IR 05000255/1992001

Corrected Pages 11 & 12 to SALP Rept 50-255/92-01.Correction Reflects Retraction of NOV 50-255/92-04-01

ML18058B001
Person / Time
Site:	Palisades
Issue date:	08/04/1992
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18058B000	List: IR 05000255/1992001 ML18058A999
References
50-255-92-01, 50-255-92-1, NUDOCS 9208110240
Download: ML18058B001 (5)

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LINE 47-52 LINE 40-41 ENCLOSURE 1

• REVISION SHEET NOW READS Two Severity Level IV violations were also issue nnn n+ +""-nrn............

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'" "'"'""""'"' '""u1 u'C~1~11 \\..U11t..ru1, 1ur which a design change in 1986 was not implemente The other violation was in the area of-corrective action. This was the second time within the last three SALP periods that the licensee had failed to take the corrective action stated in its response to a previously issued Notice of Violatio SHOULD READ One Severity Level IV violation was also issue It wa~ in electrical design control, for which a design change in 1986 was not implemente *

NOW READS Program requirements were not completed and commitments made in response to a Notice of Violation were not performe SHOULD READ (deleted)

Basis:

Notice of Violation 255/92044-01 was retr~cted by NRC letter to Consumers Power Company dated July 9, 199 I 9208110240 920804 PDR ADOCK 05000255 G

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E~CLOSL'RE 2 wo k with the security department in identifying pertinent. information on pro cting vital equipment to improve tactical response capabilitie Manag ent also began program planning* for replacing the card reader and comput portion of the access control syste Security affing was goo The experience level of the guard force was high as a result of low turnover~ A close and effective liaison existed between local law en rcement agencies and licensee security manager During this assessment per*od, the security managers continued to routinely keep both resident inspec rs and regional personnel fully informed of site security issues. Security operational events were properly identified, analyzed, and

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~uy::> wi::re c:ompieie, well marntarnea, and readily retrieva le. A timely program was implemented to heighten security awareness during the rsian Gulf conflic The training and qua1ifi tion prog~am for the security force wa~ goo In the

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middle. part of the assessm t period, an outside contractor with tactical training expertise was hired.- This tion h~lped correct the weakness identified in.the previous p*eriod regarding the eed for additional and more effective tactical response training. Security p sonnel were competent in executing their dutie * Performance Rating Performance is rated Category 1 in thi Category 1 during the previous Recommendations Non Engineering/Technical Support Analysis area.. Performance was r~ted perio Evaluation of this functional area.was based on the lts of 14 routine inspections, an electrical distribution system functiona inspection (EDSFI),

a modified operational safety team inspection (OSTI), 3 o rator licensing examinations, and interactions among th~ licensee and NRR s aff Enforcement history-was wea One Severity Level III violatio was issued for a*progralMlatic breakdown*in the area of piping and pipe support esig However, much of the inspection information which resulted in thi violation was discussed in the previous SAL This violation was similar in ature to the Level III violation issued i~ th~ previous assessment period. S sequent*

corr~ctive actions and root cause evaluations were adequate and appea d to be comprehensiv Two Severity Level IV violations were also issue of these was in electrical design control, for which a design change in was not implemente The other violation was in the area of corrective ac io This was the second time within the last three SALP periods that the licens had failed to take the corrective action stated in its response to a previous issued Notice of Violatio. '

ENCLOSURE 2 work with the security department in identifying pertinent information on protecting vital equipment to improve tactical response capabilitie Management also beg~n program planning for replacing the card ~~ader and computer portion of the access control syste Security staffing.was goo The experience level of the guard force was high as a result of low turnover. A tlose and effective liaison existed between.*

local law enforcement agencies and licensee security manager During this*

assessment period, the security managers continued to routinely keep both resident inspectors and regional personnel fully informed of site security issues. Security o~eratinnal PVPnt~ wPrP ~rn~~r1~ ~~o~t~f~~~. ~~~~y~:~, :~~

documente Security-related records and logs Were complete; well maintained~

and readily retrievable *. A timely program was implemented to heighten security awareness during the Persian Gulf conflic The training and qualification program for the security force w~s goo In the middle part of the assessment period, an outside contractor* with tactical training expertise was hired. This action helped correct the weakness identified in the previous period regarding the need for additional and more*

effective tactical response training. Security personnel were competent.in executing their dutie.

Performance Rating Performance is rated Category 1 in this are Performance was rated Category 1 during the previous assessment perio.

Recommendations Non Engineering/Technical Support Analysis Evaluation rif this functional area was based on the results of 14 routine inspectioris, an electrical distribution system functional inspection (EDSFI),

a modified operational safety team inspection (OST!), 3 operator licensing examinations, and interaction~ among the licensee and NRR staff Enforcement history was wea One Severity.Level III violation was issued for a programmatic breakdown in the area of piping and pipe support design. *

However, much of the inspection information which resulted in this violation was discussed in the previous SAL This violation was similar in nature to the Level III violation issued in the previous assessment period. Subsequent correttiv~ actions and root cause evaluations were adequate and appeared to be comprehensiv One Severity Level IV violation was also issue It was in electrical design control, for which a design change in 1986 was not*

implemente *

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I ENCLOSURE 2 RE: VIS/tJ/i S'H£E:T

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Sever l LERs were attributed to this functional area. Approximately half of the LE discussed failure to meet EQ commitments *associated with Regulatory Guide (

) 1.97. Many of these resulted from the licensee's re~iew of the conttacto report discussed belo The remaining LERs were issued for inadequate esign controls. Most of the lERs were the.result of activities in

~revious ass ssment periods~

Mariagement eff tiveness in ensuring quality remained mixe On the positive side, the system engineering.program, established in the mid~l980s, was well implemente Sys m engineers were involved in the daily operation and performance of ac:c:i nPrf cyc:tPmc:

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~1. ~~-:11i.i;-.Y;"!:l trends in system per rmance, identifying equipment problems, and planning maintenance activitie The configuration control project continued to make good progress. *For ex le, se~eral original plant electric design deficiencies were identi ied. Relocation of corporate engineering resources to the site significantly "mproved engineering support of the plan The EDSFI found design devel ment and implementation for the electrical distribution system were satis actory. For the most part, design attributes were retrievable and verifiable, although some modification documentation, such as for the unbolted diesel silenc rs, ~as not retrievable. Engineering calculations were technically soun although some nonconservative assumptions were identified in cable sizing and esign calculations. Most of these problems were associated with initial desig Improvement in design control was noted for recent design activities. This had been an area of concern during the previous assessmen Management*s effectiveness in the area of

~rater requalificatibn and initial operator examinations improved from the prev*ous*assessment period partly as a result of the add~tional* personnel assigned t the training staff. The relocation of the training simulator to the plat training building had a positive impact due to increased accessibilit On the negative side, management's effectiveness in controlling the EQ program was poor. Although the licensee hired a contractor study the EQ program, it did not provide sufficient staff and attention to* view the problems identified in a report by the contractor and to take co rective action. A detailed review of the report was not completed until a ar after it was received. Similarly, management involvement and control o the RG 1.97 program was not effective. Program requirements were not completed and conmitments made*in response to a Notice of Violation were not performed. Managers also failed to apply the necessary attention and resources in the p ogram for*

procuring and dedicating conmercial grade components for safety elated applications. Finally, weakne~ses were identifi~d by the EDSFI post~modification testin The approach to. the identification and resolution of technical issues from a safety standpoint was mixe On the *positive side, system engineers p pared quarterly system performance monitoring reports on all systems in which selected system perfoimance indicators were trende The reports identi *ed adverse component trends and were an effective predictive maintenance too The system engipeers also routinely demonstrated a conservative approach in

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ENCLOSURE 2 Several LERs were attributed to this functional area. Approximately half of the LERs discussed failure to meet EQ commitments *associated with Regulatory Guide (RG) 1.9 Many of these resulted from the licensee's review of the contractor report discussed belo The remaining LERs were issued for inadequate design controls. Most of the LERs were the result of activities in previous assessment period Management effectiveness iil ensuring quality remained mixe On the positive side, the system engineering program, established in the mid-1980s, was well implemente System engineers were involved in the daily operation and performance of assigned systems and supported plant maintenance in identifvin~

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>.Y:::. i.em performance, i cient 1 tying. equ 1 pment problems, and planning maintenance activities. The configuration control project continued to make good progres For example, several original plant electric design deficiencies wer~ identified. Relocation of corporate engineering resources to the site significantly improved engineering support of the plan *

The EDSFI found design development and implementation for the electrical distribution system were satisfactor Fo*r the most part, design attributes were retrievable and verifiable, although some modification documentation,

such as for the unbolted diesel silencers, was not retrievable. Engineering calculations were technically sound, although some nonconservative assumptions were identified in cable sizing and design calculations. Most of these problems were associated with initial desig Improvement in de~ign contrril *

was noted* for recent design activities. This had b~en an area of concern during the previous assessmen Manage~ent's effectiveness in the ~rea of operator requalification and initial~

operator examinations improved from the previous assessment period partl¥ as a result of the additional personnel assigned to the training staff. The relocation of the training simulator to the plant training building had a positive impact due to increased accessibilit On the negative side, management's effectivenesi in controlling the EQ progtam was poo Although the licensee hired a contractor to study the EQ program, it did not provide sufficient staff and attention to review the problems identified in a report by the contractor and to take corrective actiOn. A detailed review of the report was not completed until a year after it was receive Simil~rly, management involvement and control of the RG 1.97 *

program was not effective. Managers also failed to apply the necessary attention and resources in the program for procuring and dedicating commercial grade components for safety-related applications. Finally, weaknesses were identified by the EDSFI team in post-modification testin The-approach to the identification and resolution of technical issues from a safety standpoint was mixe On the positive side, system engineers prepared quarterly system performance monitoring reports on all systems in which selected system performance indicators were trende The reports identified adverse component trends and were an effective predictive maintenance too The system engineers also routinely demonstrated a conservative approach in

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