluation of this functional area was based on the results of 16 routine inspections by resident and regional inspectors, 1 special emergency operating procedure (EOP) team inspection, a requalification examination, and a replacement examinatio Plant nnPY'~tiranc Anrf f'i nV"n+or+;nr~ l.. 1.0.V'o rnnc-il'lo.V'.crf
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areas in the previous assessment periods, but have been combined as one functional area for this assessment perio Enforcement history in this functional area was excellent and showed improvement from the previous perio One Severity Level IV violation and a deviation were identified during the current 15-month assessment period, which compares favorably with the one Severity Level IV violation identified in the operations area and one Severity Level III violation identified in the fire protection area during the previous 13-month assessment perio The Severity-Level IV violation was issued for inadequate training of auxiliary operators (AOs) on the EOP A deviation was issued for an unsealed penetration openfog into electrical equipment in an area protected by a fire suppression syste The deviation was not safety significan There were several events pertaining to operations during the assessment period that involved procedural inadequacies and personnel error The procedural inadequacies involved the opening of the pressurizer power operated relief valves while heating u The events that occurred as a result of personnel error had no safety significanc Management involvement was evident in achieving improved equipment reliability by the reduced number of trips during this assessment perio Only one reactor trip was at power and resulted from a feedwater control system fuse failure. This is significant improvement over the five at power trips that occurred during the previous assessment perio During off-normal plant operational events, the operators demonstrated good plant knowledge by initiation of corrective measures in a timely and appropriate manne For example, during a routine maintenance activity, which resulted in a loss of condenser vacuum, the operators diagnosed and corrected the problem before a reactor trip occurre Additionally, during a refueling outage in which a fuel bundle unexpectedly became stuck within the upper-guide structure, an alert operator stopped the operation before the bundle was removed from the wate Operations management demonstrated effectiveness in dealing with unexpected situations involving refueling activities and preventing any serious consequence *
Management involvement in the assurance of quality was goo Initiatives implemented during previous assessment periods remain in effec These included achievement of a black board condition, routine site visits by corporate officials, direct involvement of the Operations Superintendent in training, equipment status review by the Plant Review Committee, and daily communication with corporate managemen These efforts continue to e~hance overall plant performance improvement During the recent appraisal period management involvement was typified by:
the conduct of management review boards to evaluate human performance problems, a valve checklist up9rade program, predictive trending and monitoring which input to prioritizing and scheduling maintenance activities to maximize equipm~~t availability, and fostering an attitude of how can this be done better/smarter" among the operations grou Containment cleanliness was a weakness that required management attentio There were numerous areas in containment covered by graffetti (in moderate radiation areas) and numerous miscellaneous items (tie wraps, nails, tools, and a thermometer) were left in the containmen On at least one occasion, items were found in and removed from the containment sum Implementation of procedures for general plant cleanliness and control of combustibles was considered to be improving; however, additional initiatives are necessary to bring overall plant cleanliness to the standards set by the licensee.
Management involvement in assuring quality for EOPs was adequat No unsafe operational conditions were identifie Operators utilizing the EOPs were generally able to perform their inte~ded tasks; however, several minor discrepancies were found regarding technical issues and human factors element The licensee's approach to resolution of technical issues from a safety standpoint was goo The decision to shut the plant down when steam generato~~leakage approached a fraction of the allowable, the power reduction to reduce steam generator tube degradation, the evaluation performed to implement a power increase, and the resolution of the stuck fuel bundle were well thought out and appropriately planned, reflecting a conservative approach to plant operation Analysis conducted by the licensee demonstrated that the current design of the service water system met the analyzed safety margin However, the licensee's decision to delay plans for the addition _of a fourth service water pump is viewed as adversely impacting routine plant operation by complicating the operators job (e.g., maintaining cooling flow requires throttling one system's flow to provide another).
Another example was the inadequate action taken to maintain the required tank level after it was discovered that the emergency diesel generators fuel oil tank must be maintained ~early full.
Technical fire protection expertise from corporate engineering was available when necessary and provided timely and sufficiently detailed evaluation The effectiveness of the licensee 1s training and qualification programs was mixe The licensee succeeded in preparing and maintaining the required knowledge and expertise for licensed duties, as evidenced by a 100% pass rate for both the replacement and requalification examination Operators spend 13 days at the simulator per yea The Palisades simulator is located approximately 190 miles from the site which detracts from its overal I ettectiveness Tor routine use in tne cievelopmen~ anu verification of plant procedure Licensed operators knowledge of the EOPs was found to be more than adequate to implement the EOPs, but some reactor operators (ROs) expressed a desire for additional training before they could recommend a prudent course of action that was not specifically delineated in the EOP As stated earlier, AO training was less than adequate and required remedial efforts to upgrade on-the-job trainin.
Performance Rating The licensee 1 s performance is rated Category 2 with an improving trend in this are The licensee 1 s performance was rated Category 2 with an improving trend in the previous assessment period.
Recommendations Non Radiological Controls Analysis Evaluation of this functional area was based on the results of four inspections performed during this assessment period by regional inspectors and observations made by resident inspector Enforcement history in this area was not significantly changed from that of the pr.evious assessment perio Three Severity Level IV violations were identified during this 15-month period, compared with two Severity Level IV violations identified during the previous 13-month assessment perio Two violations, regarding inadequate entry control for high radiation areas (HRAs) of greater than 1 R/hour, represent a weakness that also existed during the previous two assessment period The third violation was a radwaste shipping problem that represents a transportation issue continuing from the previous SALP period.
- Staffing was generally adequate, with radiation protection (RP)
staffing being better than chemistry staffin The turnover rate for the RP technician staff continues to be low with well-qualified replacement The RP staff was reinforced with the addition of a radiological engineer and expansion of the radwaste/decontamination crew from 7 to 12 member In contrast, the licensee augmented the RP staff with contracted personnel during the fall 1988 outage at levels less than projected need Chemistry staffing was in a transitional period due to the appointment of a new chemistry superintenden In addition, a number of chemistry technicians were not ANSI-qualified due to turnover. Overall laborato-ry supervision, howeve.r, was experienced and appeared to be adequat RP training improved significantly during this assessment period, including establishment of an RP curriculu~ committee to review and evaluate training effectiveness, development of a formal radwaste worker training and qualification program, institution of an ALARA engineering course for design/system engineers, and introduction of a summer internship progra Management support of RP and radwaste programs was generally good with resultant improvements in several areas, although some areas appeared to require additional management attentio Management initiated improvem~nts includ~d a significant reduction of personnel contamination events (PCEs) in 1989 (79 through mid-August) and in reducing waste gas system and liquid sampling system leakag Also, a comprehensive radiation source term reduction plan was develope Management has provided support for the initiation of extensive radiation source reduction techniques, such as system chemical decontamination and cobalt inventory/replacemen However, progress on these issues has not been overly aggressiv Management support for chemistry quality assurance/quality control (QA/QC) and water quality programs continued to improv This was evidenced by the construction of a new nonradiological chemistry laboratory equipped with state-of-the-art instrumentation and the improvement in the chemistry QA/QC progra The licensee's water quality program was consistent with the EPRI PWR Owners Group Guideline A new secondary system sampling panel incorporating in-line instrumentation for monitoring secondary water chemistry was installed adjacent to the new cold chemistry laborator Management oversight of the post-accident sample monitor (PASM) system was initially weak but improved considerably following a management meeting with the NRC in April 198 Also, a weakness was noted concerning management oversight of radiological analysis obtained from a vendo Licensee responsiveness to NRC issues was mixed demonstrating occasions of weak as well as good performanc Responsiveness was weak early in the assessment period, particularly in regard to the excessive number of PCEs and high personnel exposure
- associated with high-radiation background level Responsiveness to these concerns improved substantially later in the period, as did responsiveness to NRC concerns regarding the PAS Licensee progress in improving the effectiveness of the laboratory QA/QC program was not timel Examples of good licensee responsiveness included plant RP staffing and training improvements, significant ALARA program improvements, auxiliary building and containment decontamination efforts, additional frisking.stations,.construction of a more effective access control area, construction of a new radwaste building, decontamination of the old radwaste building located in a flood iJ~a;11, 1...urn:1...~iur1 or gamma "11orar1es, implementation of QA/QC control charts, and development of multiple point calibration curves for most assay The licensee's approach to resolution of technical issues from a safety standpoint was mixe Examples of good performance included upgrading computer dose assessment capabilities, design and purchase of a reactor head shielding ring, purchase of a state-of-the-art Fast Scan whole body counter, and the increased involvement of RP personnel in outage plannin Examples of poor performance in the resolution of technical issues included recurrence of problems regarding entry control for HRAs of greater than 1 R/hour, radwaste shipments, and RP technician/worker understanding of dedicated job coverage requirement Personnel contamination events were excessive for 1988 (1471 PCEs), but were greatly reduced in 1989 (79 through mid-August) due to the licensee's corrective
_action progra Personnel radiation exposure in 1988 was about 730 person-rem, which was hig The NRC recognizes that the licensee incurred much of the exposure on unanticipated outage work and on unusually extensive or one-time modification/maintenance activitie Nevertheless, work planning deficiencies appear to have contributed to the high annual dos Although the licensee implemented a radiation source reduction plan three years ago, it has not been as effective as anticipated; much additional effort appears necessary to adequately reduce personnel exposur The licensee's annual dose goal for 1989 is 400 person-rem; through mid-August, the licensee remained within the dose projection curv Gaseous releases remained well within Technical Specification limit The liquid radwaste releases decreased significantly during this assessment period due primarily to elimination of radioactive laundry waste discharge The solid radwaste volume reduction program was enhanced by utilization of a vendor's waste compaction servic One transportation incident occurred during this assessment period that resulted in the burial site issuing a civil penalty and temporarily refusing to accept further shipments from the licensee for failure to follow burial site requirement Performance in the nonradiological confirmatory measurements program was fair initially, with 21 agreements in 33 comparisons.
Analytical difficulties appeared to result from licensee unf ami 1 i a rity with the software. that contro 1 s computer-based
analytical insttumentatio Following instrument recalibration, the licensee achieved good agreemen The licensee maintains trend charts for water chemistry parameter These parameters were held below action levels and were reviewed by laboratory management dail Overall water quality was goo Performance in the radiological confirmatory measurements program was good, with 80 agreements in 82 comparison Later counts corrected the two disagreement.
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C1("t:::' The licensee 1s performance was rated Category 2 in the previous assessment perio.
Recommendations Non Maintenance/Surveillance Analysis Evaluation of this functional area was based on the results of 15 routine inspections performed by resident inspectors, one inspection of containment integrated leak rate testing (CILRT)
and local leak rate testing by a regional inspector, and one Maintenance Team Inspection (MTI).
Maintenance and surveillance were separate functional areas in the previous assessment period, but have been combined as one functional area for this assessment perio Enforcement history i~ this area continued to be good when compared with the previous assessment perio Five Severity Level IV violations were issued during this 15-month assessment period, compared with three Severity Level IV violations during the previous 13-month assessment perio Two violations were issued in the maintenance are One of these described six examples of failure to follow procedures in several area The other violation described two examples of failure to implement temporary modification requirement Three violations were issued in the surveillance area all of which were of minor safety significanc One violation resulted from the lack of testing after each opening of an air lock door sea The other violations involved inadequate testing of a containment penetration and violations of containment integrity requirement Subsequent corrective actions were timely and appropriate in all case The number of events in this functional area requiring the submittals of licensee event reports (LERs) increased somewhat during this assessment perio Eight LERs resulted from personnel error, three from equipment problems, two from post-maintenance testing, and one from a procedure proble Two of the personnel errors and one of the' post-maintenance testing events resulted
in four engineered safety feature (ESF) actuation The rema1n1ng personnel errors resulted in four cases of ~ndetected inoperability of safety-related equipment, in some instances lack of attention to detail was eviden One resulted in the violation discussed above regarding containment penetration testin The other personnel errors were determined by the NRC to be of limited safety significanc The second post-maintenance testing problem resulted in the inability to remotely close a contaminated drain line that could have resulted in an unmonitored radioactive releas LI Ll:::!ll:::il::!I:::!
llldlldYl:::!llll:::!ll"L dl!U ::.uperv I::; I Uri u I -..ne I l:::!l.:IHI I l.:d I Specification (TS) surveillance program continued to be well managed and implemented successfully with no surveillance requirements being misse As discussed earlier, two violations issued that resulted from inadequate execution and inadequate procedure The licensee 1 s maintenance programs continues to be effective, aggressively managed, and innovative in natur Management is placing heavy emphasis on industry experience and has established a separate maintenance group to implement this goa Personnel decisions reflect the organiza~ions goal The plant is in the third year of a five-year maintenance improvement pla The valve team was continuing to implement
. the valve improvement program, initiated during the previous assessment period, which has helped improve the material condition of the facility as well as the reliability of valve The scope and depth of preventive maintenance (PM) has steadily improve The ratio between preventive and corrective maintenance is goo The control of measuring and test equipment was good, and management emphasis in the area of post-maintenance testing resulted in better guidance for maintenance personnel and reduced the rework frequenc The maintenance team was concerned with the licensee 1 s actions to correct findings involving lack of change control for drawings during hardware modification, failure to follow instructions and procedures, lack of maintenance history and trend analysis for electrical components, and lack of QC involvement and participation in work activities. Weaknesses were also noted in the areas of work instruction adequacy, and the corrective action taken by the licensee to prevent recurrence of problems previously identified with control of contracted maintenance personne Indicators of maintenance also continued to improv For example, with the exception of the steam generator problems, plant operation has been very reliable from a maintenance point of vie No reactor trips occurred at power as a result of surveillance or maintenance activities (although one trip did occur in hot standby as a result of a surveillance execution error).
Prior problems with condensate dissolved oxygen were corrected by maintenance resulting in a significant reduction in dissolved oxyge Likewise, condenser offgas (condenser air
- in-leakage) was reduced from an acceptable value of 10 to less than 1 SCFM, which required installation of a low range flow measurement devic Improvements were also noted in the PM and repair of containment isolation valve The licensee failed the 1981 and 1986 CILRTs due to numerous leaking containment isolation valve The last tILRT passed due to the licensee's corrective actions and maintenance on containment isolation valve The CILRT procedure was rewritten, eliminating several days from the critical path for conduct of the tes Management involvement was evident during the 1988 ClLKI; and although two va1ves were improperly positioned for the CILRT, prompt corrective action was take Management's approach to resolution of technical issues from a safety standpoint was generally satisfactory.* Maintenance management was aware of current and future technical issues and problems, and set milestones in the long range plans to measure progres The licensee has established a boric acid walk-down team that continues to improve the cleanliness and radiological conditions of the plan The licensee was monitoring its fire protection system surveillance test program and fire protection features for specific plant areas as required by plant license requirements and in accordance NRC requirement Although an issue was raised regarding a sprinkler system surveillance procedure task for determining whether a modification had occurred since the previous surveillance, this procedure did not appear achievable with the guidance provide Staffing in the surveillance area was ample and effectiv Support by management for the conduct of the CILRT and personnel performance was adequat The maintenance organization was led by good managers and \\supported well by the on-site system engineering staff, and was adequately sized to maintain a reasonably small work order backlo At the time of the NRC MTI in October 1988, the open non-outage corrective maintenance work order (CMWO) backlog was manageable and represented about 3 months wor A review of the CMWO backlog during the MTI did not identify any work requests that had an impact on equipment operabilit Departmental overtime was approximately 4%.
The PM backlog was also low and manageabl Contractors and traveling repair crews were utilized for outage and non-outage wor While there were some problems with contractor control and training, use of a contractor helped to maximize work when ihutdown (but limited to what was controllable) and to maintain the backlog at an acceptably low level during plant operatio Maintenance training and qualification were generally well run and documente Plant craft personnel appeared knowledgeable and exhibited ~kills appropriate for the tasks
performe Work planning involved specifying the qualification level required for the wor A program was established to rotate maintenance personnel into the QC group for several month This rotation provided the workers a knowledge of job task quality requirements that could be taken back to the work grou An example of this was the identification to supervisors of concerns for containment integrity on July 19, 1989, which led to the discovery of numerous testing and procedural deficiencie Two areas of minor weakness appeared to be in the instrumentation and control (I&C) training area and the training program for nonpermanent and contractor personne In oo~n cases, personnel a1a no~ appear ~now~ecigeab~e of pr*u~e~ur*d~
requirement The licensee was initiating corrective actions
.in both area Overall, training and qualification effectiveness has continued to improve over the last assessment perio Management was generally responsive to NRC initiative During the CILRT inspection, it was determined that containment isolation valves requiring repair were not tested at the same pressure as the CILRT, which was required by 10 CFR Part 50, Appendix The licensee's response to this concern was acceptable for the 1988 tes However, the licensee's resolution of violations was not always adequate or acceptabl An example was the licensee's initial response to the MT!
violations was not adequate in several areas, however, the ensuing discussions were forthright and a consensus was reache.
Performance Rating The licensee's performance is rated Category 2 with an improving trend in this are The licensee's performance was rated Category 2 in maintenance, and Category 1 in surveillance, during the previous assessment perio.
Recommendations Non Emergency Preparedness Analysis Evaluation of this functional area was based on two inspections conducted by regional inspectors during the assessment perio These inspections consisted of one routine inspection and an evaluation of the 1989 annual emergency exercis No violations or exercise weaknesses were identifie No violations or exercise weaknesses were identified during the previous assessment perio Six emergency plant activations occurred during this SALP perio Each resulted in a Notification of Unusual Event (NUE)
being declare All required offsite notifications were made within the required time One NUE'was declared due to a stuck
fuel assembly in the reacto As a precautionary.step, a partial activation of the emergency response organization was implemente The presence of added emergency response personnel led to development of various p~anning contingencies should a more serious accident occu This partial activation of the emergency plan was a good example of conservative management action and coordination, even though -it was not required by the licensee 1 s emergency pla Management involvement in assuring quality performance was good during this perio Two n~w sirens, one on each level of the r
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UJ.Jer*<11.1ur1a e public address (PA) system for the plant has been upgraded and improve The two new sirens and the PA speaker system were included on the scheduled maintenante and surveillance progra The licensee continued to review and improve its emergency preparedness (EP) program from a technical standpoin Palisades was the first nuclear plant in the United States that volunteered to install the Emergency Response Data System (EROS).
A trial run is scheduled for the fall of 1989, with completion planned for the spring of 199 Upgrades in the area of computer enhancements during this period included programming the dose model into a personal computer system to provide greater speed, better graphics, and a more 11 user friendly 11 syste Offsite radiological data for scenario development and core damage calculations for post-accident sample results have also been computerized. -
The independent EP audit program continues to be comprehensiv The current audit included several surveillances and a review of both onsite and offsite EP activitie One audit finding recommended that the licensee eliminate separate training for exercise and drill *~ontrollers. The Training Department has since incorporated this training into drill training and EP-related subject The audit team also suggested that the licensee update the evacuation time estimate studies, since these were based on 1980 population dat The licensee indicated that this will be done when the 1990 census data become availabl Emergency response staffing at the management level has been well maintaine However, shift augmentation staffing needed modification during this assessment perio The licensee determined that because of changing training requirements and qualifications for certain job positions, the plant could no longer take credit for previous cross training that allowed certain employees to be available during the first 30 minutes of an emergency conditio These were non-managerial position The licensee identified this condition and worked with Region III to resolve the proble Changes were made to ensure fulfillment of the minimum shift staffing requirements as listed in the Palisades Site Emergency Pla **
- The training program is well defined and effectiv Interviews and walkthroughs with key emergency responders indicated that they were well trained and responsive to their emergency dutie Consolidation of the number of lesson plans from 26 to 12 was completed in this period which made their EP training program more effectiv These changes allow simultaneous training of personnel who hold comparable emergency response positions in the Technical Support Center (TSC) and Emergency Operations Facility (EOF) to receive the training at one sessio Previously there were separate training sessions for personnel in these position Generally, the 1989 exercise scenario adequately challenged the technical skills of plant management and staf The basic emergency conditions had a great deal of realism and included diesel generator problems and a primary-to-secondary leak in one of the steam generator The licensee's annual review of emergency action levels (EALs)
and other topics were well presented to state and county official A very cooperative working relationship exists between the State's Emergency Management Division and the license This has led to an improved dose assessment program, a clarification on ingestion pathway concerns, and improved interactions on offsite radiological monitoring issue Peformance Ra~
The licens,ee's performance is rated a Category 1 in this are The licensee's performance was rated Category 1 during the previous assessment perio.
Recommendations Non Security Analysis Evaluation of this functional area was based on the results of three inspections conducted by a regional security inspector and on routine observation of security activities by the resident inspector Enforcement history during this assessment remained about the sam Three Severity Level IV violations were identified during this assessment period, compared with one Severity Level IV violation and one Severity Level V violation identified during the previous assessment perio The three violations identified during this assessment period involved access control to vital areas and failures of the perimeter intrusion detection syste No major security enforcement issues were identified during this assessment
period*, and none of the violations identified were programmatic in natur The licensee initiated aggressive and effective corrective actions that should eliminate future access control or intrusion detection system violation Management 1 s involvement in assuring quality of the security program was proactive and is a program strengt The licensee's measures to correct identified vulnerabilities attained a level of action that exceeded minimum requirement Not only was the specific alarm annunciation deficiency corrected, but a decision was made to completely upgrade their computer syste Management's commitment to quality was also evident in the continuing effort to implement the assertive tracking and trending oversight program to monitor security operation Management support was evidenced through resource allocation and management accountability for security errors committed by plant personne Extensive planning and preparation for upcoming outages has been a program strengt Managements approach to resolution of technical issues has been a program strengt This was demonstrated by the upgrading of outdated security equipment with technically superior products and the use of a specialized contractor staff and testing methods to verify both.operability and adequac The licensee 1 s responsiveness to NRC initiatives continues to be excellen Security management is responsive to all findings that can strengthen the overall security progra Licensee response to NRC findings has been comprehensive and action has exceeded regulatory requirement This included comprehensive evaluations of violations, which utilized the t~lents of security, engineering, and contractor personne During this assessment period, security management personnel kept regional personnel fully informed of site security issues in a timely manne Required reports and logs were accurate and timel The licensee 1 s program for logging the three security events during this assessment period followed NRC guidanc In general, security-related records were complete, well-maintained and readily availabl Licensee staff resources dedicated to the security organization were ample and effectively utilized so that a high level of personnel performance was achieve This was demonstrated by the licensee 1s internal structure, which divides the security organization into several sections that are each responsible for implementing a specialized portion of the security progra The sections operate independently of each other, but are monitored by supervisory personnel who coordinate the effectiveness of the overall security progra The training and qualification program for the security organization is goo This was demonstrated by security personnel who were knowledgeable and competent in the execution
- of their duties and attained a high level of performance as demonstrated by the absence of personnel errors by security personne Performance Rating The licensee's performance is rated a Category 1 in this are The licensee's performance was rated a Category 1 in the previous assessment perio n
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Ve l\\l_.'-"VllUll"""llU\\.A \\.o I Vll Non Engineering/Technical Support Analysis Evaluation of this functional area was based on one routine inspection conducted by regional inspectors, one replacement and one requalification examination conducted by operator licensing inspectors, engineering team and maintenance team inspections, routine inspections by the resident inspectors, an EDP team inspection, and evaluations of licensee technical submittals by NRR.
Enforcement history declined during this period, with three Severity Level IV violations identified which included 19 examples of inadequate design contro For example, the addition of zener diodes in the safety injection tank pressure transmitter power supply was done without fully analyzing the potential failure modes and without checking the diode output voltage after installation, which resulted in the vendor recommended input voltage to downstream pressure transmitters being exceede Several LERs attributable to this functional area were issued during this assessment period, most involving original design and design controls in effect prior to 198 Management involvement to assure quality was mixe Good design basis documents and improved pump and valve testing were observed relative to the design base reconstitution portion of the configuration control projec The licensee formed a multi-discipline technical advisory group to act as an oversight review group to monitor*technical issues and to provide direction to ensure continued compliance with post-fire safe shutdown capability requirements. This approach was viewed as positive, with corrective actions being initiated to resolve post-fire safe shutdown deficiencies identified during the previous period. Management participated during operator licensing requalification material development meetings with the NRC and was aggressive in ensuring that the material met ES-601 of NUREG-1021 "Operator Licensing Examiner Standard."
Some licensee submittals and interactions between the licensee and NRC staff
during this period demonstrated a conservative, in-depth approach to engineering resolution of technical problem Examples included installation of a thermal margin monitor (TMM), which was supported by an engineering staff that was well-prepared, provided timely responses to questions, and demonstrated good understanding of the new equipmen Also, the Detailed Control Room Design Review (DCRDR) program reflected understanding and commitment to policie Additionally, the licensee's design submittal related to the anticipated transient without scram (ATWS) rule were acceptable,
~lthough imolementation has been slo System engineers provided effective support and interface with maintenance personnel, although documentation of problem resolution needed improvemen System engineers assessment of operational events was generally timely and thorough, and they played a key role in the follow-up of events, performance, and trend monitoring at the system and component leve The EDP team found that manag~ment involvement was sufficient to ensure orderly development of plant-specific procedures that would be generally responsive to NUREG and owners group general technical guideline requirement In contrast, the three violations and the multitude of design control weaknesses cited indicated that the problems may be generic, and that modifications being made under the Palisades Specification Change process are not consistently receiving an adequate level of attentio The licensee had not yet provided an acceptable response to staff review of the Three Mile Island (TMI) Action Plan Requirements for performance testing of pressurizer relief and safety valve In addition, the licensee continued to attempt to justify existing plant conditions within containment regarding fire safety in the conta_inment air room, despite the NRC staff's view that the existing level of protection was questionabl The EDP team found several examples of program deficiencies involving failure to consistently apply the guidance specified i~~the EDP Writer's Guide or the specific
.guidance therei For example, the EDPs did not always describe special requirements to perform a step, such as unlocking a valve or racking in a circuit breake These deficiencies also indicated the general weakness of not using a multidisciplinary team in EDP development and revisio The licensee's approach to resolution of technical issues from a safety standpoint was adequat A steam generator task force was established to provide input to senior management for decision making and logistics planning of the actual replacemen In addition, a separate group was tasked with defining the appropriate chemistry controls for the new generator The technical completeness of evaluations performed to support maintenance was unknow Documentation of engineering resolution to problems noted on work orders was usually missing, or only stated that "engineering resolved problem" without indicating what had been technically determine **
The licensee's responsiveness to NRC initiatives was goo The licensee took the initiative and exhibited good responsiveness in its followup and corrective action to the mechanical tube plug issu The maintenance work backlog attributpble to engineering and technical support had been drastically reduce Staffing was generally adequat Difficulties were noted in preparing for major outages and developing the EOP The lack of detail in licen-see submittals and the delay in resolving long standing issues may reflect strain on the engineering
't~ff_
Examnles included the pressurizer power-operated relief valve (PORV) and block valve testing subm1tta1s anci T.r1e eJu=111fJl.;0;-,
requests submitted regarding fire protection for redundant safe shutdown systems within containmen Management was balanced, strong, and typically focused the staff on safet The training department staff was of sufficient size to allow for implementation of the operator continuing training programs concurrent with developmental efforts towards the requalification examination material in accordance with the requirements as stated in ES-601 of NUREG-102 The licensee conducted frequent meetings and technical training for the engineering staff and improved the effectiveness of the organization except as noted abov The training and qualification programs have been outstanding in preparing the operators for licensed duties as evidenced by a 100% pass rate on the replacement examination that was administered in June 198 In addition, the licensee fully implemented its requalification progra That program appears to be successful at maintaining the required knowledge and the necessary operating expertise of licensed operators, as evidenced by a 100% pass rate for the eight operator exams that were administered_ in the Apri 1 1989 requalification examinatio.
Performance Rating The licensee's performance is rated Category 2 in this are The licensee's performance was rated Category 2 in the previous assessment perio.
Recommendations Non Safety Assessment/Quality Verificatio~ Analysis This is a new functional area and consequently was not rated during previous SALP period It contains simila~ attributes, however, to the previous SALP functional area of Quality Programs and Administrative Controls Affecting Qualit Evaluation of this area was based on 16 routine inspections performed by
resident and regional inspectors and 1 special inspection conducted by an NRC contracto Interactions with NRC staff on licensing matters was also considere The enforcement history in this area was considered average, with three Severity Level IV violations issued during the perio One violation related to inadequate quality verification to ensure that steam generator tube plugs were installed in the proper location and were properly welde A second violation concerned failure to identify a discrepancy
'"~~~~~~~~+inn nf r.nntainment penetration isolation valves as an unreviewed safety questio The third violation icier1iiricJ an inadequate level of oversight for the development of the EOP The licensee 1s corrective actions for these violations was appropriate and thoroug Review of licensee submittals to the NRC during the assessment period indicates mixed performance in both the technical and oversight aspect The licensee 1 s staff evidenced an understanding of the issues and provided sound justification for their positions with regard to their response to Generic Letter 82-3 Licensee initiatives included restriction of power operation to 80% of rated power in an attempt to prevent further steam generator tube failures, and TS change requests related to pressurizer water level instrumentation, secondary safety valves, modified area monitor surveillances, and radial peaking factor In contrast, the NRC received untimely, incomplete, or inadequately supported submittals from the licensee related to changes in the TS Administrative Controls section, an exemption request from requirements of 10 CFR 50, Appendix J for the CILRT, revision of the low temperature over-pressure protection TS requirements necessitated by the revision of the 10 CFR 50, Appendix G curves, and TS changes for opening of containment penetration isolation valves while operating at powe The licensee 1 s self-improvement efforts are considered a strengt These include efforts to convert the current TS to standard TS, continuing improvements in the 10 CFR 50.59 safety evaluation process and the use of corrective action documents to ensure adequate evaluation and resolution of deficiencie Management involvement to assure quality in this functional area was generally adequat Several examples were noted in which line management requested quality department surveillances or audits to assess the condition of programs or activities under their cognizance, e.g. the System Functional Evaluation Program and Augmented Test Program (ATP).
Maintenance management was also involved with the Corrective Action Review Board on a daily basis and was responsive to the needs of other work groups such as radiation protection, chemistry, and operation Management has made progress in fostering an attitude of 11 how can this be done better or smarter?
11 through the promotion of a suggestion
award progra The licensee continues to pursue self-identification of problem areas, making increased use of the Nuclear Plant Reliability Data System (NPRDS) and other industry informatio When safety or quality probl~ms were identified, the licensee aggressively pursued and achieved resolutions, although some examples of inadequate or inconsistent long-term management controls were eviden In one case, the 1988 biennial QA program performance review (required by TS) identified issues requiring management attentio A number of these issues were recurrent, and some had been separately identified by QA and NR Althouqh the report had clearly been reviewed by management, no specific follow-up actions were prescribe In a related example, follow-up to Material Condition Task Force and ATP findings appeared to suffer from a loss of management attention and priority as the circa 1986 issues grew olde Some progress was made late in the SALP perio The licensee's quality and self-assessment organizations are adequately staffed with properly qualified and trained personne This is evidenced by safety assessments and audits that are generally thorough, well-documented, and indicative of an appreciation for nuclear safet Rotational assignments are made to QC to increase exposure of workers to quality concern This had resulted in several substantive finding The licensee was generally responsive to NRC initiatives during the assessment period as demonstrated by prompt correction of issues identified during NRC inspections and corrective actions taken in response to NRC Bulletins and Information Notice The licensee is committed to the Restructured Technical Specifications Program and appears to be on schedul Near the end of this assessment period the Nuclear Safety Board (NSB) functions were reassigned to the Nuclear Safety Services Department (NSSD).
Inspection of the transition organization found that the NSSD 1 s independent safety review program was well-administered and provided a broad sampling of safety related activitie The involvement of NSB and NSSD in audits required by TS was adequate, however, in the past, the audits were performed by the QA department with an NSB/NSSD member participatin During 1989, this involvement changed to a review of audit preparations and post-audit review of the report The licensee committed to increased cognizance for future audit Licensee safety assessment and quality verification as applied to long-term resolution of issues generally is conservative, sound, and in some cases commendable; however, thoroughness in followup is sometimes inconsisten Resolution of more routine p~oblems and imprqvement of established programs does not always reflect the same level of management attention.
- Performance Ratings The licensee's performance is rated Category 2 in this are The licensee's performance was rated Category 2 in the similar area of Quality Programs and Administrative Controls Affecting Quality in the previous assessment perio.
Recommendations None.
- *
SUPPORTING DATA AND SUMMARIES Licensee Activities Palisades Nuclear Generating Plant operated routinely during the beginning of the assessment perio It experienced no forced outages or significant power reductions until August 8, 1988, when it was shut down as a result of steam generator (SG) tube leak The plant remained shutdown, and the licensee commenced with its scheduled refueling/maintenance outage activitie The plant experienced additional SG outages and operated routinely at restricted power 1eve1s aur1ng August l~~~-reoruary l~~~ ll montns or this assessment period).
It operated at the administratively imposed power level limitations of 80% for the duration of the SALP assessment perio Palisades experienced 11 ESF actuations and 5 reactor trip One trip occurred while operating greater than 15% power, one occurred at less than 15% power, and three trips occurred without rod movem~nt. One trip was related to procedural inadequacies and four were the result of equipment failure Significant outages and events that occurred during the assessment period are summarized belo.
During August 8-November 26, 1988, the plant was shutdown to repair SG tube leak It remained shutdown as the licensee commenced its scheduled refueling/maintenance outage earl Outage activities included SG eddy current testing, repairs to a stuck fuel bundle, repairs to a damaged service water pump, correction of valving errors that occurred during an CILRT and other routine refueling activitie.
During November 28~30, 1988, the plant was shutdown to perform main turbine overspeed testing activitie.
During December 6-26, 1988, the plant experienced a forced outage and remained shutdown for maintenance, as a result of increasing primary-to-secondary leakag Maintenance activities included a primary coolant pump seal replacement, SG tube leak repairs, and primary safety valve repair.
During January 30-February 21, 1989, the plant was shutdown for primary-to-secondary tube leak repairs on the 'B' S.
On March 2; 1989, an 80% power limitation was imposed by the licensee to improve SG reliabilit Inspection Activities Thirty inspection reports are discussed in this SALP report (June 1, 1988 through August 31, 1989) and are listed in Paragraph 1 of this section, "Inspection Data.
26
Table 1 lists the violations per functional area and their severity level Significant inspection activities are listed in Paragraph 2 of this section, "Special Inspection Summary. 11 Inspection Data Facility Name:
Palisades Nucelar Power Plant Docket No.:
50-255 Inspection Reports Nos.:
88016 through 88027, 89002 through 89004, 89007, 89009 through 89019, 89021 through 89023, and 8902 Table 1 Number of Violations in Each Severity Level Functional Areas I
II III IV
3
v G.
Plant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Safety Assessment/
Quality Verification TOTALS I
II l*
l**
III
3 4**
IV
v
- This violation was identified and evaluated in the SALP 8 report, but was not issued until SALP This is included ~n the totals for this SALP period (Inspection Report No. 255/88012).
- An Environmental Qualification Category B Severity Level III violation and a Severity Level IV violation were identified during SALP 7, but were not issued until SALP These are includes in the totals for this SALP period (Inspection Report No. 255/86032). Special Inspection Summary During September 6-December 8, 1988, a special team inspection of the operational*radiation protection program was conducted during an outage (Inspection Report No. 255/88021). During September 19-0ctober 20, 1988, ~ Maintenance Team Inspection was conducted (Inspection Report No. 255/88030).
27 During April 3-May 5, 1989, an engineering-team inspection w~s conducted (Inspection Report No. 255/89007). During July 18-20, 1989, the annual emergency preparedness exercise was conducted (Inspe.ction Report No. 255/89016).
e. -
During July 24-August 4 an Emergency Operating Procedure Inspection Team conducted an inspection (Inspection Report No. 255/89019). Escalated Enforcement Actions A Notice of Violation and Proposed Imposition of Civil Penalties in the amount of $150,000 was issued to the licensee on November 23, 1988, for an Environmental Qualification Category B violatio This action was based on violations of NRC requirements of environmental qualifications (10 CFR 50.49) of certain items of electrical equipmen The licensee-paid the $150,000 civil penalty on December 23, 1988 (Enforcement Notice 88-102, EA 88-138, Generic Letter 88-007, Inspection Report No. 255/86032). A Severity Level III Notice of Violation and Proposed Imposition of Civil Penalties in the amount of $75,000 was issued to the licensee on December 22, 198 This action was based on the failure to satisfy fire protection requirements of 10 CFR 50, Appendix R, and the failure of management to take aggressive and timely corrective actions in this are The licensee paid the $75,000 civil penalty on January 1, 1989 (Enforcement Notice 88-108, EA 88-140, Inspection Report No. 255/88012). Confirmatory Action Letters Non Review of Licensee Event Reports (LERs) Licensee Event Reports (LERs)
Thirty-five LERs (including 4 Voluntary LERs 88012, 88015, 89013, and 89TS1) were issued during this assessment perio Table 2 shows cause code comparisons of SALP 8 versus SALP 9 LER LER.Nos.:
88010 through 88025, 89001 through 89010, 89012 through 89019, and 89TS '
CAUSE AREAS Personnel Errors Design Problems External Causes n----~----' n-~--~-
Equipment Failures Other/Unknown TOTALS FREQUENCY (LERs/MO)
- Includes 4 Voluntary LER Table 2 SALP 8 (13-MO)
N (Percent}
(51.4%)
( 8.6%)
( 0.0%)
...
, ".....,,~'
..J
\\. J.':I" *..Jlo)
(25.n6}
( 0.0%}
35 SALP 9*
(15-MO)
N (Percent}
(40.0%)
(11. 4%)
( 0.0%)
-
,
.... __,...
.J
\\. 0. O/o)
(28.6%)
(11.4%}
2.33 NOTE:
The above infor~ation*was derived from review of LERs performed by NRC staff and may not compl.etely coincide with the licensee's cause assignment