IR 05000255/1989003

Insp Rept 50-255/89-03 on 890110-0213.No Violations Noted. Major Areas Inspected:Actions on Previously Identifed Items, Plant Operations,Maint,Surveillance & Security.Two Violations Noted for LER Review for Which No Notice Issued

ML18054A590
Person / Time
Site:	Palisades
Issue date:	03/01/1989
From:	Burgess B, Schapker J, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18054A589	List: IR 05000255/1989003 ML18054A588
References
50-255-89-03, 50-255-89-3, NUDOCS 8903140668
Download: ML18054A590 (14)

Text

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-255/89003(DRP)

Docket No. 50-255 Licensee:

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

Palisades Nuclear Generating Plant

.Inspection At:

Palisades Site, Covert, Michigan Inspection.Conducted:

January 10 through February 13, 1989 Inspectors:

E. R. Swanson Approved J. K. Hell er

• • f* ~. LLQ.Jc OJ~M Ulie

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Reactor Projects Section 2A Inspection Summary License No. DPR-20 3/t/gz Date Inspection on January 10, through February 13, 1989 (Report No. 50-255/89003(DRP))

Areas Inspected:

Routine unannounced inspection by the resident inspectors of:

actions on previously identified items; plant operations; radiological controls; maintenance; surveillance; security; reportable events; and steam generator tube inspectio.

Results:

Of the eight areas inspected, no violations or deviations were identified in seven area Two violations were identified during LER review (Paragraph 8) for which a Notice is not being issue The inspection disclosed weaknesses in the licensee's cleanliness standards for containmen The inspection noted strengths in licensee communication initiatives related to the steam generator repair and the conservative reporting of the LLRT failur No new Open Items or Unresolved Items were identifie ~903140668 ~90303 F

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• DETAILS Persons Contacted Consumers Power Company

• G. B. Slade, Plant General Manager

• R. D. Orosz, Engineering and Maintenance Manager R. M. Rice, Operations Manager

• R. E. McCaleb, Acting Administrative and Planning Manager

• W. L. Beckman, Radiological Services Manager J. G. Lewis, Technical Director K. V. Cedarquist, Inservice Inspection Engineer

• H. C. Tawney, Mechanical Maintenance Superintendent D. J. Malone, Licensing Analyst

• C. S. Kozup, Licensing Engineer

• R. A. Fenech, Operations Superintendent

• D. J. VandeWalle, Configuration Control Manager

• R. P. Margel, Acting Quality Assurance Director

• J. R. Brunet, Licensing Analyst Nuclear Regulatory Commission (NRC)

• E. R. Swanson, Senior Resident Inspector

• J. K. Heller, Resident Inspector

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I

• Denotes those present at the Management Interview on February 16, 198 An exit meeting was held between J. F. Schapker (NRC) and K. E. Osborne (CPC) on February 7, 1989 to discuss the results of the inspector 1s review of the steam generator inspection and repai Other members of the Plant staff, and several members of the Contract Security Force, were also contacted briefl _ Actions on Previously Identified Items (92701, 92702) (Closed) Open Item 255/86022-0l(DRP):

Reactor Coolant Pump Seal not tested to the time limit of Appendix Test data from the Byron Jackson Pump Division was reviewed concerning loss of cooling water to the reactor coolant pump seals. A seal cartridge was tested under static conditions in a fixture with water at 550 degrees F and a pressure of 22_50 psi The water was then circulated to duplicate the normal system operating conditio Cooling water was then secured for 39 hour4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> At that point a cooldown was commence Maximum seal leakage was 0.27 gpm after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without cooling wate An inspection of the parts after the tist disclosed some cracking of the seal face and slight extrusion and hardening of the nitrile 11U 11 cups.

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This was considered an open item because the portion of the test without cooling water was run for only 39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> and not the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> required by Appendix The licensee's position, as specified in a October 14, 1986 letter from Consumers Power Company to NRC Region III, was that the test was considered applicable to the Palisades Primary Coolant Pumps (PCPs).

,

According to the NRR Licensing Project Manager, this item is being reviewed by NRR as part of Generic Issue 23, PCP Seal Failur Since NRR is addressing this issue on a generic basis, no regional action is necessary, therefore, this portion of the Open Item is close A second portion of this Open Item pertaining.to loss of HVAC on safe shutdown equipment in the West Safeguards Room and the Diesel Generator 1-1 Room, remains open and will be reviewed during a future inspectio b. * (Closed) Open Item 255/86035-34(DRP):

Pursue a Technical Specification change to reduce testing frequency on containment hydrogen monitoring system valve In a letter dated January 24, 1989, from Consumers Power Company to the Nuclear Regulatory Commission, the licen~ee withdrew any request for red~ced frequency testtng and stated that the request would*be included in the restructured Technical Specification which will be submitted at a 1 ater date. * (Closed) Open Item 255/86035-56(DRP):

Develop a plan to replace all safety injection check valve Leakage of the valves has caused safety injection tank level and concentration problem A review of the valve maintenance history shows that four of the eight valves have been repaired. Currently there does not appear to be a problem with valve leakag Five year plan project number 61871 documents that a contingency plan has been initiated to replace the valves in the event of leakage problem (Closed) Open Items 255/86035-67(DRP) and -73(DRP):

Determine if post-LOCA chemical addition (hydrazine and sodium hydroxide) to the containment spray system can be delete The li~ensee has determined that the chemical addition portion of the containment spray system can be replaced with a passive means-of post-LOCA iodine removal through placement of trisodium phosphate in the basement of the containmen All work associated with ~emoval of the hydrazine tank and sodium hydroxide tank and obtaining regulatory approval is captured by fiv.e year plan project number 60710~ (Closed) Open Items 255/86014-03(DRP) and 255/86035~68(DRP): Replace the OBA/normal shutdown sequencers with new solid state sequencer The sequencers were replaced by Facility Change 737 during the 88 refueling outag Observation of the work activities associated with the Facility Change are documented in Paragraph 3.4.2.1, 11Sequencer Replacement 11, of NRC Inspection Report 255/88020(DRS).

3 (Closed) Open Item 255/86035-80(DRP):

Prepare a list of control room chart recorders that need to be upgrade Internal correspondence DMK 88*004, dated August 17, 1988, lists the recorders that* will be upgraded. *The replacement of the recorders is controlled by five year plan project number 6261 (Closed) Open Item 255/86035-83(DRP):

Develop and implement a hanger and restraint inspection progra Procedure EM-09-08,

"Palisades Secondary ISI Program" was written to establish a program for inspection of secondary side supports and hanger The program dictates that a random sample of supports/hangers is selected on a refueling frequency and inspected for wear, cracks, corrosion, alignment, setting and any other abnormalitie Results of the inspections performed on August 19, 1988, (project number 248815-226081) and October 15, 1987, (project number 238715-226304) were reviewed; no problems were noted, (Closed) Open Item 255/86035-87(DRP):

Join Combustion Engineer Owner's Group to address Neutron Instrumentation concern A September 14, 1988 letter documents that a Combustion Engineering Owner's group was not formed because the interests of participating utflities were so divergen * (Closed) Open Item 255/86035-88(DRP):

Refurbish spare power range channel (S/N-106).

During receipt inspection, nonconforming material report_N-QP-86-066 documented that the power range channe~

could not pass a functional test after a contractor had attempted to refurbish the channe The channel was refurbished per Work Order 24606126 and then passed a functional tes (Closed) Open Items 255/86035-90(DRP) and -112(DRP):

Replace pressurizer pressure Safety Injection 11A 11 channel with a variable high power trip. During the 88 refueling outage the licensee insta1led a variable high power trip per Facility Change FC-62 An NRR review team evaluated the modification duri.ng a site visit on November 7 - 9, 1988, and issued safety evaluation for Technical Specification 118 authorizing use of the Facility Chang (Closed) Open Item 255/86035-117(DRP):

Develop a preventive maintenance program to inspect valves and operators of Bettis Actuators and Allis-Chalmers Valve Internal correspondence DDC*018 dated November 21, 1988~ stated that 74 valves have been identified on 24 Planned Periodic Activity Control Sheets (PPAC).

The PPAC frequency is every five year The inspector selected 10 valves and verified that PPAC numbers had been issue The inspector found that the PPACs were in the planning stages and not available for us To assur~ PPAC planning is complete, the computer generates a weekly_ list of PPACs that are in the planning stages. This should assure that the PPAC completion is not delayed or missed. *Since the valves are identified to a PPAC number and checks and balances exist to trigger completion 6f the PPAC, the inspector has no additional question '

I (Closed) 255/86035-129(DRP):

Evaluate the installation of a permanent sump pump in the Auxiliary Feedwater Pump roo The licensee determined that cleaning of the turbine building sump and repair/modification of the turbine building sump pumps would improve the reliability of the turbine building sump and eliminate the need for a permanent AFW room sum This has been done by PPAC RWS-132, PPAC RWS-133 and SC-87-31 In addition, the AFW room has a temporary sump pump installe (Closed) 255/86035-150(DRP):

FSAR rev1s1on is required to identify seismic and Q categorization of the backup nitrogen syste A review of FSAR Table 5.2.3 shows that the required revision has been mad (Closed) Deviation 255/88012-04(DRP):

It was determined that a fire brigade member of shift three did not attend the required number of fire drills during calendar year 198 By letter dated September 7, 1988, the licensee identified personnel error as the reason for the deviatio An inadequate Safety Evaluation was performed, which failed to disclose the FSAR statement that each fire brigade member will participate in two fire drills per yea The licensee's corrective actions included notifying departments that have personnel on the fire brigade of the two drills per year per person commitmen The licensee is also spot checking the brigade members'

drill attendance on approximately a quarterly basis and the plant

fire pr~tection staff is being ~ugmented to increase oversite capabilities. Additionally, the.Fire Protection Implementing Procedure (No. 6) is being revised to reflect the two drill per year per person commftmen These corrective actions are scheduled to be achieved on or before December 31, 198 Based on the above licensee submitted information, this item is being close (Closed) Unresolved Item 255/88027-0l(DRP):

Control rod group overlap was not maintained as required by Technical Specification 3.10. See Paragraph 8, Reportable Events, for a discussion of this Unresolved Ite No violations, deviations, unresolved or open items were identifie.

Operational Safety Verification (71707, 72710, 42700)

Routine facility operating activities were observed as conducted in the plant and from the main control room Plant startup, steady power operation, plant shutdown, and system(s) lineup and operation were observed as applicabl The performance of licensed Reactor Operators and Senior Reactor Operators, and of auxiliary operators was observed and evaluated including procedure use and adherence~ records and logs, communications, shift/duty turnover, and the degree of professionalism of control room activitie *~

Evaluation, corrective action, and response for off normal c.onditions or events, if any, were examine This included compliance to any reporting requirement *

Observations of the control room monitors, indicators, and recorders were made to verify the operability of emergency systems, radiation monitoring systems and nuclear reactor protection systems, as

applicabl Reviews of surveillance, equipment condition, and tagout logs were.conducte Proper return to service of selected components was verifie The following activities were observed: Steam Generator Leakage The unit began the reporting period at essentially full power, however, an increasing primary to secondary leak rate caused a unit shutdow On January 23 the leakrate started increasing and on January 26 at 7:30 p.m. exceeded the administrative leakrate limit of.1 gpm (Technical Specification limit is.3 gpm).

At that time a controlled shutdown was starte The shutdown was stopped a number of times for preplanned activities and to perform additional leakrate calculation On January 27 the shutdown was

~uspended at 45 percent power and the* decisio~ made to hold until January 30 to allow mobilization of resources for the upcoming outag The leak rate reduced to less than, and stayed be\\ow,

.02 gpm while the plant was at 45 percent powe Senior site management briefed RIII management and the NRR project manager on the plant status and outage plans during licensee initiated conference calls on January 2 Steam Generator tube inspection is discussed in Paragraph.9 of this repor Off-Gas Flow Instrument During a tour of the turbine building the inspector noted that FI-0631, 110ff-Gas Flow Monitor 11 had a hand written scale taped to the outer glass of the mete The permanent scale was located inside the outer glass next to the metering tub The permanent scale was in GPM, while the handwritten scale did not specify unit The inspector reviewed equipment data base and the work order history for FI-0631 and determined the following:

(1) The meter had been installed in January of 1985 per Specification Change 85-00 * *

(2) The calibration sheets attached to Specification Change 85-002 stated that the calibration was good to 10.6 SCFM, although the handwritten scale goes to 20 SCF The calibration sheets documented that a calibration standard above 10.6 SCFM was not available at the time of the calibratio The licensee stated that readings over 10 SCFM require corrective action to reduce flow under chemistry procedure COP-1 *

(3) The c~libration converts the GPM scale *to SCF The inspector notes that use of the installed scale and then converting the reading to SCFM by-the procedure may produce more repeatable readings since the handwritten scale is approximately one inch from the metering tub The licensee commented that because the float bounces around that the reading is at best an estimat (4)

PPAC AES-009, 11Calibrate or Inspect Instrument for the Steam Jet Air Ejector 11 lists FI-0631 and only requires a cleanin Work Order 24805624 last implemented PPAC AES-009 and stated that FI-0631 was cleaned inside and ou However, the PPAC or Work Order does not state that the zero line on the metering tube and the scale were checked for proper alignment as recommended by the vendor manua The licensee agreed to modify the PPAC to zero the metering tube with the scal (5) The meter is considered non-Q, but the licensee identified that it should be Q-listed because of it's use in determining primary to secondary leak rate which is a Technical Specification limi These issues were discussed at the exit intervie Containment Tour During a post operat1ons/pr~maintenance inspection of the containment on February 1 the following were note Licensee actions follow the concerns in brackets[].

(1) Nails, tie wraps and coat hangers were on the supports near the top of the Clean Waste Receiver Tanks [cleaned up].

(2) A cable tray, in the overhead next to the "Rats Nest 11 valve area, had boric acid on the tray and cables in the tra The boric acid appeared to be leeching from the refueling cavity tilt pit wall [end of period, considering steam cleaning, cable tray was hand cleaned and found not degraded, DR to be initiated to trade action].

(3) Several valves in the "Rats Nest" had packing leaks as evidenced by boric acid buildup [no action taken this outage, licensee stated that packing leak repairs are scheduled for a future outage].

(4) A service water valve or p1p1ng associated with containment air cooler number 3 was leaking a mist of water [later stopped on its own, no action taken].

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(5) The half loop water level watch was at his assigned station however, the phone was not functional during draining to mid-loop [phone cord later extended for his use].

7 Plant Shutdown The inspector observed control room activities pertaining to the shutdown of January 30, from 45 percent power to 0 percent* power as directed by General Operating Procedure Number Walkdown The inspector walked down both Diesel Generator's starting* air from the air compressors to the air start motors using licensee print M-21 The inspector verified that each accessible valve in the flow path was in its correct position, that essential instrumentation was operable and there was no condition that degraded the syste CFR 50.72 Report A Local Leak Rate Test performed on February 6, 1989 exceeded the guid~line leakage, and a 10 CFR 50.72 report was made due to the potential for exceeding the 0.6 La containment leakage limi The test result was 18,060 cc/min, which is approximately 28% of the limi When added to the kno~n leakage the ~otal was onl~

about 60% of the limit, and therefore the report was not require Tagging During a tour of the turbine building, the inspector found what appeared to be two improper caution tag The tags were pieces of notebook paper with the words:

"Do not use - this disconnect is for temporary power on turbine floo Do not remove tag".

The tags were attached to disconnects located behind 4160 Volt Switchgear lA and 18 at south end of the turbine* building on elevation 59 This was identified to the Shift Supervisor and the tags were remove No violations, deviations, unresolved or open items were identifie.

Radiological Controls (71707)

During routine tours of radiologically controlled plant facilities or areas, the inspector observed occupational radiation safety practices by the radiation protection staff and other worker Effluent releases were routinely checked, including examination of on-line recorder traces and proper operation of automatic monitoring equipmen Independent surveys were performed in various radiologically controlled area *

The inspector noted a significant reduction in the rate of personnel contamination At the close of the inspection period, only 30 for the year and 7 for the current tiutage had occurre This outage statistic represents a reduction of about 84% from the last Steam Generator outage of December, 198.

Maintenance (62703, 42700)

Maintenance activities in the plant were routinely inspected, including both corrective maintenance (repairs) and preventive maintenanc Mechanical, electrical, and instrument and control group maintenance activities were included as availabl The focus of the inspection was to assure the maintenance activities reviewed were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with Technical Specification The following items were considered during this review: the Limiting Conditions for Operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures; and post maintenance testing was performed as applicabl The following activities were inspected:

a. NOE of repair weld for MV-AED 808a (W.O. 24804734)

Repair weld leak (W.O. 24802736)

Repack P-98 (W.O. 24900627)

Change coolant hoses to Diesel Fire Pump P-41 (W.O. 24800616)

Repair fuel oil leak to K-10 (W.O. 24802056)

Calibrate FI-1347, 11Service Water Pump - inservice inspection fl ow meter 11 (W. 0. 24900435) Replacement and calibration of flow controller for CV-0610 (SC-88-085, W.O. 24803200/24805158)

No violations, deviations, unresolved or open items were identifie.

Surveillance (61726, 42700)

The inspector rev1ewed Technical Specifications required surveillance testing as described below and verified that testing was pe~formed in accordance with adequate procedures, that test instrumentation was calibrated, that Limiting Conditions for Operation were met, that removal and restoration of the affected components were properly accomplished, that test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other tha the individual directing the ~est, and that deficiencies identified during the*testing were properly. reviewed and resolved by appropriate management personnel..

The following activities were inspected: RI-47 Auto Rod Withdrawal Prohibit Interlock Matri Q0-2 Recirculation Actuation System and Containment Sump*

Valve Tes R0-32-17 Local Leak Rate Test - Containment Sump Level Instrumen During the test, the operators adjusted the packing on a penetration test isolation valv This is not permitted by the procedure and was properly identified to the Shift Supervisor and documented on a deviation repor The inspector interviewed the operators shortly after the packing was adjusted, but while the test was in process and found what appeared to be confusion on the part of the operators pertaining to identification of containment penetration isolation valves. This was discussed with the Technical Engineer and at the exit intervie The inspector expressed concern that any operator would not be able to instantly identify a boundary isolation valve, especially with the licensee history of degraded containment integrity due to. valving errors.

. The packing adjustment was reviewed with Region III to determine if enforcement action was appropriat It*was determined that because of penetration line size, size of the valve and location of the valve that this procedure violation would be classified as a level According to the new enforcement policy level V violation will not be issued especially when identified by the license In this case issuance of a violation is not appropriat DW0-1 SH0-1 Daily Control Room Surveillanc Operators Shift Surveillanc No violations, deviations, unresolved or open items were identifie.

Security (71707)

Routine facility security measures, including control of access for vehicles, packages and personnel, were observe Performance of dedicated physical security equipment was verified during inspections in various plant area The activities of the professional security force in maintaining facility security protection were occasionally examined or reviewed, and interviews were occasionally conducted with security force member *

a*.

~ The inspector interviewed an officer stationed as a 11 IR 11 watch at the containment equipment hatc The officer was knowledgeable of his post orders and appeared to execute them properl The inspector observed, from the central alarm station, a perimeter

. alarm check and emergency phone check; no problems were identifie During a visit to the central alarm station, the inspector noted that a camera was inoperabl The officers interviewed were able to describe the administrative program to obtain repair During

a subsequent visit, the inspector found that the camera had been repaired and was working properl No devi~tions, unresolved or open items were identifie.

Reportable Events (92700, 90712)

The inspector reviewed the following Licensee Event Reports (LERs) by means of direct observation, discussions with licensee personnel, and review of record The review addressed compliance to reporting requirements and, as applicable, that immediate corrective action and appropriate action to prevent recurrence had been accomplishe (Closed) LER 255/88023:

Potential unmonitored release pat This event was discussed in Report 255/88027(DRP), Paragraph Corrective actions were adequate, and the potential release is bounded by assumptions made in the licensee's analysis of the Maximum Hypothetical Acciden (Closed) LER 255/88024:

Inadvertent release of radioactive waste gas decay tank due to operator erro Independent verification is being implemented to prevent recurrenc Due to the number of varied causes of inadvertent tank releases over the last two years, a human performance evaluation is being conducte The violation of T.S. 3.24.6 will not be cited as allowed by 10 CFR 2, Appendix C. (Closed) LER 255/88025:

Control rod group overlap violat.io This event is discussed in Inspection Report 255/8802 Causes of the event were failure of the position indication primary (PIP) due to a power supply failure, and the operator continuing to move rods in 11Manual Sequential 11 mode when the sequencing feature of the PIP was inoperable and failing to check the overlap at intervals prescribed by the System Operating Procedur The operator was misled when the rod sequence alarm was received and the overlap was found to be acceptabl Presuming that the alarm was caused by a shutdown control rod that had been reading erratically, the operator did not notice that one group was not sequencing out due to misalignment during work on the.PI Corrective actions discussed in the LER (88025 dated January 25, 1988) include review of the event with operators emphasizing attention to detail, verifying nuisance alarms frequently, keeping supervision aware of conditions and strict use of procedures; improved simulator and classroom training on rod sequencing, overlap and PIP and SP! control

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• logic and alarm functions; improved preoperational testing of the position indication and control system; and an operator aid, which will depict the control rod overlap scheme, will be. attached to the control pane i

Although a violation of NRC requirements occurred, a notice of violation will not be issued, 'as allowed by 10 CFR 2 Appendix C, due to the licensee's identification and reporting of the violation, the low significance of the violation, the corrective actions taken and planned, and the absence of precursor events or willfulnes Two violations were identified by the licensee to which no notice of violation was issued. Also no deviations, unresolved or open items were identifie.

Steam Generator (SG) Tube Inspection A primary to secondary SGtube leak in the 118 11 steam generator was identified on January 24, 198 The licensee redu.ced power to 45% on January 26, 1989, upon reaching a leak rate of.10 GP The Palisades Technical Specification limit is.30 GP On January 30, 1989, the licensee removed the unit from service to investigate the source of the lea Upon locating the leak via pressure testing, the licensee performed eddy current (ET) examination of the leaking SG tub Results of the ET examination determined that the leak was in the SG tube hot leg at the 3rd support plate and was characterized as a 78 degree circumferential crack-like indication. This was not typical of the defect location associated with the previous forced outages,- where circumferential cracking in the 13th support plate was foun The licensee performed an additional forty (40 ET examinations with the motorized rotating pancake coil (MRPC) at the 3rd support plate and an additional 104 ET examinations, from the tube sheet to the hot leg bend (with the 4C4F ET procedure), in the outer periphery of the 3rd support plat No additional defective tubes were found in these sample The licensee deplugged three tubes which had been plugged in August of 1988 for circumferential cracking at the.13th support plate. The purpose of the deplugging was to ET examine the tubes to determine the growth of the cracking after plugging. The.ET examination, utilizing MRPC, revealed no change in two of the cracks, and a significant crack growth in one of the tubes (57° increased to 150° circumferential). The licensee also performed MRPC of 240 tubes at the 13th support plat From the sample, an additional three crack-like indications were disclosed. A total of 238 tubes were 11B1ock 11 plugged which included all active tubes surrounding the third support leaker and selected crack susceptible areas at the 13th support plat The NRC inspector reviewed the licensee's ET inspection plan and data*

results. The licensee has experienced an increased rate of SG tube failures due to circumferential cracking at the tube support plates since December of 1987, primarily at the 13th support plate. Although no leaker was found at the 13th support plate this outage, three additional crack-like indications were foun Based on previous experience of SG

tube cracking at this support plate, the li~ensee planned to "Block" plug the outer sections of support plate 1 Further evaluation for lug and rim cuts of selected support plates is ongoing by the licensee. This procedure is to relieve stresses to th.e SG tubes caused by deformation of the support plates.. The NRC inspector brought to the licensee's attention that, considering past experience and the current ET data, the ET examinations that were performed this outage did not assure that additional cracking of SG tubes had not occurre The inspector does not*consider this to be a safety significant finding since the licensee's adherence to the administrative primary to secondary leakage limits is conservative, and has demonstrated that tube leakage will precede the tube failure by a safe margin (leak before break-analysis).

The licensee is in the process of upgra9ing their ET progra The licensee currently plans to utilize the Zetec MIZ-18 system; however, qualification of this system is not expected to be completed until August 198 The current MIZ-12 has limitations due to the increased i.ncidence of tube denting at the support plates. The MIZ-12 system has the ability to suppress the dent response up to an 8.0 mil diametrical dent. After that point the system begins to lose the ability to suppress the den The MIZ-18 system has improved dent suppression ability and therefore, will improve on flaw detection in the dented support plate regions where the Palisades SG's have experienced circumferential cracking of SG tubes; In December of 1987, the licensee utilized a MRPC probe with the MIZ-18 to characterize the circ~mferential cracking.. This procedure.

is too slow to use as a 100% ET inspection tool; however, it-is a practical tool to use in selected suspected tube degradation areas such as support plate #1 The licensee did utilize this inspection tool for 240 tubes at support plate #13; howe~er, three additional crack-like indications were identified in this sampl This is the basis for the NRC inspector concluding that the ET examinations performed this outage did not assure the SG tubes do not have additional cracks. Also it i~ the NRC inspector's opinion that additional ET examinations should have been performed in the upper support plates (11, 12, 13) and in the "Tab" of the 3rd support plate utilizing the *MRPC MIZ-18 syste The NRC inspector attended a NRC/NRR meeting in Headquarters with the licensee on February 10, 1989, to discuss the steam generator safety issue The concensus of this meeting was that the licensee could start up the plant based on the li~ensee's conservative leak detection and plant shut down procedure The licensee will ~ddress additional NRC questions concerning steam generator safety issues for future operations within 14 days..

The licensee's eddy current program complies with the Palisades Technical Specification requirement No violations or deviations were identifie.

Management Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1)

on February 6, 1989 to discuss the results of the Steam Generator Tube Inspection and on February 16, 1989 to discuss the scope and findings of the.Resident inspectio In addition, the inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents/processes as proprietar