IR 05000255/1999010

Insp Rept 50-255/99-10 on 990812-0921.One Violation Noted & Being Treated as Ncv.Major Areas Inspected:Aspects of Licensee Operations,Maint,Engineering & Plant Support

ML18066A686
Person / Time
Site:	Palisades
Issue date:	10/13/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18066A685	List: IR 05000255/1999010 ML18066A684
References
50-255-99-10, NUDOCS 9910250095
Download: ML18066A686 (18)

Text

U.S. NUCLEAR REGULA TORY COMMISSION Docket No:

License No:

Report No:

Licensee:

Facility:

• Location:

Dates:

Inspectors:

Approved by:

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9910250095 991013 PDR ADOCK 05000255 Q

PDR REGION Ill 50-255 DPR-20 50-255/9901 O(DRP)

Consumers Energy Company 212 West Michigan Avenue Jackson, Ml 49201 Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530 August 12, through September 21, 1999 J. Lennartz, Senior Resident Inspector R. Krsek, Resident Inspector Anton Vegel, Chief Reactor Projects Branch 6 Division of Reactor Projects

EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRC Inspection Report 50-255/9901 O(DRP)

This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6-week period.of resident inspection activitie Operations

Conduct of operations was characterized by a professional environment in the control room. Power was reduced slightly to eliminate spurious Thermal Margin Low Pressure and Variable High Power pre-trip alarms which demonstrated a positive focus on safet (Section 01.1)

Control room operators demonstrated effective monitoring of equipment parameters by identifying and accurately diagnosing an increase in the leak rate from a Safety Injection Tank T-828 Motor Operated Isolation Valve. (Section 02.1)

Operations personnel lacked a rigorous questioning attitude regarding the impact on other plant equipment from the leak from Safety Injection Tank T-828 Motor Operated Isolation Valve. (Section 02.1)

The operators' response to the failure of Charging Pump P-55C to start as designed, on August 18, 1999, was timely and in accordance with plant procedures. System restoration, following repairs, was completed without incident. (Section 04.1)

A lack of rigor regarding attention to detail and ineffective Senior Reactor Operator oversight during a routine activity to vent a safety injection tank on Septembe~ 14, 1999, contributed to a procedure adherence error which was considered mino (Section 04.2)

Maintenance

The inspectors noted frequent supervisory oversight of maintenance activities and competent general work practices. (Section M 1.1)

• * There were overall job performance and documentation weaknesses during the -* *..

maintenance outage on Spent Fuel Cooling Pump P-518. Workers incorrectly installed the new seal resulting in re-work and there was a valve lineup error during restoration *

resulting. in a leak. In addition, some licensee identified conditions adverse to quality were not documented until prompted by the inspectors. (Section M.1.1)

Prompt support by maintenance and system engineering personnel during emergent maintenance on Charging Pump.P-55C contributed to repairs being completed in a timely manner. Operations, maintenance, and engineering personnel coordinated effectively during the planning and execution of the emergent repairs and subsequent system res~oration. (Section 04.1)

Endineering

Engineering personnel demonstrated a rigorous questioning attitude regarding a leak from a Safety Injection Tank T-828 Motor Operated Isolation Valve. The persqnnel evaluated the leak's impact on other equipment, including the leak's impact on the operability of the trisodium phosphate baskets. (Section 02.1)

I

Thorough and timely communications were demonstrated among engineering, maintenance, and operations personnel regarding inadequate packing gland leakoff during a monthly test of.Auxiliary Feedwater Pump P-8A. (Section E2.1)

The auxiliary feedwater pump procedure's scope and clarity for monitoring the packing glands for minimum leakoff, and for performing packing gland adjustments by operations personnel were weak.. (Section E2.1)

System engineering personnel provided prompt support following failure of Charging Pump P-55C to start because of an emergent problem with the associated breaker's charging spring motor. (Section 04.1)

Plant Support

The inspectors identified *several instances where operations personnel failed to perform required frisking activities for contamination control, resulting in a Severity Level IV Non-Cited Violation. Although the instances did not result in the significant spread of contamination outside of the contamination area, deficiencies in operations personnel *

knowledge of basic radiation protection requirements were demonstrate (Section R4.1)

En:iergency response personnel conducted a thorough investigation following discovery that the offsite commercial telephone lines were not available. The ensuing emergency event on September 7, 1999, was accurately classified as an Unusual Event and the required notifications were completed in a timely manner following declaration. Actions initiated to ensure that the mihimum required emergency response personnel could be achieved were considered pro-active and demonstrated a positive focus on safet (Section P1.1)

Declaration of the Unusual Event on September 7, 1999, was unnecessarily delaye There was ineffective communication following initial discovery that-the offsite - -

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commercial telephone lines were lost. Also, there was diminished perceived significance because emergency use satellite telephones were available. (Section P1.1) *

Emergency planning personnel effectively used the September 8, 1999, exercise to satisfy the training objectives. The post exercise critique was self-critical and demonstrated an appropriate threshold for identifying deficiencies. (Section P5.1)

A lack of rigor and poor attention to detail contributed to deficiencies regarding Emergency Plan Implementing procedures and simulator modeling of the failed fuel monitor. (Section PS.1)

• Report Details Summary of Plant Status The plant operated at full power for the duration of the inspection perio I. Operations

Conduct of Operations 01.1. General Comments (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations. The control room environment remained professional and free of unnecessary distractions. Operations personnel demonstrated a positive focus*

on safety by decreasing power from 99.9 percent to 99.5 percent to eliminate momentary Thermal Margin Low Pressure and Variable High Power pre-trip alarms that had annunciated on several occasion *

The frequent spurious annunciation of the alarms had the potential to desensitize the control room operators' response to the alarms: Reactor engineering personnel investigated the alarms and concluded that the primary cause was hot leg stratification and swirling which caused a momentary rise in deJta-temperature power and a resultant*

rise in Thermal Margin Low Pressure and Variable High Power calculated parameter The inspectors concluded that the cause for the spurious alarms was understood by the

• 1icensee staff.and that there were no apparent safety consequence Operational Status of Facilities and Equipment 0 Leak Fr9m Safety Injection Tank T-828 Motor Operated Isolation Valve Inspection Scope (71707. 37551)

The inspectors reviewed applicable Technical Specifications and condition reports related to a leak thatdeveloped on Safety Injection Tank T-828 Motor Operated Isolation Valve. Also, the inspectors discussed the issue with engineering and

. operations personnel to assess the leak's impact on other plant equipment and the control room operator Observations and Findings Control room operators identified that the rate of a slowly lowering level on Safety Injection Tank T-828 had increased which demonstrated effective monitoring of plant*

parameters. Control Room operators diagnosed that the increased rate was because a known leak from Motor Operated Valve M0-3045, "Safety Injection Tank T-828 Outlet Isolation Valve," had gotten worse.

The leak was from the valve body-to-bonnet seal to the containment and had previously been quantified by operations personnel during a containment entry on August 31, *

• 1999, as.5-6 drops per minute. A containment entry made by operations personnel on September 14, 1999, to investigate the increased leakage confirmed the control room operators diagnosis. The leak had increased to a small "~teady stream" and quantified at approximately 19 gallons.per day. The licensee generated Condition Reports C-PAL-99-1453 and 99-1475 regarding the leakage which were entered into the licensee's corrective action progra The inspectors reviewed and did not identify any concerns with the operability determination which concluded that T-828 was operable. Make up capability to T-828 was much greater than the leak rate and M0-3045 was in its safety position, electrically de-en.ergized open, and capable of performing its safety function. However, the leak resulted in a minor impact on the operators in that the tank would have to be filled more frequentl Following the first containment entry, operations personnel indicated that the leak was dripping onto the containment floor (590 foot elevation) and entering a floor drai Operations personnel did not identify any impact on other plant equipment from the lea However, a subsequent containment entry on September 1 S, 1999, by engineering personnel identified that the leak was dripping onto one and also splashing onto the screen of three other safety-related Iodine Removal System baskets that contained trisodium phosphat *

Trisodium phosphate was used to retain iodine and maintain a neutral pH in the containment sump water used for recirculation following a loss of coolant acciden Engineering personnel demonstrated a rigorous questioning attitude, which was lacking by operations personnel, regarding the impact on plant equipment from the lea Engineering personnel generated Condition Report C-PAL-9901482 regarding the leak dripping on the trisodium phosphate baskets which was entered into the licensee's corrective action progra An operability evaluation concluded that the Iodine Removal System was operable which was based on there being no apparent loss of trisodium phosphate from the baskets that the leak was contacting. Also,, there was approximately 692 pounds above the Technical Specification minim1,1m required amount of trisodium phosphat The inspectors noted that M0-.3045 was targeted for repairs during the refueling outage that was scheduled to start in mid-October 1999. Following an engineering evaluation and in consideration of the operability determinations, the licensee did not plan on _

conducting any repairs to the valve before the outage unless the leak worsene Consequently, a heightened level of monitoring for any changes in the leakage rate was implemented by the control room operator Conclusions The inspectors concluded that control room operators demonstrated effective monitoring *

of equipment parameters by identifying and accurately diagnosing an increase in the leak rate from a Safety Injection Tank T-828 Motor Operated Isolation Valve. The associated operability determination was timely and reasonable. The leak created some burden on control room operators in that the tank would have to be filled more frequently and more frequent monitoring of tank parameters was required. The added burden was not considered significan *

• Engineering personnel demonstrated a rigorous questioning attitude regarding the leak's impact on other plant equipment, in that they identified and subsequently evaluated the impact of the leak on the operability of the trisodium phosphate basket Operator Knowledge and Performance 04.1 * Failure of Charging Pump to Start on Demand as Designed (71707. 62707. 37551)

The inspectors observed the control room operators' response to a failure of a charging pump and assessed the support provided to operations department personnel by the maintenance and engineering organization On August 18, 1999, Charging Pump P-55A was out-of-service for maintenance and Charging Pump P-55C failed to start on demand as designed for a lowering pressurizer level. Consequently, two charging pumps were inoperable which placed the plant in a 24-hour Limiting Condition of Operation to conduct repairs. Control room operators isolated letdown.in a timely manner following failure of P-55C which precluded excessive lowering of pressurizer level. Troubleshooting on P-55C revealed that the breaker's charging motor had failed. The charging motor was replaced, tested, and P-55C was placed back in service. Letdown was restored by the control room operators without incident after P-55C was returned to servic The inspectOrs concluded that the operators response to the failure of Charging Pump P-55C to start was timely and in accordance with plant procedures. Prompt support from maintenance and system engineering personnel contributed to repairs being completed in a timely manner. Coordination and communication between operations, maintenance, and engineering personnel was effective during the planning and execution of the emergent repairs and subsequent system restoratio.2 Procedure Adherence Error Procedure adherence was evident during the inspection period with one noted exception as described below:.

A Reactor Operator momentarily opened the vent valve for Safety Injection Tank T-820 while attempting to vent Safety Injection Tank T-828 in accordance with

• plant procedures on September 14, 1999. The operator immediately recognized and corrected the error. Therefore, the loss of pressure from T... 82D was-insignificant (pressure dropped 2.5 psig).

However, the human performance error during this uncomplicated task resulted in an inadvertent entry into Technical Specification 3.3.2b. Also, peer checking and self-checking, while utilized, were not effective and consequently did not prevent the error from occurring. In addition, Senior Reactor Operator oversight of the activity was ineffective. A lack of rigor and attention to detail during the routine activity contributed to the error. Opening the incorrect valve did not result in significant adverse consequences and therefore constitutes a violation of minor significance that is not subject to formal enforcement action.

The inspector$ concluded that the procedure adherence error that occurred during a routine evolution to vent a Safety Injection Tank on September 14, 1999, was of minor

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significance. A lack of rigor regarding attention to detail and ineffective Senior Reactor Operator oversight contributed to the erro IL Maintenance M1 Conduct of Maintenance M1.1 Maintenance and Surveillance Testing Observations Inspection Scope (61726. 62707. 71707)

The inspectors observed or reviewed portions of the following maintenance work orders and surveillance activities. Also, the inspe_ctors interviewed operations, engineering, and maintenance department personnel and, when applicable, reviewed Technical Specifications, the Final Safety Analysis Report and vendor manual Work Order No.:

24713232

'24810861

24910725

24910439

..

24910626

24911275

. 24911105 Surveillance No.:

M0-38

FWS-1-18

RE-131

Q0-21 Modification of Air Filter for Control Valve CV-3037, Including Installation of New Valve and Relief Valve Inspection of Oiler and Air Filter for Control Valve CV-3037 Pump P-518 Preventative Maintenance for Pump Coupling and Coupling Lubrication

Pump P-518 Suction Flange Gasket Replacement Pump P-518 Discharge Check Valve (CK-SFP930) Hinge Pin Cover Gasket Replacement Pump P-518 Installation of New Single Cartridge Mechanical Seal Test the Auxiliary Feedwater Pump P-8C Trip on Low Suction Water Pressure Auxiliary Feedwater System Monthly Test Procedure Auxiliary Feedwater Pump P-8C Trip on Low Suction Water Pressure Diesel Generator 1-1 Load Reject Auxiliary Feedwater System Quarterly Test Procedure

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Observations and Findings General Comments The inspectors noted that work instructions were present and utilized at the job sites to complete work activities and that supervisors frequently observed work activitie Maintenance workers followed good general work practices. Discussion of the M0-38,

"Auxiliary Feedwater System Monthly Test," activities is contained in Section E2.1 of this repor *

Spent Fuel Pool Cooling Pump P-518 Maintenance Outage Licensee maintenance personnel planned the maintenance outage for Spent Fuel Pool Cooling Pump P-518 to address a number of system leaks and preventive maintenance items prior to the 1999 refueling outage. While.no violations of NRC requirements were *

identified, the inspectors determined that there were negative attributes regarding the maintenance outage this pump:

Conditions adverse to quality, such as* incorrect replacement parts, were discovered by plant personnel during the pre-job reviews conducted by supervisors and planners, and during the work performed by maintenance personnel; however, condition reports were not initiated for some issues until questions were raised by the inspector *

Unanticipated leakage occurred during initial restart of the pump because a sample valve was inadvertently left open, and because the new mechanical seal was installed incorrectly. Consequently, the leaks resulted in the extension of the radiation contaminated area boundary. The sample valve was within*the valve tag-out boundary and opened by maintenance personnel after obtaining permission from control roorn. operators; however, *the position of the valve was not identified on the tagout order or work order summary to ensure that the valve would be closed when the system was restore *

A work package administrative signoff, required to be complete prior to the initial post maintenance test by operations personnel, was not signed, although all the appropriate work had been completed..

The work order feedback form was not consistently used to document the required pre-job (T-3) reviews. Although plant procedures did not require that the review was documented on the form, the maintenance management expectation was that, at a minimum, the work order feedback form be used to document the pre-job review Work planning personnel coordinated closely with maintenance personnel following discover)' of the incorrect mechanical seal installation, to ensure proper installation was understood prior to the mechanical se~I re-work. The seal re-work was performed and the post maintenance test was completed satisfactorily. In addition, maintenance management planned to conduct' a post job critique and develop lessons learned to improve upon the weaknesses identified during the maintenance performed on pump P-51 *

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Conclusions.

The inspectors noted frequent supervisory oversight of maintenance activities and competent general work practices. While no violations of NRC requirements were identified, there were overall job performance and documentation weaknesses during the maintenance outage on Spent Fuel Cooling Pump P-51 B. Workers incorrectly installed the new seal resulting in re-work and there was a valve lineup error during restoration resulting in a leak. In addition, some licensee identified conditions adverse to quality were not documented until prompted by the inspectors. Maintenance management planned to conduct a post job critique of the evolution to develop improvements and assess any weaknesses which was considered a positive initiativ Ill. Engineering E2 Engineering Support of Facilities and Equipment E Auxiliary Feedwater Pump Packing Gland Leakoff Inspection Scope (37551)

The inspectors reviewed emergent issues pertaining to Auxiliary Feedwater System Monthly Surveillance Test M0-38. In addition, the inspectors reviewed vendor documentation and discussed pump packing gland issues with operations, engineering and maintenan~e personne Observations and Findings On August 23, 1999, during performance of the auxiliary feedwater system monthly surveillance, operations personnel stopped Auxiliary Feedwater Pump P-8A when no inboard pump packing gland leakage was observed. The auxiliary operator noted that at the start of the pump run, the inboard packing gland leakoff was at 30 drops of water per minute, the minimum acceptable value allowed by the procedure. Mechanical maintenance personnel noted that after running the pump for approximately 20 minutes, there was no packing gland leakoff. In addition, the packing gland temperature was 100~F above normal. *

The pump was subsequently declared inoperable, and the 72-hour Limiting Condition of __ _

Operation was entered in accordance with Technical Specification Requirement 3.5. Condition Report C-PAL-99-1336 was initiated to document the event. Maintenance personnel then adjusted packing leakage until the packing gland temperature was normal and the packing gland leakoff was a stream of water approximately 1/16 of an inch wide. The inspectors noted that very minor adjustments of the packing gland nuts altered the flow rates from zero to steady flow. The pump was subsequently tested and declared operable, The inspectors also noted timely and thorough communications among the maintenance, operations and engineering personnel during this emergent issu The inspectors noted, during further review of the monthly and quarterly auxiliary feedwater system surveillance procedures, M0-38 and Q0-21 respectively, that the procedures allowed the auxiliary operators to adjust the packing gland leakof :.,

• Subsequent discussions with the system engineer revealed that auxiliary operators had not received training on adjustments for this type of packin The scope of the procedure steps was to allow auxiliary operators to only adjust the leakoff when maintenance was not available and the leakoff rate from the packing was excessive. The scope of the procedure did not allow auxiliary operators to adjust

• packing for less than adequate flow during emergent situations when maintenance *

personnel were not available. The system engineer initiated Condition Report C-PAL-99-1428 to address the training issues, and to clarify and evaluate the scope~ of the current procedure steps that operations personnel would perfor In addition, system engineering personnel's review of other plant procedures regarding auxiliary feedwa~er pump operation identified that neither the guidance for monitoring packing gland leakoff rates or the minimum leakoff rate criteria were specified. The system engineer initiated Condition Report C-PAL-99-1444 which documented the findings in the licensee's corrective action system. System engineering personnel *

generated procedure change requests to address the procedure weaknesse Conclusions R4 The inspectors concluded that engineering, maintenance, and operations personnel demonstrated thorough and timely communication regarding the resolution of inadequate packing gland leakoff during a monthly test of Auxiliary Feedwater Pump P-8 However, the auxiliary feedwater pump procedure's scope and clarity for monitoring the packing glands for minimum leakoff, and for performing pac,king gland adjustments by operations personnel were weak. -

IV. Plant Support

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Staff Knowledge and Performance in Radiological Protection and Chemistry Controls.

.. R4-.1 Observations of Activities in Contaminated Areas * Inspection Scope (71750)

The inspectors observed radiological protection practices for contamination control within the radiation controlled area during plant tours and while, observing maintenance activitie Observations and Findings The inspectors observed auxiliary operators perform valve line-ups in support of the Spent Fuel Pool Cooling Pump P-51 B restoration. Some work was performed within contaminated areas inside the radiation controlled area. Upon completion of the work within the contaminated area~. the auxiliary operators properly removed personal protective equipment and proceeded to the next work area. The inspectors questioned the operators as to whether or riot a personnel contamination survey was required upon

• exiting the contamination area. The auxiliary operators noted that although surveying was a good health physics practice, surveys were not require In addition, the inspectors noted that a key used to lock and unlock valves was removed from the contaminated area by the auxiliary operators, and surveyed by the operators at the nearest frisking station. The auxiliary operators indicated that their surveying of equipment used inside the contaminated area was an allowed practic During follow-up with health physics personnel regarding these observations, the inspectors noted that the procedure requirements for contamination control had not been met. Subsequent conversations with the auxiliary operators confirmed that the required actions were not performed and that the operators were not aware of the

. requirement Technical Specification Requirement 6.4.1, requires, in part, that written procedures shall be implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 7(e)(4) of Appendix A of Regulatory Guide 1.33 specifies radiation protection procedures for contamination contro Attachment 3, "Personnel Contamination Monitoring Req1.,1irements," of Procedure 7.15,

"Contamination Control," Revision 7, implements requirements for contamination control, and required, in part, that upon exiting from a contaminated area, personnel use the nearest PCM-1 B, and if one is not available, perform a hand and foot frisk at the nearest frisking station.

Attachment 4, "Requirements for Removal of Tools and Hand Carried Items from the Radiation Controlled Area," of Procedure 7.15, required, in part, that upon removal of hand carried items from a contaminated area, the item is properly bagged and transferred to Access Control and radiation safety technicians survey the item for release from the Radiation Controlled Are The failure to implement the requirements of Procedure 7.15 for contamination control is a violation of Technical Specification Requirement 6.4.1. This Severity Level IV Violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was entered into the licensee's corrective action program as Condition Report C-PAL-99-1480. (NCV 50-25_5/99010-01)

Health physics personnel instituted immediate corrective actions and initiated Condition Report C-PAL-99-1480 which documented the issue in the licensee's corrective action program. In addition, operations personnel initiated immediate corrective actions by ensuring a discussion of required health physics practices was conducted during the shift briefings held for oncoming operations shift Conclusions The inspectors identified two examples* where operations personnel failed to implement the radiation protection requirements for contamination control. These examples resulted in a Severity Level IV Non-Cited Violation. Although the instances did not result in the significant spread of contamination outside of the contamination area, deficiencies in operations personnel knowledge of basic radiation protection requirements were demonstrate *

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Conduct of Emergency Plan Activities P1.1 Significant Loss of Offsite Communication Capability Unusual Event Inspection Scope (71750. 71707)

• The inspectors observed the licensee's emergency response organization response to the significant loss of communications and the resultant Unusual Event that occurred on September 7, 199 Observations and Findings

• The inspectors noted that the loss of communication capabilities was accurately classified as an Unusual Event in accordance with the emergency plan. However, the declaration was delaye *

Licensee personnel first became aware that there was a problem with the commercial telephone system used to place calls to offsite locations at approximately 3:00 p.m. The problem was caused by work activities, not associated with the plant, that inadvertently cut two fiber optic cables approximately 30 miles from the plant. Following identification of the problem, a general plant announcement was made by the switchboard operator that indicated the site was "experiencing problems" with the offsite telephone lines:

However, the general plant announcement was not received in the control roo Consequently, the control room operators were unaware of the problem.

The problem was subsequently noted and communicated to the control room at 3:50 p.m. during routine testing of telephones by emergency planning personnel in preparation for an upcoming exercise. The Shift Supervisor immediately referred *to the Emergency Plan Implementing Procedure El-1, "Emergency Classification and Actions,"

Attachment 1, "Site Emergency Plan Classification" after being informed that all of the commercial telephone lines to place calls offsite were not working. Attachment 1 of Procedure El-1 specified that a significant loss of offsite communication capabilitywas classified as an unusual event and provided an example as "loss of all commercial and dedicated telephone lines." However, the Shift Supervisor did not declare the Unusual Event until 4:25 p.m., 35 minutes after being informed that all commercial telephone

• lines used to place calls offsite were unavailabl Factors that contributed*to the delay in declaring the Unusual Event included: -,_

. Control room operators had successfully contacted NRC, State of Michigan and

other local county agencies during an informational "courtesy" call using a satellite telephone available to them in the control room. The calls were made immediately after the control room operators were made aware of the problem which demonstrated the ability to communicate with offsite agencie Consequently, the perceived significance of the problem was inappropriately diminished; The plant announcement that was made by the switchboard operator was

"general" in nature in that it did not specify a "loss of communications." Instead it was informational and identified that the site was experiencing a "problem" with

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the commercial telephone lines. Consequently, the significance of the problem was not effectively communicated; Several site personnel, including the control room operators, did not hear the plant announcement that was made by the switchboard operator which delayed time of discovery by the operators; and

The example referenced in the emergency action levels, "loss of all commercial and dedicated telephones," caused some confusion with the operators in that satellite telephones were availabl Timely declaration of emergency events is needed to ensure that offsite agencies would be informed and ready to respond if adverse conditions degraded. During this event, the offsite agencies were immediately aware of the problem but were not necessarily in a "ready" status to respond during the first 35 minutes of the event, if needed, because an actual event had not been declared as per the emergency pla Also, the satellite telephone in the control room was intended to be used as a last resort in an emergency and not for regular, everyday communications. Consequently, offsite communication capabilities over an extended period with only the satellite telephone would have proven to be difficult in that the sound "quality" was less than desirable. In addition, the ability to.maintain an open line with the NRC, if needed, would have been in jeopard '

The inspectors noted the following positive attributes regarding the licensee's response to the Unusual Event:

Licensee personnel conducted a thorough investigation to determine the scope of the problem following discovery which identified that the Emergency Response Data System and the.Automatic Augmentation System for emergency response personnel were also not available. The Unusual Event was. declared immediately after it was identified that these othe'r emergency plan functions.

were also not available;

Required notifications were completed in a timely manner following declaration of the Unusual Event;

Site management initiated actions to ensure that minimum staffing of required.

emergency response organization personnel could be achieved if needed. This demonstrated a positive focus on safety and was considered pro-active and conservative; and,

Following repairs, the commercial telephone lines, the Automatic Augmentation System, and the Emergency Response Data System were tested and declared operable before the Unusual Event was exited..

The Unusual Event was terminated at a:31 p.m. on September 7, 1999.

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Conclusions.

The inspectors concluded that licensee emergency response personnel conducted a thorough investigation to determined the scope of the problem following discovery that the offsite commercial telephone lines were not available. The emergency event was accurately classified as an Unusual Event and the required notifications were completed in a timely manner following declaration. Actions initiated to ensure that the minimum required emergency response personnel could be achieved, if needed, were considered pro-active and demonstrated a positive focus on safet However, declaration of the Unusual Event was delayed. Ineffective communication following initial discovery that the offsite commercial telephone lines were lost and the diminished perceived significance because of the availability of emergency use satellite telephones contributed to the delayed declaratio P5 Staff Training and Qualification in Emergency Planning P Emergency Plan Exercise * Inspection Scope (71750)

The inspectors observed the Emergency Plan exercise on September 8, 1999, in. the Technical Support Center and the Emergency Offsite Facility. In addition, the inspectors observed the post exercise critique that was conducted in the Emergency Offsite facility and reviewed applicable procedure Observations and Findings The inspectors noted that emergency planning personnel effectively used the exercise to satisfy the training objectives. The emergency offsite facility's environment was professional and the unnecessary noise level was kept to a minimum. The post

.

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exercise critique in the emergency offsite facility effectively identified areas for improvernent and was considered self-critical. The critique comments were subsequently documented on a "punch list" that was maintained by emergency planning personnel for tracking and trending any necessary corrective actions..

The inspectors noted the following deficiencies while observing exercise activities and while reviewing procedures:

. Failed fuel monitor modeling was incorrect during the exercise. Information from the monitor was available from the plant computer that would not be available in the plant. The monitor was configured in the plant such that it was inoperable and did not input to the plant computer because of inadvertent alarms. The inspectors noted that an evaluation was ongoing to retire the monitor in plac Also, Emergency Plan Implementing procedures inappropriately referenced the failed fuel monitor parameters as a method of detection for failed fuel. Condition Report C-PAL-99-1469 was generated and entered into the licensee's correctiv action program regarding this ite ;,.

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A temporary modification currently installed.in the plant that jumpers out the failed fuel monitor low flow alarm was not installed in the simulator. A lack of communication from operations and engineering personnel to the training department regarding the status of the temporary modification contributed to this deficiency. Condition Report C-PAL-99-1469 was generated and entered into the licensee's corrective action program regarding this ite *

The failed fuel monitor modeling error was not identified when the scenario was validated for the exercise which demonstrated a lack of rigor regarding attention to detai The noted deficiencies were also identified by licensee personnel during the post exercise critique. The inspectors determined that the status of the failed fuel monitor was specified and actively tracked on the Operations Limiting Condition for Operation Board Anne Conclusions The inspectors concluded that emergency planning personnel effectively used an exercise to satisfy the training objectives. The post exercise critique was self-critical which demonstrated an appropriate threshold for identifying deficiencie However, a lack of rigor and poor attention to detail contributed to deficiencies regarding Emergency Plan Implementing procedures and simulator modeling of the failed fuel monito V. Management Meetings

. X1 Exit Meeting Summary.

The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 21, 1999. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary. No proprietary information was identified.

• '.

PARTIAL LIST OF PERSONS CONTACTED Licensee G. R. Boss, Operations Manager 8. E. Dotson, Licensing R. A. Gambrill, Component Engineering Supervisor R. M. Hamm, Electrical/l&C Supervisor, System Engineering N. L. Haskell, Director, Licensing D. G. Malone, Licensing R. L. Massa, Shift Operations Supervisor T. J. Palmisano, Site Vice President D. W. Rogers, General Manager, Plant Operations G. E. Schrader, Component Engineering R. G. Schaaf, Project Manager, NRR IP 37551:

IP 61726:

IP 62707:

IP 7t707:

IP 71750:

IP 92901:

IP 92903:

IP 92700:

INSPECTION PROCEDURES USED Onsite Engineering Surveillance Observations Maintenance Observations Plant Operations Plant Support Activities Follow-Up Operations Follow-Up Engineering LER Follow-Up.

Opened 50-255/99010-01 Closed 50-255/99010-01 Discussed None ITEMS OPENED, CLOSED, AND DISCUSSED NCV Failure to follow radiation protection procedures on contamination contro NCV Failure to follow radiation protection procedures on contamination contro *,.

Licensee:

Consumers Energy Company Event No:

Facility:

Palisades Nuclear Plant Event Date: October 15, 1999 City:

Jackson State:

Michigan Unit:

Region: 3 Rx Info:

PWR/CE Location Code: POW Docket:

050-255 Notification Date & Method: October 18, 1999; SRI Via Telecon SUBJECT: PALISADES SHUTDOWN FOR PLANNED REFUELING OUTAGE Contact:

Anton Vegel (630) 829-9620 fr)

Discussion: The Palisades Nuclear Plant was taken off-line on October 15, 1999, at 11 :24 p.m., for the scheduled 1999 refueling outage: In addition to the refueling activities, other major maintenance activities that were scheduled include: 1) Primary Coolant Pump P-50D motor replacement; 2) Primary Coolant Pump P-50A pump casing leak repairs and pump rebuild; 3) replace shaft seals on three primary coolant pumps; and 4) replace both low pressure turbine rotors on the main turbine generato Regional Action: Resident inspectors observed portions of the reactor and plant shutdown activities and will inspect various outage activities.