IR 05000255/1996007

Insp Rept 50-255/96-07 on 960615-0726.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML18065B280
Person / Time
Site:	Palisades
Issue date:	10/01/1996
From:	NRC/RGN-III
To:
Shared Package
9610090260A	List: IR 05000255/1996007
References
50-255-96-07, 50-255-96-7, NUDOCS 9610090269
Download: ML18065B280 (36)

Text

U.S. NUCLEAR REGULATORY COMMISSION -

• REGION I II Docket No.:

License No.:

Report No.:

1 icensee:

Facility:

Location:

Dates:

Inspectors:

-*Approved by:

9610090269 961001 PDR ADOCK 05000255 G

PDR 50-255 DPR-20 50-255/96007(DRP)

Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway -

Covert, MI 49043-9530 June 15 through July 26, 1996 M~ Parker, Senior-Resident Inspector P. Prescott, Resident Inspector K. Salehi, Reactor Safety Inspector N. Jackiw, Reactor Projects Inspector J. Neisler, Reactor Safety Inspector C. Orsini, Resident Inspector R. Paul, Radiation Specialist R. Glinski, Radiation Specialist T. Madeda, Security Inspector

• w. J. Kropp, *chief **

Reactor Projects Branch 3

EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRC Inspection Report 50-255/96007 This integrated inspection included.aspects of licensee operation~,

maintenance, engineering and plant suppor The report covers a 6-week period of resident inspection; in addition, it includes the results of announced inspections by.regional reactor safety inspectors, radiation protection specialists, a security inspector, and a projects inspecto Operations

The licensee's use of the simulator to prepare operators for an infrequently performed evolution was considered a strength. However,

, the inspectors identified a weakness in operator knowledge of procedural

• guidance concerning temperature change limitations on the low pressure turbine (Section 01.2)~

The inspectors concluded that the SFP heatup test was performed with the use of daily orders and within the limitatJon~ of SOP-27 (Section 01.4).

Problems with balance of plant feedwater heaters challenged plant

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operators and could have impacted safe op~ration of the plant (Section 01. 5).

Licensee actions to replace the overcurrent r~lay for the high pressure safety-injection pump P-6A were considered well -Organize However, the inspectors *noted that spare parts for the relay were not available in inventory and this had the poten~ial of challenging the *availability of the safety injection pump. The issue of unavailability of spare parts was-mentioned in the two previous inspection reports *(Section 01.6).

Maintenance

The inspector's review of operations and maintenance performance for the planned maintenance outage for repair of a leaking condenser tube were

_~ell managed and 1 ed _to_ a safe outage (S_ect ion _Ml. 2).

Engineering

• The inspectors revi~wed the cable ampacity margin issue and concluded that the cables in question are operable, pending.completion of a licensee engineering revie The review is to confirm that the cables have sufficient ampacity to prevent overheating in the cable trays

• • • csection*El.1).-

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The.inspectors identified that during a system walkdown with the system engineers, that written guidance or standards to ~erform a walkdown had not yet been issued but were under development (Section El.2).

The inspectors concluded that system engineering had maintained good monitoring and oversight of the primary coolant pump motor upper oil reservoir and seal staging pressure oscillations (Section El.3 and El. 4).

Plant Support

The Radiological Environmental Monitoring Program (REMP) was effective and well implemented, and the results indicated no discernable impact on the environment from plant operations (Section Rl.2).

• Reactor water quality continued to be maintained within Electric Power Research Institute (EPRI) guidelines and plant limits {Section Rl.3).

• The chemistry laboratory demonstrated proficiency in radiological and ana~ytical capabilities as evidenced by its performance in inter-and intracomparison analyses (Section R7.l).

• Regular function tests and high operability of the chemistry sampling stations, the post accident sample monitor, the in-line monitors, and the REMP air sampling equipment indicated no material condition concerns (Section R2.l).

The inspectors observed weak monitoring of personnel search activities.

Corrective measures addressing a similar finding were not totally effective (Section Sl.l.b[l]).

The inspectors identified a vulnerability regarding monitoring of some intrusion alarm status points in the alarm station (Section Sl.l.b[2]).

I * ~

• Report Details Summary of Plant Status On June 21, 1996, unit power was decreased to 40 percent for a scheduled maintenance outage to identity and plug condenser tube leak The event is detailed in this repor Full power was.resumed on June 2 On July 1, operators commenced a derate and on July 2, 1996, took the unit off-line due to an oil leak on the P-500 reactor coolant pum The unit was returned to service on July 4, 1996. This event is also detailed in the repor For the remainder of the inspection period, the unit remained at full powe I. Operations

Conduct of Operations

01.1 General Comments (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operation In general, the conduct of opera-tions was professional and safety-conscious; specific events and noteworthy observations are detailed in the sections belo.2 Main Turbine Valve Testing Inspection Scope (71707 and 61726)

On June 21, 1996, the licensee decreased power to conduct main turbine valve testing in accordance with Procedure No. SOP-8 "Main Turbine Generating Systems," Attachment 2, Revision 3 The licensee continued to reduce power following testing to* perform condenser tube inspection and repai The inspectors observed portions of the testing and downpower evolutions and reviewed the operating procedur Observations and Findings Not a 11 licensed operators have had exfens i ve experience *with startups and shutdowns and the use of SOP-8 since installing the digital turbine control system in 1992. Therefore, the licensee used the simulator to a 11 ow the operators to. f ami l i ari ze themselves with the procedure, the control system, and to simulate*communication with in-plant operator The inspectors did identify one concern regarding the operators

-~k-n.owledge* of expected conditions during one portion of the testin Step 1.1.2 of procedure SOP-8 contains a caution to not reduce the 1Topical headings such as 01, MB, etc., are used in accordance with the NRC standardized reactor inspection report outlin Individual reports are not expected to address all outline topic temperature of reheater steam outlet to the low pressure turbine at a rate in excess of l00°F per hou Prior to the performance of this step, the inspectors questioned the control room supervisor (CRS} as to the method with which the operators would control the cooldown rat The CRS responded that the temperature limitations would not be challenged because the manually operated valves could not be closed quickly enough to result in a cooldown rate that hig While performing step 1.1.2, the nuclear control operator noticed that the steam temperature was decreasing more than expected, and was approaching the stated limits. There was some confusion because the procedure did not require temperature to be logged prior to performing step 1.1.2 and there was no guidance provided on actions to be taken should the limits be exceede The crew was also not in agreement as to the impact on plant equipment if the limits were challenge The operators determined that exceeding the temperature limits was imminent, and suspended the valve operations in progres The evolution was resumed after.sufficient time had passed to not challenge the l00°F per hour limi No adverse conditions appeared to result from the temperature chang c. Conclusions The licensee performed the power decrease in a well controlled manne The licensee's use of the simulator to prepare the operators for an infrequently performed evolution was considered a strengt The inspectors did note a weakness in the operator's knowledge of, and the guidance provided in the procedure~ concerning temperature change limitations on the low pressure turbin.3 Plant Shutdown to Repair Primary Coolant Pump Inspection Scope (71707, 62703 and 37551)

On July 1, 1996, the licensee initiated a power reduction to allow containment entry to perform an inspection of primary coolant pump, P-50 Over the previous week the primary coolant pumps' motor upper oil reservoir had show~ a decrease in-oil lev~l. The inspectors observed the 1 i cen.see' s actions to take the p 1 ant of fl i ne to perform necessary pump repair Observations and Findings On July 1, 1996, the licensee initiated a downpower evolution to bring the reactor to a hot standby cond-i ti on (0.1 to 1. O percent power}.

Over the previous 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period, control operators had noted a significant step decrease in the P-500 motors' upper oil reservoir (49 percent to 43.5 percent}.

Prior to July 1, 1996, the control operators and system engineers had been trending a slow steady decline in upper oil reservoir leve The down-power was authorized by plant management to allow an inspection and necessary repairs to P-500 moto The inspectors

. *

observed the control operators take the turbine offline and reduce reactor power to a hot standby conditio Upon achieving a hot standby condition the shift supervisor authorized a containment entry to inspect P-50 Initial report based upon the containment entry, determined that the oil line from the upper oil reservoir was damaged and leakin In order to perform necessary repairs to the oil lines, plant management authorized taking the plant from hot standby to a hot shutdown condition, and securing the P-500 pump, to perform pump motor oil line repairs. The inspectors observed the shift borate the primary coolant system (PCS} to an all rods out critical boron plus 50 ppm and trip the reacto Upon completion of oil line repairs on July 4, 1996, the inspectors observed the control *operators perform appropriate technical specification surveillances prior to returning the plant to a hot shutdown conditio On July 4, 1996, during power escalation following synchronization of the main turbine, control operators observed that the main feedwater temperatures on the plant process computer (PPC} (TT-0708A and TT-0706A}

did not agree with the control room recorders (TR-706}.

This problem was similar to that noted during the power escalation following the condenser tube plugging on June 24, 1996, (paragraph Ml.2}.

In both cases the PPC indicated average feedwater temperatures were not following actual temperatures and were lagging actual control room indication The inspectors observed that the control operators stopped further power escalation and requested the assistance of system engineering. After a further *review into the discrepancy, it was determined that the PPC filtered value for feedwater temperature average was slow or lagging actual feedwater changes, and that the control room recorder was providing accurate reading Further, instantaneous feedwater temperatures from the PPC were determined accurate. After determining the cause of the discrepancy the licensee resumed the power level increase using a manual heat balance calculation as provided for in GOP-12, "Heat Balance Calculation." Additional restrictions consisted of a limiting maximum power level to 90 percent with a maximum power escalation rate of 3 percent to 4 percent per hou c:

Conclusions The inspectors concluded that the operators took appropriate action to stop the power escalation with regard to feedwater flo The inspectors also confirmed that procedure GOP-12 was revised to include a note for the operators that the PPC lagged the actual feedwater temperature changes as compared to the control room indicatio * 01.4 Spent Fuel Pool Heatup Rate Test Inspection Scope (71707)

The inspectors reviewed Procedure SOP-27, "Fuel Pool System," dated November 11, 1995; daily orders for July 9 and July 10, 1996; and

.. *

• station log The inspectors also held discussions with operations personnel, system engineers, and station management regarding heatup rate tests performed on the plant spent fuel poo Observations *and Findings On July ~. 1996, with the spent fuel pool (SFP) temperature at 87°F, SFP cooling pump, P-51A, was stopped in order to determine the SFP heatup rate. This heatup rate data was necessary in planning major SFP work to be done in the beginning of Augus The inspector noted that the daily orders from July 7, 1996, gave instructions to take the demineralizers out of service and to attempt to keep the SFP off recirculation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in.order to collect the heatup data every 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> The inspector also noted that no guidance was given as to what temperature limits should be followed during performance of this test. Based on discussions with the operating shift involved in the testing, the inspector determined that procedure SOP-27, Fuel Pool System, was used for this test. However, the operators were unable to identify the applicable steps being performe Section 4. of SOP-27, required that the temperature of the spent fuel pool to be maintained at greater than 70°F and 1 ess than l 25°F when the SFP contained, irradiated fue The maximum temperature reached was 104° Procedure SOP-27 did not have steps that directly addressed performing a SFP heatup test. Following discussions with station management, the licensee stated that the use of standing orders to perform this test was not the best method and agreed to review this practic Conclusions The inspectors concluded that the SFP heatup test was performed with the use of daily orders and within the limitations of SOP-2.5 Heater Level Control Valve Air Line Failure Inspection Scope (71707 and 62703)

The inspectors attended daily planning meetings, held discussions with operations ~~rsonnel, and reviewed co~trol room chart An event relating to the air line failure on a feedwater level control valve was selected for revie Observations and Findings On July 11, 1996, with the plant operating at full power, the air line to air operated l~vel control valve CV-0602, on the E-6A feedwater heater, broke.due to vibration fatigu The valve failed closed and caused the heater startup dump valve opened, which resulted in a loss of feedwater heating and an increase in power of about 0.5 percent.

• In attempting to isolate the broken feedwater heater air line, the operator closed an air isolation valve, which also isolated air to the

"A" main feedwater pump control As a result, the feedwater pump alarm annunciated in the control room and the operator was immediately instructed to reopen the air isolation valv The "A" main feedwater pump control recovered causing onl~ a minor feedwater.transien Since there was no separate valve to isolate the air leak on the broken feedwater heater air line, the air leak was stopped by crimping the air lin The air line was subsequently spliced with a rubber hose and a temporary air isolation valve was installed, prior to returning the heater drain control valve to servic The plant remained stable during this even In response to the event, condition report C-PAL-96-0752 and a work request to repair the valve's air line were issued. *system engineering performed a walkdown of air lines in the turbine and auxiliary buildings... Work requests.were generated for identified deficiencie Prior to the above event, on July 8, control valve CV-0605 for the heater E-68 developed an air leak in the actuator. This resulted in a high level in the feedwater heater. Actuator spring tension for CV~605 was reduced and level was brought under contro *

c. Conclusions The insp~ctors concluded that operator response to the air line failur was prompt and maintenance actions to repair the leak were prope The operators also responded well to the event on July 8th and prevented a more significant transien The inspector confirmed that system engineering performed a plant-wide walkdown of all air lines. Several discrepanties we~e identified. Management had ~arlier identified.~ir lines as a potential weakness, but no ~ction was take Thes~ events show how operators have been challenged by material conditions on balance of plant systems, which could have impacted safe operation of the plan *

01.6 High Pressure Safety Injection CHPSll Pump T_r.i Inspection Scope (71707, 62703 and 61726)

On July 15, 1996, the licensee was in the process of performing System Operating Procedure SOP-3, "Safety Injection and Shutdown Cooling System," when the HPSI Pump P-66A tripped on a time-overcurrent relay trip. Since the "C" safety injection tank (SIT) T-82C was below its-Technical Specifications *(TS) low pressure limit du~ing sam~lin~ of the

tank, the licensee declared both T-82C and P-66A inoperable and entered T.S. 3.0.3. This event was reported to the NRC, as a 10 CFR 72 non-event report, as required. The inspection involved the review of records~ observation of licensee troubleshooting and testing activities and an independent assessment of licensee's root cause operability analysis and deter~inatio Observation and Finding The inspectors observed and assessed the licensee's activities relating to the troubleshooting and resolution of problems with the time-overcurrent relay for Pump 'P-66A including:

Observation of the pre-job briefing for this activit *

Witness post-maintenance testing activitie The inspectors noted that during filling of SIT T-82C, following collection of a sample to verify the boron concentration of water in the SIT, HPSI pump P-66A tripped on overcurrent. Samples were being tested in all four SITs for a mo~thly surveillance test. SITs "A" and "B" had been sampled and refilled without any problem HPSI pump P-66A was being used to refill the SIT SIT T-82C was being refilled following sampling, when P-66A tripped unexpectedl The licensee's investigation found that the time-over current relay 150/151Y-207, did not reset properly following introduction of starting current during the pump start proces The induction disc of the relay continued to rotate during each pump start instead of resetting (rotating back to its initial position) following ~ach P-66A pump start: The disc rotation continued until the relay contacts were activated, causing the pump to tri Immediate licensee action was to declare the pump inoperable and perform troubleshooting ~n the 15Q/151Y-207 rela No indication of component degra~ation was note The relay was cleaned, the rotating mechanism was exercised and the relay was returned to service. Although, no specifi~ root cause was identified for the failure, the inspectors determined that the investigation was thoroug The inspectors observed three pump start tests performed on this pump and no problems were*

noted. Jhe relay performed as designed. A spare relay was not available onsite. A relay was located at the V. C. Summer station, which was delivered and installed several days late~.

After successful testing of the relay, P-66A pump was declared operable and sampling of the last SIT, T-820, continue The insp~ctors

• independently witnessed the filling of T-82C fo -reach the desired 1eve1 in the tan In addition, the inspectors observed the draining and refilling activities of T-82 The inspectors also accompanied a station chemistry technician while tank T-820 was being sample The boron concentration sample was analyzed and the inspectors witnessed that the test results of 2131 ppm were within TS limits_ of between 1720-2500 pp As interim action, a temporary change was made to procedure SOP-3 to

,observe that P-66A pump time-over current relay on breaker 152-207 reset once the pump starts. The inspectors verified that *the temporary change also included appropriate guidance to identify visually the status of the relay.once the pump has starte *

c. Conclusions The inspectors determined that the license's planned actions to replace the relay were appropriat The pre-job briefing was well organized and included all participants involved in the work activity. The nuclear control ope*rators were aware of the ongoing wor One issue the.

inspectors noted was that while the plant had a large number of relays, similar to the one that failed, the licensee did not have a spare in its inventor This had the potential of challenging the availability of the safety injection pum Lack of spare parts has been an inspector concern detailed in the two preceding inspection report.7 Personnel Airlock Limiting Condition for Operation (LCOl Inspection Scope (61726. 37551. 62703 and 71707)

Th~ inspectors reviewed the.surveillance procedures and test dat The inspectors independently verified calculations performed with the test dat Also, the inspectors observed licensee discussions to resolve the problems encountered during the LC Additionally, portions of the testing were observe Observations and Findings On July 16, 1996, the licensee entered the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Technical Specification (TS) action statement 4.5.2a.(2) to install strongbacks on the containment personnel airlock inner door and placement of a C clamp on the equalizing valve. This was in preparation of the semi-annual full pressure ~~rlock surveillance test S0-4A, "Personnel Airlock Penetration Leak Test." During pressurization of the airlock, the.test pressure of approximately 60 psig could not be reache The maximum pressure attained was 49.9 psig, which decayed to 47 psig in 20 minute The licensee immediately terminated the surveillance-tes The inspectors observed licensee discussions to troubleshoot the proble The lice'nsee determined that perhaps temperature v_ariations may -have affected pressure readings~ Also af that time, the licensee performed leak checks on the outer door and bulkhea The airlock was repressurized, and appeared to stabilize at 49.4 psi However, over a one hour* period, pressure decreased to 46 psi The licensee performed leak checks on the outer door, with no observable leaks detecte The outer door was then locked closed, as required by TS 4.5.2c.(3), due to suspected degradation of the inner door seal or equalizing valv *

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As a result of the personnel airlock outer door being locked closed as required by TS, the licensee made a containment entry via the emergency escape airloc The licensee detected leakage on a lower portion of the inner door seal. Further S0-4A testing was aborted and the personnel airlock was depressurize The inspectors observed troubleshooting discussions held by the license The licensee determined the outer

• door should be proven operable by a between the door seals test DW0-13,

"LLRT-Local Leak Rate Test for Inner and Outer Personnel Air Lock Door Seals." The DW0-13 surveillance test faile The licensee entered a one hour limiting condition for operation (LCO} to begin shutdown per TS 4.5.2c.(2}, which required that within six hours the plant should be placed in.hot shutdown and 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to cold shutdow The licensee entered the personnel airlock and "fluffed" the seals of the outer doo The term fluffed is a common licensee term to describe pulling the seals out of the door, after they have been compressed to give better resiliency. Also on this entry, it was discovered that the lower strongback on the inner door did not appear to have been properly torqued, which was then torqued to the correct specifications. A DW0-13 surveillance was performed satisfactorily on the outer doo The licensee stopped the plant derate at approximately 99 percent powe A one hour non-emergency 10 CFR 72 notification was made to NRC, due to a shutdown initiated in accordance with TS 4.5.2c.(2}.

The licensee re-performed surveillance S0-4A satisfactorily, and after removing the strongbacks, performed successful DW0-13 surveillances on both personnel airlock door Due to entries through the escape airlock to troubleshoot the personnel airlock, a S0-4B surveillance test was performed and passed on the escape airloc Technical Specification Observations (1)

During the troubleshooting effort, the residents expressed concern to the licensee over their interpretation of TS 3.0.5. The interpretation of the paragraph became a nonissue when the outer door failed the DW0-13 surveillance, which then made both doors inoperabl Initially, the licensee considered utilizing TS 3.0.5, as a vehicle for authorizing entry into the personnel airlock to perform necessary repairs to the inner door, had the outer passed the DW0-13 surveillanc The part of TS 3.0.5 pertinent to the discussions states, "Equipment removed from service or declared inoperable to comply with action requirements may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment."

The licensee interpreted this to mean that had the outer door DW0-13 surv_eillance passed, it would.. have been acceptable to breach containment integrity by opening the outer door and make the necessary repairs or adjustments to the inner doo The inspectors questioned this approach as the purpose of entering the outer door was not for testing purposes but to perform necessary repairs to the inner doo The inspectors viewed this as maintenance and not a normal part of testing. Also, this would have meant breaching containment integrity in order to effect repairs. This would conflict with TS-4.5.2c.(3},-which requfred that the remaining operable door be locked.close (2)

During a previous event, documented in licensee event report (LER)95-002, the licensee determined that it was in violation of TS to enter the outer personnel airlock door to correct or identify potential problems with the inner door if it was considered inoperable, and that the outer

door should be locked and sealed close In the 1995 event, the inner door seals were being tested and the required test pressure of 15 psig quickly decaye The operator performing the test was instructed by the control room supervisor to enter the personnel airlock and verify that the inner door was closed tightly~ The licensee determined that based on the inner door seal leak rate and the temporary opening of the outer door, entry into the airlock violated containment integrity requirement (3)

In observing licensee discussions with regard to TS interpretations, the licensee referenced improved standard technical specifications (ISTS),

which allows passage through the airlock doors under administrative controls for up to 7 days with one airlock door inoperabl In interpreting their TS, the licensee evaluated the acceptability of allowing passage through the only operable personnel airlock doo The licensee reviewed their TS position against the STS position and considered STS as a basis to allow entry through the airlock door, as the NRC had accepted this position in IST While the inspectors believe the licensee ultimately took the appropriate steps in conforming with their TS, the licensee is cautioned that utilizing ISTS in this regard could lead to a non-conservative interpretation of their TS, as their TS are not based on IST The licensee must ensure compliance with the literal wording of their T Conclusions The inspectors noted that observed interdepartmental meetings to identify and resolve the airlock leak were open and led to good discussio Personnel involved, from senior management to mechanical*

maintenance personnel, actively participated in the discussions, and effected appropriate repairs to the containment personnel airloc However, the inspectors concluded that proper torquing of the strongback would have resulted in a successful surveillance tes In addition, the licensee had prior opportunity to address the TS issue and reduce the overall impact to the plant had they taken timely corrective action consistent with their response to LER 95-00 Miscellaneous Operation~ Issues * (92700)

0 (Closed) Inspection Followup Item CIFil 50-255/94014-67: Ineffectiveness of management to provide adequate control and oversight. Closure of this item was pending NRC review and evaluation of the licensee's Palisades Performance Enhancement Program (PPEP), which contained action plans to address this issu The PPEP was meant to be a living

- -doeument, to be consta~tly reviewed and revised t~ assure that 'docume~t guidance was consistent with licensee corporate visio The inspector reviewed several action plans including:

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Review and revision of the "Business Plan" and "Nuclear Operations Department" (NOD) guid The draft revisions were subject to review and comment by direct reports to the vice president. This assured buy-in of the strategies and focus areas by the plant management tea Management communicated the document's strategies to employees, contractors and vendor *

Development of the "Roles and Responsibilities document, which established detailed specific management position roles and responsibilitie *

Management conducted standdown meetings on a frequent basi These meetings, in which all site personnel attended, provide a forum for discussions on roles and responsibilities, expectations, and standard *

The NOD developed a "Professional Competency Model" document. Ii was based on supervisory and managerial performance needs and was expanded to address the performance results and competencies required of all professional *

A management Performance Monitoring Report was develope Each department manager used the report to monitor trends within their respective departmen If discrepancies occurred, the department*

manager was expected to identify the problems and align the department to initiate appropriate corrective actio Administrat~ve Procedure 1.09 "Self Assessment," was developed from other nuclear utilities and from within Consumers Powe The procedure defines levels of self-assessment and methodology, a reporting plan, and management expectations. Training of personnel was provided on the procedure.

. Although not all -0f the licensee actions to address this issue were discussed, the.items mentioned above were the framework for more*

specific actions taken to improve management effectiveness. The inspectors, on a daily basis, assess management effectiveness. Since

_t~e DET, progress in this area has been noted and the lic_ensee_ continue$ ___ -~---- _

to strive for improvemen This item is close (Closed) IFI 50-255/94014-68:

Failure of the licensee to integrate programs and processe Some of the licensee management actions that addressed in IFI 50-255/94014-67, were determined pertinent to this issue. Closure of this item was pending NRC review and evaluation of the licensee's PPEP, which contained action plans to address this

- issu*e:*- Some additional. action plans reviewed were:-

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Procedure 3.03 "Corrective Action (CA) Process" was implemented and described the CA syste The CA system was used to document and track progress, evaluate, correct and report conditions adverse to quality or safet Any deficiency that required CA had

• 0 *

a condition report (CR) written to identify and track or trend a proble The inspectors reviewed this process and found it was well implemente Licensee ma.nagement had effectively used standdown meetings as a tool to identify existing programs and processes that needed clarification. Also, the meetings were used to outline new programs that management had been preparing to institut Management Performance Monitoring Report, with its performance indicators, provided a tangible method to management of measuring progress of various departments, which should also be indicative of program and process integration effectivenes One action plan was developed to enhance the operability determination process. Training was provided for Generic Letter 91-18.for supervisory personnel and technical staff involved in equipment operability issue The inspectors noted that, coupled with better identification of operability issues through the CR reporting process, operability determinations have shown improvemen In recent inspection-reports, the inspectors identified wea~nesses i~

the temporary modification and design basis document review 'processe The inspectors determined the licensee focused adequate attention on these processe In general, the licensee continued to improve in the

• area of integrating programs and processe When weaknesses are found, management focused adequate attention to resolve the issue(s). This item is close (Closed) IFI 50-255/94014-69:

Failure to provide clearly.defined roles and responsibilitie Some of the lfcensee management actions that addressed IFI 50-255/94014-67, were determined pertinent to this issu Closure of this item was pending NRC review and evaluation of the licensee's PPEP, which contained action plans to address this *issu Some additional action* pl~ns revi~wed were:

The lic~nsee issued the "Nuclear Operations Department Business Pl an. II This d'ocument out 1 i ned the basic philosophy of the NO The document outlined, in a broad sense,, expectations of managers and personnel within the NO The document also outline future goals and actions tha't would be necessary tq achieve those goals

The licensee issued the*"Nuclear Performance Assessment Department (NPAD) Position Description." This clearly delineated the roles

-- and responsibilities of NPAD management positio-ns.-- It alSC>

outlined experience, training, and qualification requirements.

In addition, the inspectors, through daily observations of licensee management, determined that management personnel adequately understood their individual defined roles and responsibilities.. This item is close.4 (Closed) IFI 50-255/94014-72:

Licensee was not effective in addressing problems associated with human performanc Some of the licensee management actions that addressed IFI 50-255/94014-67, 68, 69 and 71, were determined pertinent to this issue. Closure of this item was pending NRC review and evaluation of the licensee's PPEP, which contained action plans to address this issu Some additional action pl ans reviewed were:.

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One of the more recent changes to address human performance issues involved root cause analysis of events. Often, licensee personnel directly involved in an issue will take part in the root cause investigation for closing out a condition report trending that particular issue. The condition report process also aided management in identifying adverse human.performance trends. This has enabled management to identify and develop a solution for the adverse tren *

Recently, NRC inspectors concluded the licensee had taken actions to adequately address several training weaknesses {see inspection report {IR) 96005, section 8). Also, in IR 50-255/95014, several items*were closed that addressed operations human performance issues. The specific items closed were 50-255/94014-02,08,09,20,23 and 2 *

The m~nagement performance monitoring report has allowed management to identify weaknesses in human performance by trending various data point Some data points trended that would be*.

indicative of peak human performance are switching and tagging order compliance, operator avoidable occurrence~, repeat maintenance items and personnel contamination dat The inspectors were aware of several other licensee actions to address this issue. This ite~ is closed..

• II. Maintenance Ml Conduct of Maintenance

M General Comments Inspectio~ Scope (62703 and 61726}

The inspectors observed all or portions of the following work activities:

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WO 24511374:

WO 24513293:

WR 267296':

WO 24611462:

Surveillance Activities

RI-41:

RI-21:

DW0-13:

SOP-4A:

SOP-4B:

..

Charging pump P-55A repacking and motor refurbishment NOT block and valve for P-55A Safety Injection Pump time-overcurrent relay Breaker preventive maintenanc Rod Withdrawal Prohibit and Interlock Matrix Check Conirol Rod Drive System Interlocks Personnel Airlock Door Test.

Personnel Airlock Penetration Leak Test Escape Airlock Penetration Leak Test Observations and Findings The inspectors found the work performed under these activities to be profes~ional and thorough. All work observed was performed with the work package present and in active us The inspectors frequently..

observed supervisors ahd system engineers monitoring job progres When applicable, appropriate radiation control measures were in plac c. Conclusions The inspectors observed good procedure adherence practice In addition, see the specific discussions of maintenance observed under and Ml. 2, belo Surveillance activities are included under "Maintenance". For example, a section involving surveillance observations might be included as a

separate sub-topic under MI,

"Conduct of Maintenance."

Ml.2 Unit Oerated to Repair Condenser Leak Inspection Scope (71707 and 37551)

On June 21, 1996, the unit was derated to 40 percent power for a scheduled maintenance outage to locate and repair a condenser tube leak in the east water bo The unit was returned to normal operation on June 24, 1996. The inspectors reviewed records and interviewed plant personne Observations and Findings Using eddy current testing, the licensee identified the leaking condenser tube, visually inspected* the tube and repaired the leak by plugging the tube. Additionally, the licensee eddy current tested approximately 40 other tubes and cleaned debris from six rows of tube Following repairs to the condenser tube and cleaning of the water box, the circulating flowrate increased from approximately 20,000 to 25,000 gp Power escalation to full power was initiated following completion of condenser repairs. During startup activities, the nuclear control operator noted that the primary coolant heat balance showed excessive differences between feedwater temperature indicated on the plant process computer (PPC) and the control room recorder.* An immediate manual heat balance was performed and revealed that the nuclear instrumentation (NI)

values were within limit Investigation by the licensee identified that the PPC filtered value for feedwater flow and temperature provided to the heat balance calculation was slow in responding to feedwater change The root cause was determined to be a computer software problem which was resolved per software change package SCR 03 c. Conclusions The inspector's review of records and logs, and interviews with personnel, indicated licensee actions during the outage were safety conscious and appropriate. The inspectors observed portions of the power escalation. Conservative actions were noted of the operations personnel.-

MB Miscellaneous Maintenance Issues (92902)

M (Closed) IFI 50-255/94014-70:

Causes for problems and events observed during outages were not unique to outage perio The causes included ineffective communication, coordination scheduling, planning,

.. supervisory oversight, project management and poor implementation of lessons learned. These.causes, along with weak oversight of work contributed to problems during normal operations and outage Some of the licensee management actions that addressed IFI 50-255/94014-67, 6B and 69, were determined pertinent to this issue. Closure of this item was pending NRC review and evaluation of the licensee's PPEP; which

• contained action plans to address this issu Some additional action plans reviewed were:

To control contractors, the licensee issued a directive that work authorization was required prior to contractors performing wor *

The work request backlog has seen a significant decrease since the DE The licensee has developed the Fix-It-Now team to address emergent work issues. Control of emergent issues has meant improvement in keeping the 13 week rolling schedule on trac *

Time sheets were developed to assist management in the tracking of personnel resource Adequate management oversight of projects such as dry fuel storage and reactor vessel annealing has been eviden Communications of lessons learned has been communicated to personnel by management at standdown meetings. This item is close M (Closed) IFI 50-255/94014-71:

Failure to provide proper resource allocation and utilizatio Some of the licensee management action that addressed IFI 50-255/9.014-67, 69 and 70, were determined pertinent to this issue. Closure of this item was pending NRC review and evaluation of the licensee's PPEP, which contained action plans to address this issu Some additional action plans reviewed were:

• Licensee management's two major tools for control and utilization of resources are the management performance monitoring report and monthly management review meetin Management used the report to track upcoming milestones and events and identify potential problems that may require additional resource Each manager has a section of the report which details and trends items requiring that department's attention and resource *

The other licensee management tool is the monthly management review meetin At this meeting, the monthly performance monitoring report is updated and a status given by the respective department manager on the various items, if discussion is require Prior to the meeting, the departmen~ managers update the report to identify items that may require additional resource A long range management tool was also developed in response to DET findings on this issu The five year plan looked at the financing required for departments and upcoming projects for the next five years..

This- -item-is -close *

El El. I Conduct of Engineering Cable Ampacity Inspection Scope {37551)

III. Engineering The inspectors reviewed calculations, guidelines, engineering analyses, condition reports, drawings and cable lists relative to cable ampacity margin Observations and Findings The licensee reported that on July 11, 1996, while comparing the plant condition to the FSAR, they had determined that a number of cables did not meet the thermal design basis stated in Section 8. Specifically, power cables in overfilled trays had not been analyzed to confirm that existing loading conditions are acceptable. * The FSAR states that cable ampacities are adjusted based on actual field condition when possible. Condition report C-Pal-96-0756 was issued to provide tracking and initiate corrective action Preliminary s~reening of 13 cable trays containing 165 circuits indicated 37 cables have a potential to be overloaded u~ing the criteri~ *

in Institute of Electrical and Electronic Engineers '(IEEE) paper 94WMI00-8PWR The IEEE paper differs from the standard used in the initial design calcul~tion, Insulated Cable Engineers Association (ICEA)

P-54-440, in that ICEA assumes all *cable~ in a tray are energi.zed and fully loaded, while the IEEE paper takes*into account that all cables are not loaded all the tim Licensee and contractor reviews found seven cables that overlapped both the ICEA and IEEE criteria and will need additional analysis.. The licensee's preliminary calculations show ampacities to be significantly reduced in these cables when calculated by either the ICEA or the IEEE method The inspector questioned whether changing from the ICEA to the IEEE calculation method represented a change to the FSAR as described in 10 CFR_ 50.5 The licensee representative did not consider-the use of --

~lt~rnate calculation methods to be a change to the FSA This issue will be further reviewed during a future inspectio The licensee determined the cables to be operable based on all the cable trays being lightly loaded at any one time and that measured temperatures within the cable trays were near room temperatur They are currently reviewing the ampacity of all cables carry-ing safety-"-~-~ --

- r~lited or balance of plant loads that impact plant s*fety and reliability. The inspector will review the licensee's completed ampacity analysis and the resulting corrective actions during a future inspection. IFI (50-255/96007-01)

Based on the inspector's review of cable calculations and actual loading of the cable, including some tray walkdowns to observe cable tray fill, the inspectors concurs with the licensee's operability assessmen c. Conclusions The inspectors concluded that the cables in question are operable pending the licensee's completion of ongoing ampacity studies to confirm that the cables have sufficient ampacities to prevent overheating in the cable tray El.2 Engineering Svstem Walkdown Inspection Scope (71707 and 37551)

The inspectors held discussions and walked down the east and west safeguards equipment rooms with two system engin~er Observations and Findings The inspectors conducted a system walkdown with the applicable system engineers, for the associated equipment located in the e~st and west safeguards equipment room The following items were identified that could pre.sent a ris~ t~. safety related equipment:

The inspectors identified two large metal tool boxes, approximately 4' x 4' x 6'*, that were on wheels and did not have the wheel locks locke The engin~ers locked these Wheelsi

The inspectors identified that the chain on a chain fall could-swing during a seismic event and breik the sight glass on a safety injection pum The engineers corrected this situatio Discussion with the engineers revealed that the system walkdowns are performed without taking into the field, a checklist or written guidanc Each engineer does what they think they need to do, which could result in varying standards for the walkdown The previous day during an engineering standdown meeting, ~anagement announced written.

guidance for wa-lkdowns was being develope The quality of ehgineerTng ___ _

walkdowns will be evaluated during further inspection c. Conclusions The inspectors concluded that the system engineers had missed the above identified potential seismic_ hazards and did not have written guidance to. perform. system walkdowns.-

However-, engineering management announced that written guidance for walkdowns was under developmen *

El.3 Reactor Coolant Pump P-500 Oil Leak Inspection Scope {71707 and 37551)

During the week of June 24, 1996, the system engineer, for the Primary Coolant System, noted an anomalous decreasing trend in the P-500 upper oil reservoir level. After review and evaluation of this condition, the licensee determined that the pump was still operable, but degrade The Inspectors monitored the licensee's actions to.resolve this issu Observations and Findings The inspectors, during *the week of June 24, 1996, initiated an *

independent evaluation of the licensee's activities and proposed plans for locating and repairing the oil leak on P-50 Interviews with the system engineer revealed that he had discovered the decreasing oil level during a routine system walkdow The system erigineer maintains operational data on all four reactor cdolant pumps on a routine basis and had noted that the oil level which is normally at about 80 percent had been steadily decreasing and on June 28 1996, was at about 50 percen Based Qn the rate of oil level decrease and a ~udden drop of about 1 percent-2 percent in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the licensee developed a plan to come down in power to about 2 perceDt and locate and repair the leak.

The inspectors attended a planning meeting were the licensee discussed the details of their plan. 1he inspectors noted that the licensee appropriately addressed ALARA considerations in their plan and also reviewed the impact of previous containment entries during powe The inspectors confirmed that the licensee focused on safety in their planning activitie Conclusion The inspectors witnessed that the licensee was aggressive in pursuing the decreasing oil level in primary coolant pump P-50 The inspectors were present during the planning meeting on June 28, 1996, and concluded that safety was a dominant concern ~uring the internal planning discussions..

El.4 Primary Coolant Pump. P-500. Seal Failure Inspection Scope (71707 and 37551) *

--**-----* -*-

Following the forced outage on July 2, 1996, to repair P-500, increased

.

seal pres~ure Qscillations..arid seal stage leakoff flows were* observed:----.-~--

The inspectors attended plant status meetings and briefings, observed control room indications, and held discussions with control operators, system engineers, and the plant manager *

• Observations and Findings Following the forced outage to perform repairs to primary coolant pump, P-500, the inspectors observed increased oscillations on the seal stage pressure recorder in the control roo The pressure oscillations were significant at times, creating spikes that actuated control room annunciator The inspectors observed that primary coolant pump, P-500, had seal stage pressure spiking and increased seal leak-off flo These spikes were discussed at the morning operations and leadership meeting The inspectors discussed these observations with the plant manager who stated that system engineering had been keeping apprised of the seal performanc Information was provided at daily operations meetings during the time that additional spikes were occurrin On July 16, 1996, the middle seal pressure increased from 1340 psig to a maximum indication of 2000 psig. Also, the upper seal pressure step increased from approximately 680 psig to 925 psi The upper seal continued to oscillate between 850 and 1000 psig. Seal leakoff flow increased from approximately 1.2 to 1.8 gp The operating shift'~ and system engineering's initial. review determined that the lower seal had faile Pl ant operations took action consistent with a 1 arm response procedure (ARP)-5 fer control room annunciator EK-095 Approximately one hour prior to the seal failure, the inspectors observed that the seal stage pressure and seal leakoff flow had stabilized and seal stage pressure oscillations had moderated out and were significantly reduce Upon identification of seal failure the licensee evaluated the acceptability of continued plant operation. These discussions included contact with the seal manufacture The licensee concluded tha continued plant operation was acceptable, as long as performance of the seal does not degrade further. Specific*acceptance criteria for continued operation had been provided to the operations shif Conclusions The inspectors concluded that the licensee was aware of seal ~tage -*--

degradation an~ were taking appropriate steps to minimize impact to the seal One major action included minimizing perturbations on closed cooJing water syste Operator actions were consist with plant procedures, and evaluations concluded continued plant operation with a failed seal were acceptabl ES

--Mi-scellaneous Engineering Issues (92902 and 92702)

E (Closed) Violation 50-255/93020-Jb: Failure to test or inspect acceptable fuel performance* after five cycles in the reacto The inspectors monitored the licensee's effort in response to the failed fuel even The inspectors noted various corrective actions to include:

E *

Not using a standard bi-metallic design spacer grid springs in fuel assembly for fifth or higher cycles,

Inspecting four fuel assemblies in the shroud corner locations in the past refueling outage,

Placing solid stainless steel rods in the four corners of two assemblies in each quadrant which are near the core barrel,

Inspecting the core shroud in the past outage,

Using High Thermal Performance (HTP) spacer grids with proven added strength and less susceptibility for relaxation,

Performing periodic reactor noise analysis using ex-core neutron detectors,

Performing supplemental noise monitoring during cycle 11 using external vibration monitoring equipment,

Improving the existing failed fuel action plan, and

Improving the fuel performance monitoring procedure including closer monitoring of the reactor water chemistry and reactor effluent.

These added corrective actions were presently in place and some were monitored by the inspector The inspectors also noted changes the licensee planned to take due to the results of the above stated corrective action Included were a reduction of the number of stainless steel corner rods from three to on The frequency of collecting vibration data was being considered to less frequent than once a mont Violation 50-255/93020-3a was previously closed in inspection report 50-255/95-007. Therefore,.this closes item 50-255/93020-0 (Open) Inspection Followup Item 50-255/93020-01: Fuel failure monitoring and core vibratio In order to thoroughly evaluate the root cause of the failed fuel event, th' licensee evaluated the impact of flow-induced vibration close to the edge of the core as a contributing cause for the failed fuel ro The licensee used subcontractors and consultants to meet this objective. Specifically, two different consultants examined the effect of core flow and its potential to induce fuel rod vibration causirig a failed fue The results of one consultant's evaluations and recommendations were given to another consulting firm for further evaluation and concurrence. Since the final conclusion of this-evaluatioff is still pending, this -item is still ope E (Closed) Violation 50-255/93020-02: Failure to consider the effect of fast neutrons in mechanical properties of core components when performing 50.59 safety evaluation The inspectors evaluated the

• licensee's corrective actions for this issue. This included an evaluation of the effect of fast neutrons on core component The evaluation revealed that there was negligible impact of fast neutron on core component Further, the licensee modified the core reload design procedure to evaluate the effect of fast neutrons on mechanical properties of core components for each core reloa The inspectors considered these actions to be adequate and appropriate. This item is close E (Closed) LER 50-255/950II: Control rod 40 withdrawal when given an insertion signal. The inspectors evaluated this event which occurred in August I7, I99 With the reactor critical and the primary coolant system in the hot standby condition, Group 4 control rods were given insert signal during lower power physics testing. A rod deviation alarm and subsequent indication revealed that the rod 40 had moved in opposite direction, (withdrawn instead of insertion). This event was caused by presence of a foreign material, an unattached and crimped wire lug, previously left in the junction box of the CROM (Control Rod Drive Mechanism) Motor Connection Bo This loose metal shortened two (2)

limit switches which adversely impacted the rod 40 and other rods in Group Since this problem would not prevent the rod to perform its safety function (the rods would *insert upon a trip signal), there were minimal safety significance. The corrective actions, including sharing this experience with electrical maintenance personnel, and revising procedure PPAC CR0005 for inspecting the motor connection boxes appeared adequat The licensee also planned to develop a mechanism to test for shorts and grounds in.the circuitry by August 2, I99 This item is close IV. Plant Support RI Radiological Protection and Chemistry Controls (RP&C)

RI.I Maintenance Outages and Daily Radiological Worker Practic~s Inspection Scope (83750)

The inspectors observed !adiological worker activities during th~

various applicable maintenance outages detailed in this inspection report, and also monitored radiological practices during daily plant tour Observations and Findings During the applicable maintenance outages radiation technici~ns w&re

---

-

-~-- - ----

. vJsible at the job sites. - The technicians took appropriate actions and surveys in accordance with good ALARA practices..

c. Conclusion The inspectors observed that radiological practices observed during the maintenance outages and plant daily walkdowns were adequat The inspectors had no concerns.

. R Implementation of the Radiological Environmental Monitoring Program (REMPl The inspectors observed air sample collection and air sampling equipment at selected sites, and interviewed REMP staff regarding other sampling activities. The inspectors also reviewed the environmental sampling procedure, the 1995 Annual Radiation Environmental Operating Report (AREOP), and 1996 REMP dat The REMP sampling and analyses were ~onducted iri accordance with the Final Safety Analysis Report (FSAR) and the Offsite Dose Calculation Manua All deviations from the monitoring program were noted in the AREO The material condition of the air sampling equipment was excellent, as evidenced by inspector observation and the low number of

• air samples missed due to equipment problem The REMP data indicated no radiological impact to the environment from plant operation The REMP was effective and well implemented, and the results indicated no discernable impact on the environment from plant operation Rl.3 Plant Water Quality and Fuel Integrity Monitoring Inspection Scope (84750)

.The inspectors interviewed plant personnel and reviewed data regarding water quality of various plant systems for the past twelve months.* The inspectors also reviewed the applicable portions of the FSAR, Technical Specifications (TS), and chemistry procedures governing water qualit The inspectors also interviewed plant personnel and reviewed data

• regarding fuel integrity monitorin *

• b. Observations and Findings

• The plant water quality.was well manage The inspectors noted that during power operation the licensee maintained the chloride, fluoride, hydrogen, and 1 ithium levels of the *primary coolant system (PCS) within the FSAR and TS requirements, and EPRI guideline PCS conductivity and boron were also controlled within plant limit *

The inspectors also determined that the power operation levels of chloride, sulfate, and hydrazine, in steam generator blowdowns were maintained within EPRI guidelines and plant limits. Dissolved oxygen and pH in the condensate, and feedwater iron and copper levels, remained within EPRI guidelines.

• The program for monitoring fuel integrity was extensive, as several independent radionuclides and radionuclide ratios were monitored for trend The licensee has also formed a fuel integrity committee which met regularly to assess fuel integrity. The licensee's data showed a slow increase in the Dose Equivalent Iodine concentration during the current fuel cycle. However, the fuel integrity committee noted that the lack of iodine spikes during a recent power reduction/escalation cycle and the consistently low levels of neptunium-239 both indicated that the source of the PCS iodine was probably tramp uraniu The inspectors agreed with the licensee's assessmen Conclusions The management of plant water quality. was excellent, as evidenced by continued control of chemical constitu~nt~ within EPRI guidelines and plant limits. The collection and assessment of fuel integrity data indicated that the fuel integrity program was effectiv R2 Status of RP+C Facilities and Equipment R The Post Accident Sample Monitor CPASM). Chemistry Sampling Station and In-Line Monitors a., Inspection Scope {84750) The inspectors walked down the PASM panel, the chemistry sampling stations, and the in-line monitor panel The inspectors observed a

.conductivity function check, interviewed ~taff regarding operability, and reviewed function tests *conducted for the past yea Observations and Findings The inspectors examined the PASM panel and determined that the material condition was good as illustrated by no outstanding work request The licensee had i.nitiated a self-assessment of the PASM in February 1996 in response to some analytical problems associated with the. function test The inspe~tors reviewed the PASM self-asiessment report, which was completed in May 1996, and determined that the proposed changes w~r-~: _

appropriate to improve PA~M performanc Chemistry technicians (CT}

~ndicated that ~ach CT ~onducted a semi-annual function test and that the operation of the PASM had improve During walkdowns of the chemistry sampling stations for the primary and secondary systems, the -inspectors observed that the material condition was very goo Also, the CTs. indicated that these sampling stations operated reliabl The inspectors noted similar material condition with the in-line monitors of the C-42 panel, the auxiliary building, and the feedwater syste The in-line monitors were all within calibration.* Various chemistry personnel indicated that this equipment has routinely operated with few problem Also, a review of required function checks indicated

• that these instruments have operated reliabl The inspectors observed that a conductivity function check was conducted appropriatel Conclusions Inspector observation, regular function checks, and interviews with chemistry staff indicated that the material condition and overall operability of the PASH panel, the chemistry sampling stations, and the in-line monitors was.very goo RS Staff Training and Qualification in RP+C (84750)

RS.I Training and Performance of Chemistry Technicians Inspection Scope (84750)

The inspectors reviewed the chemistry training program, interviewed a chemistry training coordinator, and reviewed the training documentation for a CT undergoing initial qualification. The inspectors also observed sampling and analysis activities, and interviewed CTs regarding 1 aboratory quality control (QC). Obs~rvations and Findings (84750)

The training program was extensive, and consisted of *initial classwork, on the job training (OJT), and continuing trainin The classes required a passing grade of $0 percent on a written.examinatio During the OJT, CTs were evaluated by chemistry supervisors or Senior CTs prior to receiving approval for working independentl The CT training program typically.required three years to complete and was sufficient to ensure that *American Nuclear Standards Institute (ANSI) Nl8.l-1971 qualifications were me After initial qualification, CTs received continuing trainin The continuing training covered all the chemistry tasks in a three year cycl In addition, a curriculum committee consisting of chemistry supervisors~ CTs, and the training coordinator met quarterly to determine topics for continuing trainin _ The inspectors observed primary and secondary water sample collection, secondary offgas collection, and laboratory analysis activities. The CTs exhibited very good sampling techniques and ALARA practice The CTs also displayed in-depth knowledge of laboratory analyses and quality contro c. Conclusions*

-

-

. --

. * -

The chemistry training program was well implemented and ensured that CTs were ASNI qualifie The inspectors observed that CTs were proficient in the performance of sampling and analysis activities.

- ------~-----

R7 Qual;ty Assurance ;n RP+C Act;v;t;es R7.l Chemistry Laboratory Quality Control (QC) Inspection Scope CB4750)

The inspectors reviewed instrument QC records and intercomparison data, and interviewed laboratory staff regarding laboratory QC pract;ce Also, the inspectors rev;ewed the chemistry self-assessment plan and reports regarding laboratory activitie Observations and Findings Chemistry Procedure. CH 1.3, Rev. 6, "Laboratory Quality Control Program" was implemented effectively. The inspectors noted that the laboratories were well equipped and the control charts indicated that the radiological and analytical instrumentation remained within contro The chemistry reagents and.standards were properly labeled and controlle The laboratory demonstrated excellent proficiency in radiochemical analysis with nearly 100 percent agreement in an intercomparison progra The laboratory performance in the 1996 non-radiological

.

chemistry intercomparison program was very good, with nearly 90 percent agreement on the first attemp The CTs whose initial results were not in agreement re-analyzed the samples, and all subsequent results were in agreemen The laboratory also achieved greater than 90 percent agreement on first attempt in its non~radiological intracomparison progra The inspectors reviewed chemistry self-assessments and a Nuclear Performance Assessment Department (NPAD} audi The 1996 chemistry self-assessment plan was aggressive. The assessments and audits reviewed were appropriately focussed, based on.field observations, and identified pertinent issues. The inspectors also reviewed condition reports initiated by the chemistry department and determined that they were thoroughly evaluated and resolved in a timely manne c. Conclusions laboratory QC practices were sufficiently implemented to ensure that the radiological and analytical instrumentation remained within contro The laboratory demonstrated very good analytical capabilities by its performance in both inter-and intracomparison program The chemistry self-assessment plan was aggressive and well implemente RB M; see 11 aneous __ RP+C Issues- *

.. -

~.. - -

-

R (Closed) VIO 50-255/95007-03:

failure to correct air sampling deficiencies identified in the REM An NRC inspector had observed that a vendor technician removed the particulate air filter in a very turbulent manner which compromised sample integrity. Although this

• 2B

sampling deficiency had been previously identified in two separate NPAD audits, corrective action had not been take The REMP staff implemented the following corrective actions~

The indicator air samples are now collected by station HP technicians who have received appropriate training;

The Health Physics Procedure HP 10.10, "Palisades Radiological Environmental Program Sample Collection and Shipment" has been revised and states, "Using tweezers, carefully remove particulate filter from the sample head"; the filters and charcoal cartridges are then to be placed into individual envelopes; and

Periodic observation of field activities by REMP supervisory staf The inspectors verified the implementation of the corrective action by a review -0f pertinent records and observation of air sample collectio The inspectors determined that the corrective actions were appropriat R (Closed) URI 50-255/95007-02: weaknesses in the control of non-radiological chemistry standard An inspector had observed that expiration d~tes of non-radiological standards were being extended beyond the manufacturer's date, without a technical basis or supervisory approval, and that there were weaknesses in labeling and traceabilit The chemistry management implemented the following corrective actions:

+

Chemistry Procedure CH 1.3, Rev. 6, "Laboratory Quality Control Program" was revised to allow, in extreme circumstances, only one six month shelf-life extension with the documented approval of the Laboratory Supervisor;

+

a reagent label was developed to facilitate labeling;

+

Cts received training regarding the procedure change and labeling requirements for chemistry reagents; and

_+

chemistry management will monitor compliance through field observation The inspectors verified the procedural change, and observed that laboratory reagents were appropriately labeled and within the expiration dat Interviews with CTs and chemistry supervisors indicated that there have been no' occasions to extend shelf-life. All laboratory staff -

appeared to be aware of-the new lab~ling requirement The weaknesses in the control of laboratory standards did not violate NRC requirements or plant procedures, and the inspector's determined the corrective actions were effectiv *

Sl Conduct of Security and Safeguards Activities Sl.l Inspection Procedure 81700. "Physical Security Program for Power Reactors" Inspection Scope The inspection of the physical security program focused on management controls; corrective actions; audits; security procedures; alarm stations and communications; and follow up of previous inspection finding Inspection showed that the conduct of security was professional and generally technically soun Members of the security organization were generally knowledgeable of their assigned tasks. Management control activities were focused to maintain security program effectivenes The inspector conducted interviews of cognizant program personnel; observation of various security activities; and review of selective security records to verify program implementatio Observation and Findings (1)

Access Control-Personnel On July 9, 1996, during observation of search activities at the protected area main access point, the inspector identified examples of weak personnel search practices. During the morning personnel rush period:

(1)

• those searched, assisted security officers in identifying individuals who caused alarms; _and (2) monitoring of the metal detector to assure personnel usage was not conducte (Note: The licensee had previously established a requirement regarding detector monitoring to address a vulnerability

. identified by the inspector in a previous inspection.) The identified weaknesses demonstrated an increase in the probability that the search program could be compromised resulting in the.introduction of prohibited items into the protected are When identified, the P~~perty Protection Supervisor (PPS)

initiated action addressing the weaknesse A security force member was specifically assigned to monitor and provide oversight of search activitie Inspector observation on July 11, 1996, showed that search activities had improved and the inspector's findings had been

---

~-

adequately addresse Inspector review showed that similar findings regarding weak monitoring of personnel search activities were identified in NRC Inspection Reports 50-255/94005 and 9500 Corrective action had included the posting of a supervisor to provide overview of search activities. That current inspection

,. *

(2)

finding showed that during the "rush" period the supervisor assisted in the searching of hand-carried packages instead of monitoring search activitie Inspector interviews of security officers showed this was commo Inspector interviews of several supervisors showed that they believed it was important to assist in searching activities to reduce the "backlog".

Licensee's action to improve personnel search activities and to ensure that corrective action is effective will be tracked as an IFI (50-255/96007-01).

Alarm Stations The inspector observed that security alarm station operators were generally effective in implementing assigned duties. Required equipment performed in an effective manne However, the inspector identified that changes o some security alarm points were only indicated visually and not audibly. Alarm status changes could occur. without adequate detection. (Note:

Other alarm points when activated indicated both a visual and audible condition.)

The licensee's Property Protection Supervisor (PPS) was not aware of this until identified by the inspecto The security significance was reduced because alarm statio operators routinely communicated changes in alarm point status verball The inspector's finding resulted in a decrease in the effectiveness of the alarm syste The PPS will evaluate the inspector's findin Licensee's actions to address the inspector's finding will be tracked as an IFI (50-255/96007-02). Conclusion SecQrity program performance in the areas inspected provided the necessary level of protection to the facilit Two IFI's were identified pertaining to implementation weaknesses in the quality of personnel searches and alarm station monitoring of some intrusion alarm point SB * Miscellaneous Security and Safeguards Issues (92904)

S (Closed) IFI (50-255/93019-01): This issue pertained to several Access Authorization (AA) procedures that did not fully address program implementation requirements or reflect actual practices

,and in some cases lacked specificit To correct these weakness~s the licensee's Access Authorization staff rewrote.-all-AA~--- *

procedures.. The inspector selectively reviewed 25 percent of the procedural guidanc Procedures appeared well written, addressed regulatory requirements and were in concert with actual practice This item is close,_ *

S (Closed) IFI (50-255/93019-02):

Self-screening contractors were not provided detailed criteria to define and evaluate derogatory informatio Licensee corrective action included providing to self-screeners the licensee's procedure for the adjudication of derogatory informatio Inspector review determined the procedure was well written and effectively described derogatory information and action to be taken when this information was identified. This item is close S8~3 (Closed) IFI (50-255/9319-03):

Procedural guidance regarding proctoring of psychological evaluation tests were not provided to cognizant organizations responsible for-conducting those activities. The inspector verified by interviews and review of records that procedural guidance regarding administration of psychological testing was provided to all cognizant organizations. This item is close S (Closed) IFI (50-255/9319-04):

Training related to identifying.

adverse behavioral traits was not emphasized in the licensee's training progra The licensee has implemented guidance in Nuclear Energy Institute {NEI} 94-04, dated June 1996, which describes a training program addressing adverse behavioral

• traits. This trainin~ has improved licensee's scope and emphasize in their behavioral observation progra This item is closed~

S8.5 * (Closed) IFI (50-255/9319-05):

Forms, documenting transfer of temporary access, were* not comp l eteq in accordance with instruc.tions contained in NUMAC 93-0 Inspector review of a randomly selected 93-01 transfer forms showed that the forms were do~umented in accordance with 93-01.. This item is close V. Management Meetings XI Exit Meeting Su11111ary The inspectors presented the i nspec*ti on results to members of licensee management at the conclusion of the inspection on August I, 199 PARTIAL LIST OF PERSONS CONTACTED Licensee R. A. Fenech, Vice President, Nuclear Operations T. J. Palmisano, Plant General Manager K. P. Powers, Nuclear Services General Manager G. 8. Szczotka, Acting Nuclear Performance Assessment Manager H. L. Linsinbigler, Design Engineering Manager

,

R; W. Smedley, Licensing Manager D. W. Rogers, Operations Manager J. P. Pomeranski, Maintenance and Construction Manager D. P. Fadel, System Engineering Manager D. G. Milone, Shift Operations Supervisor D. J. Malone, Chemical & Radiation Protection Services Manager K. M. Haas, Training Manager S. Y. Wawro, Planning & Scheduling Manager M. E. Parker, Senior Resident Inspector, Palisades P. F. Prescott, Resident Inspector, Palisades K. Salehi, Reactor Safety Inspector N. Jackiw, Reactor Projects Inspector J. Neisler, Reactor Safety Inspector C. Orsini, Resident Inspector R. Paul, Radiation Specialist R.. Glinski, Radiation Specialist T.. Madeda, Security Inspector

--*------~

• IP 37551:

IP 61726:

IP 62703:

IP 71707:

IP 83750:

IP 92700:

IP 92702:

IP 92902:

Opened INSPECTION PROCEDURES USED Onsite Engineering Surveillance Observations Maintenance Observation Plant Operations Occupational Radiation Exposure Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities Followup on Corrective Actions for Violations and Deviations Followup - Mainteriance ITEMS OPENED AND CLOSED 50~255/93020-01 IFI Fuel failure monitoring and core vibration 50-255/96007-01 IFI Completion of cable ampacity reviews

50-255/96007-02 IFI Improve personnel search activities 50-255/96007-03 IFI Vulnerability regarding monitoring.of intrusion *alarm status points Closed 50-255/93019-01 IFI Several Access Authorization (AA) procedures that did not fully address program implementation requirements or reflect actual practices

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50-255/93019-02 IFI Self-screening.contractors were not provided detailed criteria to define and evaluate derogatory informatio /93019-03 IFI Procedural guidance regarding pro~toring of psychological.

evaluation tests were not provided to cognizant organizations responsible for conducting those acti~itie /93019-04 IFI Training related to identifying adverse behavioral traits was not emphasized in the licensee's training progra /93019-05 IFI Forms, documenting transfer of temporary access, were not completed in accordance with instructions contained in

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NUMAC 93-0 /93020~3b VIO Failure to test -0r inspect ac~eptable fuel.performance

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after five eye l es in the reactor 50-255/93020-02 VIO Failure to consider the effect of fast neutrons in mechanical properties of core components when performing 50.59 safety evaluation 50-255/94014-67 IFI Ineffectiveness of management to provide adequate control and oversight

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50-255/94014-6~ IFI Failure of the licensee to integrate procirams and process 50-255/94014-69 IFI Failure to provide clearly defined roles and responsibilities 50-255/94014-72 IFI Licensee not effective in addressing problems associated with human performance 50-255/94014-70 IFI Causes for problems and events observed during outages were not unique to outage period

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50-255/94014-71 IFI Failure to provide proper resource allocation and utilization 50-255/95007-02 URI Weaknesses in the control of non-radiological chemistry standards 50-255/95011 LER Control rod 40 withdrawal when given an insertion signal

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ALARA ANSI AREOR CA CFR CR CROM CRS CT CV DET DRP EPRI FIN FSAR GPM HPSI HTP IEEE ICEA IFI IP

IR LCO LER LLRT NOT NEI NI NOD NPAD NRC NRR OJT PCS PDR PPAC PPC PPEP PPM PPS PSIG QC REMP RP&C SFP SIT TS VIO WO LIST OF ACRONYMS USED As Low As Reasonably Achievable Annual Radiological and Environmental Operating Report Corrective Action Code of Federal Regulations Condition Report Control Rod Drive Mechanism Control Room Supervisor Chemistry Technician Control Valve Diagnostic Evaluation Team Division of Reactor Projects Electric Power Research Institute Fix-It-Now Final Safety Analysis Report Gallons Per Minute High Pressure Safety Injection High Thermal Performance Institute of Electrical & Electronic Engineers Insulated Cable Engineers Association Inspection Followup Item Inspection Procedure

Inspection Report

Limiting Condition of Operation

Licensee Event Report

Local Leak Rate Test

Non-Destructive Test

Nuclear Energy Institute

Nuclear Instrumentation

Nuclear Operations Department

Nuclear Performance Assessment Department

Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

On-the-job Training

Primary Coolant System

Public Document Room

Periodic and Predetermined Activity Contrril

Plant Performance Computer

Palisades Performance Enhancement Program

Parts Per Million

Property Protection Supervisor

Pounds per Square Inch Gauge

Quality Control

_____ -Radiologica-1 -and Environmental Monitoring-Program

Radiological Protection and Chemistry Control

Spent Fuel Pool

Safety Injection Tank

Technical Specification

Violation

Work Order