IR 05000255/2002004

IR 05000255-02-004, on 04/01-2002-06/30-2002, Nuclear Management Company, LLC, Palisades Nuclear Generating Plant. Personnel Performance Related to Non-Routine Plant Evolutions and Events, and Problem Identification and Resolution

ML021980580
Person / Time
Site:	Palisades
Issue date:	07/17/2002
From:	Passehl D NRC/RGN-III/DRP/RPB6
To:	Cooper D Nuclear Management Co
References
IR-02-004
Download: ML021980580 (38)

Text

uly 17, 2002

SUBJECT:

PALISADES NUCLEAR GENERATING PLANT NRC INSPECTION REPORT 50-255/02-04(DRP)

Dear Mr. Cooper:

On June 30, 2002, the NRC completed an inspection at your Palisades Nuclear Generating Plant. The enclosed report documents the inspection findings which were discussed on June 27, 2002, with members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, we identified two issues of very low safety significance (Green) that were determined to involve violations of NRC requirements. However, because of the very low safety significance and because the issues were entered into your corrective action program, the NRC is treating these issues as Non-Cited Violations in accordance with Section VI.A.1 of the NRC s Enforcement Policy. If you deny these Non-Cited Violations, you should provide a response with a basis for your denial, within 30 days of the date of this inspection report, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector Office at the Palisades facility. In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Dave Passehl, Acting Chief Branch 6 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 50-255/02-04(DRP)

REGION III==

Docket No: 50-255 License No: DPR-20 Report No: 50-255/02-04(DRP)

Licensee: Nuclear Management Company, LLC Facility: Palisades Nuclear Generating Plant Location: 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Dates: April 1 through June 30, 2002 Inspectors: J. Lennartz, Senior Resident Inspector R. Krsek, Resident Inspector T. Madeda, Physical Security Inspector R. Winter, Reactor Engineer H. Peterson, Senior Operations Engineer Observer: M. Castenado, Nuclear Safety Intern / Reactor Engineer Approved by: Dave Passehl, Acting Chief Branch 6 Division of Reactor Projects

SUMMARY OF FINDINGS IR 05000255/02-04, Nuclear Management Company, LLC, on 04/01/2002 - 06/30/2002, Palisades Nuclear Generating Plant. Personnel Performance Related to Non-Routine Plant Evolutions and Events, and Problem Identification and Resolution.

This report covers a 12-week period of resident inspection, a review of annual operating test results by a regional senior operations engineer and an announced baseline physical protection inspection by a physical security inspector. The significance of most findings is indicated by their color (green, white, yellow, red) using Inspection Manual Chapter 0609, Significance Determination Process, (SDP). The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, Reactor Oversight Process, Revision 3, dated July 2000.

A. Inspector Identified Findings Cornerstone: Initiating Event C Green. The inspectors identified one Green self-revealed finding that is being treated as a Non-Cited Violation of Technical Specifications 5.4, Procedures, for the failure to establish and maintain System Operating Procedure 30, Station Power. This procedure is used for electrical system equipment control, an activity contained in Appendix A to Regulatory Guide 1.33. Specifically, steps for the tag out of stored energy breakers did not provide adequate physical controls to prevent inadvertent system/component interactions. This resulted in the independent tripping of Cooling Tower Pump P-39B on June 11, 2002, while the plant was at full power.

This self-revealed finding was determined to be of very low safety significance (Green) by the significance determination process, because: (1) the finding did not contribute to the likelihood of a Primary or Secondary system Loss of Coolant Accident initiator; (2) the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available; and (3) the finding did not increase the likelihood of a fire or internal/external flood. (Section 1R14.1)

Cornerstone: Mitigating Systems C Green. The inspectors identified a Green finding that is being treated as a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the failure to promptly identify and correct conditions adverse to quality regarding the licensees review, acceptance, and approval of licensee contractors procedures utilized to perform work and testing on all safety-related electrical components at the plant.

This inspector identified finding was determined to be of very low safety significance (Green) by the significance determination process, because: (1) the finding was not a design or qualification deficiency; (2) the finding did not represent an actual loss of safety function; (3) the finding did not represent an

actual loss of a safety function of a single train for greater than Technical Specification outage time; (4) the finding did not represent an actual loss of a safety function of one or more Non-Technical Specification trains of equipment; and (5) the finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. (Section 4OA2)

B. Licensee Identified Findings None.

Report Details A list of documents reviewed within each inspection area is included at the end of the report.

Summary of Plant Status The plant was at full power for the majority of the inspection period. However, from May 17 to May 20, 2002, Reactor Power was reduced to 22 percent for a planned oil addition to the Reactor Coolant Pump P-50D. On June 11, 2002, a rapid downpower was initiated from 100 percent to 50 percent, due to the inadvertent loss of Cooling Tower Pump P-39B. Power was returned to 99 percent on the morning of June 14, 2002; however, power was again reduced on June 14, 2002, to 90 percent due to the emergent, sporadic opening and closing of Reheat Intercept Valve CV-0540. The plant was returned to full power on June 15, 2002, and remained essentially at full power for the remainder of the inspection period.

1. REACTOR SAFETY Cornerstones: Initiating Event, Mitigating Systems, Barrier Integrity, Emergency Preparedness 1R01 Adverse Weather (71111.01)

a. Inspection Scope The inspectors assessed plant procedures to protect mitigating systems from high winds, tornado and hot weather condition risks for the site. The inspectors queried operations personnel regarding the actions that would be taken in response to notification of high wind conditions and reviewed the licensees procedures utilized to mitigate weather induced risks.

The inspectors also verified that licensee personnel had completed the necessary actions in preparation for the onset of warm weather.

b. Findings No findings of significance were identified.

1R04 Equipment Alignment (71111.04Q)

.1 Quarterly Equipment Alignment Walkdowns a. Inspection Scope The inspectors performed partial walkdowns of the Emergency Diesel Generator 1-2, Low Pressure Safety Injection Pump P-67A and Auxiliary Feedwater Pumps P-8A and P-8B. The inspectors performed the walkdowns to verify proper system lineup. The Diesel Generator 1-2 walkdowns were performed while redundant plant equipment was out of service. For the systems walked down, the inspectors verified that power was

available, that accessible equipment and components were appropriately aligned, and that no discrepancies existed which would impact the systems function. Portions of the system alignment inspection included discussions and system walkdowns with operations and engineering personnel.

The inspectors also reviewed condition reports related to equipment alignment issues to verify that the problems were appropriately characterized.

b. Findings No findings of significance were identified.

1R05 Fire Protection Area Walkdowns (71111.05)

a. Inspection Scope The inspectors toured the following areas in which a fire could affect safety-related equipment:

• Cable Spreading Room (Fire Area 2);

• Turbine Building (Fire Area 23);

• 1C Switchgear Room (Fire Area 4);

• Battery Room No. 2 (Fire Area 11); and

• Emergency Diesel Generator Room 1-2 (Fire Area 6).

The inspectors assessed the material condition of the passive fire protection features and verified that transient combustibles and ignition sources were appropriately controlled. Also, the inspectors reviewed documentation for randomly selected completed surveillances to verify the availability of the sprinkler fire suppression system, smoke detection system, and manual fire fighting equipment for these areas.

The inspectors also verified that the fire protection equipment that was installed and available in the fire areas corresponded with the equipment which was referenced in the applicable portions of the Final Safety Analysis Report, Section 9.6, Fire Protection.

Finally, for Fire Areas where compensatory actions were in place, the inspectors verified the compensatory actions were implemented.

b. Findings No findings of significance were identified.

1R06 Flood Protection (71111.06)

a. Inspection Scope The inspectors reviewed and assessed flood protection measures for external flooding events including plant areas with safety-related equipment which were below flood levels that were susceptible to groundwater ingress. The inspectors also reviewed

preventative maintenance activities that had been completed on watertight barriers for the areas below flood levels.

In addition, the inspectors reviewed applicable design basis documentation and relevant plant procedures to verify that the licensees flooding mitigation plans and equipment were consistent with design requirements and the risk analysis assumptions. Further, the inspectors reviewed condition reports to verify that identified problems associated with flood protection activities were appropriately characterized and entered into the licensees corrective action program.

b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification (71111.11Q)

.1 Quarterly Resident Inspector Licensed Operator Performance Observations a. Inspection Scope The inspectors observed licensed operator performance during annual requalification examinations on the plant simulator to assess the operators ability to complete required actions in off-normal and emergency operating procedures. The inspectors also reviewed the completed operator evaluations to assess the licensee evaluators ability to identify and assess operator performance deficiencies.

In addition the inspectors reviewed condition reports to verify that identified problems associated with licensed operator requalification training activities were appropriately characterized.

b. Findings No findings of significance were identified.

.2 Annual Operating Test Results (71111.11)

a. Inspection Scope The inspectors reviewed the overall pass/fail results of individual Job Performance Measure operating tests and simulator operating tests (required to be given per 10 CFR 55.59(a)(2)) administered by the licensee during calender year 2002. The biennial written examination was administered during calender year 2001.

b. Findings No findings of significance were identified.

1R12 Maintenance Rule Implementation (71111.12Q)

a. Inspection Scope The inspectors reviewed the licensees Maintenance Rule Scoping Document for the following plant equipment designated as having high safety significance:

C Component Cooling Water System; C 480-Volt AC Power System; and C Control Room Heating, Ventilation and Air Conditioning.

The inspectors reviewed the licensees maintenance rule performance indicators associated with the systems maintenance rule category status. In addition, the inspectors discussed various technical issues with the applicable system engineer.

Further, the inspectors reviewed selected condition reports to verify that the identified issues were appropriately characterized and were dispositioned in accordance with the licensees Maintenance Rule program. The inspectors reviewed selected condition reports to verify that designated corrective actions were reasonable and had been implemented as scheduled.

b. Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation (71111.13Q)

a. Inspection Scope The inspectors reviewed, Operators Risk Reports, Shift Supervisor logs, and maintenance activity schedules to verify that equipment necessary to minimize plant risk was operable or available as required. The inspectors also conducted plant tours to verify that equipment necessary to minimize risk was available for use during the following planned and emergent maintenance activities:

C Planned maintenance on High Pressure Safety Injection Pump P-66A and Service Water Pump P-7B; C Emergent maintenance on a switchyard breaker in combination with emergent inclement weather; C Planned maintenance on Emergency Diesel Generator 1-1 with ongoing planned switchyard work activities; and C Emergent maintenance on 345-kiloVolt switchyard R Bus with an emergent Cooling Tower Pump P-39B Trip.

The inspectors discussed plant configuration control for the maintenance activities with operations, maintenance and work control center staff to verify that work activities were appropriately controlled.

In addition, the inspectors reviewed select condition reports to verify that problems regarding maintenance risk assessments and control of emergent work activities were appropriately characterized and entered into the licensees corrective action program.

b. Findings No findings of significance were identified.

1R14 Personnel Performance Related to Non-Routine Plant Evolutions and Events (71111.14Q)

.1 Loss of Cooling Tower Pump P-39B While at Full Power a. Inspection Scope The inspectors assessed operator performance in response to the inadvertent trip of Cooling Tower Pump P-39B trip on June 11, 2002. The inspectors observed the operators actions in the control room in response to this pump trip and verified that the operators responded appropriately in accordance with Off Normal Operating Procedure -

14, Loss of Condenser Vacuum, Off Normal Operating Procedure - 26, Rapid Power Reduction, and the various annunciator response procedures. In addition, the inspectors verified the appropriate Technical Specifications were met for the subsequent rapid downpower of reactor power to 50 percent.

Further, the inspectors reviewed the resultant condition reports that were initiated to verify that this issue was entered into the corrective action program with the appropriated characterization and significance.

b. Findings The inspectors identified one Green self-revealed finding that is being treated as a Non-Cited Violation of Technical Specifications 5.4, Procedures, for the failure to establish and maintain the applicable procedure for electrical system equipment control, an activity contained in Appendix A to Regulatory Guide 1.33. Specifically, the licensee did not maintain the applicable procedure for electrical system equipment control, System Operating Procedure 30, Revision 32, Station Power. The steps for the tag out of stored energy breakers from service did not provide adequate physical controls to prevent inadvertent system/component interactions. This, in turn, resulted in the tripping of Cooling Tower Pump P-39B on June 11, 2002, while the plant was at full power.

On June 11, 2002, the plant was at 100 percent power when the control room operators received unexpected alarms which indicated that 4160-Volt Bus 1G was in an under voltage condition and that Cooling Tower Pump P-39B, fed from Bus 1G, had tripped.

The inspectors observed control room activities and noted that the operating crew responded appropriately to the alarms and initiated a rapid downpower of plant power to 50 percent. At the time this evolution occurred, the plant was in a degraded offsite power condition due to the loss of the switchyard R Bus on June 10, 2002, due to a failed lightning arrester on the Y phase of the Start-up Transformer.

The licensee later identified that at the time Pump P-39B tripped, an auxiliary operator and System Maintenance and Construction Services (SM&CS) personnel were verifying the tag out of Breaker 252-204 (Start-up Transformer 1-3 to Bus 1G Supply Breaker).

System Operating Procedure 30, Station Power, Section 8.4.1, provided instructions for the removal of the Allis-Chalmers 4160-Volt Breaker stored energy breaker from service. In accordance with that procedure, the operator attached the breaker fuse block and red personal protective tag to a shower curtain hook. Within the breaker cubicle, the operator placed the shower curtain hook, with the fuse block and red tag, through the breaker depressing lever (foot pedal). Breakers similar to Breaker 252-204 were located on all plant busses, including the safety-related busses, and were tagged out utilizing System Operating Procedure 30.

The auxiliary operators had tagged out the breaker in accordance with System Operating Procedure 30; however, upon closing the cubicle door for Breaker 252-204 and after showing clearance to the SM&CS personnel, the fuse block contacted the under voltage relays located on the bottom of the cubicle door. This, in turn, caused the control room to lose Bus 1G voltage indication and activated the under voltage relay for Bus 1G which, by design, tripped Pump P-39B. Based on these events, the inspectors concluded that System Operating Procedure 30 was not adequately maintained, in that, it did not provide adequate instructions to prevent an inadvertent system interaction with the removed fuse block.

The inspectors determined that the failure to maintain the appropriate, applicable procedure for electrical system equipment control could have a credible impact on safety, could be reasonably viewed as a precursor to a significant plant event such as a reactor or turbine trip, and that if left uncorrected, could become a more significant safety concern. The inspectors also determined that this issue could cause or increase the frequency of an initiating event. Therefore this issue was considered a licensee performance deficiency which was more than minor.

The inspectors assessed this finding using Manual Chapter 0609, Significance Determination Process, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. The inspectors determined that the finding was a transient initiator contributor, in that, the activation of bus under voltage relays could lead to the loss of plant equipment which could result in either a reactor or turbine trip affecting the initiating event cornerstone. The inspectors determined that:

• The finding did not contribute to the likelihood of a Primary or Secondary system Loss of Coolant Accident initiator;

• The finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available; and

• The finding did not increase the likelihood of a fire or internal/external flood.

Therefore, the finding was determined to be of very low safety significance (Green).

Technical Specification 5.4.1, Procedures, requires, in part, that written procedures be established, implemented, and maintained covering the activities and applicable procedures recommended in Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A to Regulatory Guide 1.33, lists equipment control (e.g. locking and tagging)

and onsite electrical systems as requiring written procedures. Contrary to this, licensee personnel did not establish and maintain the appropriate, applicable procedure for electrical system equipment control, in that, Section 8.4.1 of System Operating Procedure 30 was not appropriate to the circumstances for the tag out of stored energy breakers from service. This violation is associated with a self-revealed finding that is characterized by the significance determination process as having very low risk significance (Green) and is being treated as a Non-Cited Violation of licensee Technical Specifications 5.4.1, Procedures, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 50-255/02-04-01)

This finding is in the licensees corrective action program as Condition Report CPAL0202280, Inadvertent Actuation of Under-Voltage Relay 227X-4 Causes P-39B Trip. The licensee took immediate corrective actions by requiring that all similar stored energy breakers be taken out of service by removing the breaker from the cubicle when tagged out of service.

.2 Other Non-Routine Evolutions a. Inspection Scope The inspectors observed and assessed operator performance in the control room in response to the following events which occurred during the inspection period:

• On June 10, 2002, the R or Rear Bus in the switchyard was deenergized due to the failure of a lightning arrester on the Start-Up Transformer Y Phase power lines between the switchyard and the plant. The lightning arrester failure caused Start-Up Transformer 1-2 to become inoperable, and the plant entered a 72-hour Limiting Condition for Operation under Technical Specification 3.8.1 to restore the R Bus.

• On June 14, 2002, Control Valve CV-0540, No. 2 Intercept Valve from Moisture Separator Reheater E-9A to the A Low Pressure Turbine began to spuriously open and close while the plant was near full power. The cycling of the intercept valve caused secondary plant feedwater transients which were abated when the test circuitry to Control Valve CV-0540 was determinated.

The inspectors reviewed the applicable Off-Normal Procedures, System Operating Procedures, General Operating Procedures, and Technical Specifications for these events. Further, the inspectors reviewed the control room logs and the resultant condition reports which were initiated to verify that these issues were entered into the corrective action program with the appropriate characterization and significance.

b. Findings No findings of significance were identified.

1R15 Operability Evaluations (71111.15Q)

a. Inspection Scope The inspectors reviewed the operability assessments as documented in the associated condition reports for the following risk significant components:

• Primary Coolant Pump Controlled Bleed-Off Line Isolation Valves;

• High Pressure Safety Injection Pump P-66B Breaker 152-113;

• Containment Air Cooler-4 Service Water Inlet Isolation Valve CV-0869; and

• Fire Penetration FZ-0126 in the Cable Spreading Room.

The inspectors interviewed the cognizant engineers and reviewed the supporting documents to assess the adequacy of the operability assessments for the current plant Mode. The inspectors also reviewed the applicable sections of the Technical Specifications, Final Safety Analysis Report, and Design Basis Documents to verify that the operability assessments were technically adequate and that the components remained available, such that no unrecognized increase in plant risk had occurred.

Further, the inspectors reviewed select condition reports to verify that identified problems associated with the operability evaluations were appropriately characterized and entered into the licensees corrective action program.

b. Findings No findings of significance were identified.

1R16 Operator Workarounds (71111.16S)

a. Inspection Scope The inspectors reviewed the operator challenges, operator workarounds, and control room deficiencies that have been identified by licensee personnel to assess the cumulative effects on the reliability, availability and potential for incorrect operation of accident mitigating systems. The inspectors assessed the cumulative effects on the operators ability to implement abnormal and emergency response procedures to verify that the operators could respond in a correct and timely manner to plant transients and accidents.

The inspectors also reviewed condition reports related to operator workarounds to verify that identified problems were appropriately characterized and to verify that corrective actions were reasonable and had been implemented as scheduled.

b. Findings No findings of significance were identified.

1R19 Post Maintenance Testing (71111.19Q)

a. Inspection Scope The inspectors observed portions of post maintenance testing and reviewed documented testing activities following scheduled maintenance to determine whether the tests were performed as written. The inspectors also verified that applicable testing prerequisites were met prior to the start of the tests and that the effect of testing on plant conditions was adequately addressed by control room staff. Post maintenance test activities were reviewed for the following:

• Component Cooling Water Pump P-52C;

• Emergency Diesel Generator 1-1;

• Containment Spray Pump P-54B;

• Startup Transformer 1-2; and

• Diesel Driven Fire Pump P-41.

The inspectors reviewed post maintenance testing criteria to verify that the test criteria was appropriate with respect to the scope of work performed and that the acceptance criteria were clear.

In addition, the inspectors reviewed the completed tests and procedures to verify that the tests adequately verified system operability. Documented test data was reviewed to verify that the data was complete and that the equipment met the procedure acceptance criteria, which demonstrated that the equipment was able to perform the intended safety functions.

Further, the inspectors reviewed condition reports regarding post maintenance testing activities to verify that identified problems were appropriately characterized.

b. Findings No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope The inspectors observed portions of the following surveillance testing activities conducted on risk-significant plant equipment to verify that testing was conducted in accordance with prescribed procedures:

• Auxiliary Feedwater System;

• Safety Injection System; and

• Emergency Diesel Generator 1-2.

The inspectors also reviewed the documented test data for the Technical Specification Surveillance Test procedures and the associated basis documents to verify that testing acceptance criteria were satisfied.

In addition, the inspectors reviewed applicable portions of Technical Specifications, the Final Safety Analysis Report and Design Basis Documents to verify that the surveillance tests adequately demonstrated that system components could perform designated safety functions.

Further, the inspectors reviewed condition reports regarding surveillance testing activities to verify that identified problems were appropriately characterized.

b. Findings No findings of significance were identified.

1E06 Emergency Plan Drill Evaluation (71114.06)

a. Inspection Scope The inspectors observed performance of emergency response personnel in the simulator control room and the technical support center during a drill on May 1, 2002, and in the simulator control room and the emergency offsite facility during a drill on May 22, 2002. The observations were conducted to verify that emergency response personnel classified the event and completed appropriate offsite notifications in an accurate and timely manner. The inspectors also verified that emergency response personnel provided protective action recommendations to offsite authorities in accordance with emergency plan implementing procedures.

The inspectors observed the post-drill critique to verify that licensee evaluators adequately identified emergency response performance problems and reviewed the associated condition reports to verify that identified problems were appropriately characterized.

b. Findings No findings of significance were identified.

3. SAFEGUARDS Cornerstone: Physical Protection 3PP3 Response to Contingency Events (71130.03)

a. Inspection Scope The inspector reviewed and evaluated the licensees current Protective Strategy which included target set analysis, observation of weapon requalification and stress firing activities with assigned and contingency weapons at an offsite firing range. The inspector conducted a walk down of the protected area physical barrier and associated intrusion alarm system and observed testing of selected protected area intrusion alarm zones. The inspector observed and evaluated alarm station operator performance and evaluated the assessment capability of the protected area closed circuit television

system. Security defensive positions, as defined in the licensees protective strategy, were observed and evaluated, and the inspector discussed with licensee security personnel their current defense strategy and associated response procedures. The inspector observed one licensee conducted table top exercise and reviewed selected procedures, training records, and licensee drill and exercise critiques pertaining to response to security contingency events.

b Findings No findings of significance were identified.

4. OTHER ACTIVITIES (OA)

4OA1 Performance Indicator Verification (71151)

a. Inspection Scope The inspectors verified that the data submitted by the licensee was accurate and complete for the following Performance Indicators:

• High Pressure Safety Injection Pump Unavailability;

• Unplanned Scrams; and

• Scrams With Loss of Normal Heat Removal.

The inspectors reviewed control room logs, licensee monthly operating reports, licensees Incident Analysis System logs, completed Technical Specification Surveillance Tests, and the licensees maintenance work order database for April 2001 through April 2002, to verify that the licensee had accurately reported the high pressure safety injection pump unavailability performance indicator for these quarters.

The inspectors also reviewed Palisades Nuclear Plant monthly operating data from July 2001 until March 2002 to verify that the licensee accurately reported the unplanned scrams and the scrams with loss of normal heat removal performance indicators.

In addition, the inspectors discussed the data with the licensee staff responsible for gathering and reporting the information related to the performance indicators.

b. Findings No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152)

a. Inspection Scope The inspectors reviewed the condition report evaluation and corrective actions associated with Condition Report CPAL0103678, System Maintenance and Construction Services Laboratory Procedures not Included in Administrative Procedure 10.41, Procedure Initiation and Revision, as Requiring Periodic Reviews.

The inspectors verified that this condition adverse to quality was entered into the corrective action program and that the appropriate corrective actions were identified and implemented by the licensee.

b. Findings The inspectors identified a Green Finding that is being treated as a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the failure to promptly identify and correct conditions adverse to quality regarding the licensees review, acceptance and approval of licensee contractors procedures utilized to perform work and testing on safety-related electrical components at the plant.

In November 2001, the inspectors observed the calibration of the Safeguards Bus 1C undervoltage and time delay relays performed by System Maintenance and Construction Services (SM&CS), a contractor for the licensee (NRC Inspection Report 50-255/01-14(DRP)). At Palisades, SM&CS personnel perform the majority of preventive, corrective and post maintenance testing on safety-related electrical components at the plant. After noticing some minor quality issues with the procedures SM&CS personnel used, the inspectors questioned licensee personnel regarding the availability and extent of the owner acceptance reviews the licensee performed of their contractors SM&CS procedures.

The licensee subsequently determined that SM&CS procedures were not being reviewed in accordance with the licensees procedures. Condition Report CPAL0103678, SM&CS Lab Procedures not included in AP 10.41, Procedure Initiation and Revision as Requiring Reviews, was initiated by licensee personnel.

The inspectors reviewed the completed condition report evaluation and corrective actions in April 2002 and noted that the conclusion of licensee personnel was that the contractor had reviewed their own procedures and, therefore, that the contractors procedures did not require review by the licensee. The subsequent corrective action was the initiation of a procedure change request to exempt all SM&CS procedures from having to be reviewed by the licensee and approved by the Plant Review Committee, even though the procedures were utilized to perform the work and testing on safety-related electrical components in the plant.

However, the inspectors noted again that the contractors procedures were utilized for work performed on safety-related electrical components. 10 CFR 50 Appendix B, Criterion V, Procedures; Administrative Technical Specification 5.4, Procedures; and also CPC-2A, Quality Program Description for the Palisades Plant, required that all

work and maintenance on safety-related equipment be performed in accordance with approved, established, implemented and maintained procedures. Therefore, the licensee was required to review the SM&CS procedures and approve the procedures through the Plant Review Committee. The licensees Nuclear Oversight Department also concurred with the inspectors assessment.

The inspectors determined that this issue has existed since the mid-1990s when a procedure change inadvertently omitted previous requirements which specified that SM&CS procedures required licensee review. The inspectors also reviewed the licensees corrective action system and noted numerous condition reports related to problems associated with the quality of SM&CS procedures and the quality of SM&CS oversight by licensee personnel. In addition, the inspectors noted that a causal factor in recent problems associated with the electric driven Fire Pump P-9A breaker maintenance was the quality of SM&CS procedures used during the activities (NRC Inspection Reports 50-255/01-17(DRP) and 50-255/02-02(DRP)).

The inspectors determined that the failure to promptly identify and correct conditions adverse to quality regarding the SM&CS procedures, utilized for work on all safety-related electrical equipment which were not reviewed and approved in accordance with the licensees quality assurance program, could have a credible impact on safety, and that if left uncorrected could become a more significant safety concern. Therefore, this issue was considered a licensee performance deficiency which was more than minor.

The inspectors also determined that this issue could credibly affect the operability, availability, reliability or function of a mitigating system, in that all mitigating systems utilize the safety-related electrical components worked on by SM&CS personnel.

The inspectors assessed the finding using Manual Chapter 0609, Significance Determination Process, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. The inspectors determined that the finding affected the mitigating system cornerstone in that the procedures were utilized for work on all safety-related electrical equipment, used to supply the power source for mitigating system equipment. The inspectors determined that:

C The finding was not a design or qualification deficiency; C The finding did not represent an actual loss of safety function of a system; C The finding did not represent an actual loss of a safety function of a single train for greater than Technical Specification outage time; C The finding did not represent an actual loss of a safety function of one or more Non-Technical Specification trains of equipment; and C The finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.

Therefore, the finding was determined to be of very low safety significance (Green).

10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, requires in part that conditions adverse to quality be promptly identified and corrected. Contrary to this, licensee personnel failed to appropriately identify and correct the condition adverse to quality documented in Condition Report CPAL0103678, SM&CS Lab Procedures not included in AP 10.41, Procedure Initiation and Revision as Requiring Reviews, in that,

the licensee inappropriately concluded that the review and approval of SM&CS procedures utilized to perform work on safety-related electrical equipment was not required and inappropriately initiated corrective actions to exempt these procedures from licensee review and approval. This violation is associated with an NRC identified finding that is characterized by the significance determination process as having very low risk significance (Green) and is being treated as a Non-Cited Violation of 10 CFR 50 Appendix B, Criterion XVI, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 50-255/02-04-02)

This finding is in the licensees corrective action program as Condition Report CPAL0201265, Inappropriate Result from the Analysis in Support of an Assigned Corrective Action.

4OA3 Event Follow-up (71153)

(Closed) Licensee Event Report (LER) 50-255/01-003:

Small Fire Within the Plant Protected Area. On May 18, 2001, a security officer, while conducting a routine security patrol, discovered a small fire in a trash barrel located inside a shop building within the protected area. The officer extinguished the fire. No damage to plant equipment or safety-related equipment occurred. No personnel injuries were identified. Investigative activities included an offsite corporate review and an investigation by the local law enforcement agency. The local office of the Federal Bureau of Investigation was notified of the event and associated investigation activities.

Investigation activities determined that the cause of the fire was suspicious (the building was unoccupied at the time), but no specific individual was identified. No violation of NRC requirements was identified. This Licensee Event Report is closed.

4OA4 Cross-Cutting Issues Corrective Actions In Section 4OA2 of this report a Green finding (50-255/02-04-02) is documented for the failure to promptly identify and correct a condition adverse to quality which affected the Mitigating Systems Cornerstone.

4OA6 Meetings

.1 Exit Meeting The inspectors presented the inspection results to Mr. and other members of licensee management on June 27, 2002. Licensee personnel acknowledged the findings presented. The inspectors asked licensee personnel whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

.2 Interim Exit Meetings The results of the review of licensed operator annual requalification examination results for calendar year 2002 were presented to Mr. R. Bender, Operations Requalification Training Supervisor on April 3, 2002. The inspector asked licensee personnel whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

The results of the Safeguards inspection were presented to Mr. and other members of the licensees management on May 16, 2002. Licensee personnel acknowledged the inspectors comments. The inspector asked licensee personnel whether any materials examined during the inspection should be considered proprietary.

No proprietary information was identified.

KEY POINTS OF CONTACT Licensee T. Brown, Manager, Chemical and Radiological Services D. Cooper, Site Vice President D. Crabtree, Systems Engineering Manager B. Dotson, Licensing Analyst J. J. Fletcher, Security Manager P. Harden, Director, Engineering N. Haskell, Nuclear Oversight Manager G.W. Hettel, Manager, Maintenance and Construction L. Lahti, Licensing Manager D. G. Malone, Supervisor, Regulatory Assurance D. J. Malone, General Plant Manager T. OLeary, Plant Support Director G. Packard, Operations Manager D. Vandewalle, Operations Superintendent E. Weinkam, Director Regulatory and Strategic Issues NRC D. Passehl, Acting Branch Chief, RIII D. Hood, Project Manager, NRR

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-255/02-04-01 NCV Green. Technical Specification 5.4.1, Procedures, licensee personnel did not maintain the appropriate, applicable procedure for electrical system equipment control, in that, the procedure steps were not appropriate to the circumstances for the tag out of certain stored energy breakers from service.

50-255/02-04-02 NCV Green. 10 CFR 50, Appendix B, Criterion XVI, licensee personnel failed to promptly identify and correct the condition adverse to quality in CPAL0103678, in that, the licensee incorrectly concluded that review and approval of SM&CS procedures utilized to perform work on safety-related electrical equipment was not required.

Closed 50-255/2001-003 LER Small Fire Within the Plant Protected Area.

50-255/02-04-01 NCV Green. Technical Specification 5.4.1, Procedures, licensee personnel did not maintain the appropriate, applicable procedure for electrical system equipment control, in that, the procedure steps were not appropriate to the circumstances for the tag out of certain stored energy breakers from service.

50-255/02-04-02 NCV Green. 10 CFR 50, Appendix B, Criterion XVI, licensee personnel failed to promptly identify and correct the condition adverse to quality in CPAL0103678, in that, the licensee incorrectly concluded that review and approval of SM&CS procedures utilized to perform work on safety-related electrical equipment was not required.

LIST OF ACRONYMS USED CFR Code of Federal Regulations CR Condition Report DRS Division of Reactor Safety FSAR Final Safety Analysis Report LER Licensee Event Report NCV Non-Cited Violation NRC Nuclear Regulatory Commission SM&CS System Maintenance and Construction Services SDP Significance Determination Process

LIST OF DOCUMENTS REVIEWED 1R01 Adverse Weather Protection SOP-23 Attachment 10, Warm Weather Checklist Revision 16 Procedure - 4 Administrative Procedure - Operations Revision 23 Organization, Responsibilities and Conduct ONP-12 Off Normal Procedure - Acts of Nature Revision 17 EOP-9 Functional Recovery Procedure Revision 13 WO 24114158 Work Order - Remove Exterior Cold Weather Covers of Fans V-21D-H at the Intake Structure Condition Reports Reviewed for Problem Identification Characterization and Corrective Actions CPAL0001200 Misleading Information on Warm Weather Checklist CPAL0002346 Weaknesses Found in Warm Weather Checklist and Corrective Actions for CPAL9901204 CPAL0202010 Possible Violation of FCC License Restrictions Associated with the Level Sensing Transmitters in the Screen House 1R04 Equipment Alignment Plant Procedures SOP-22, CL 22.2 Fuel Oil System Checklist Revision 31 SOP-22 Emergency Diesel Generators Revision 31 SOP-3 Safety Injection and Shutdown Cooling System Revision 19 SOP-12 Feedwater System Revision 41 SOP-20 High Pressure Control Air System Revision 19 4.00 Operations Organization, Responsibilities, and Revision 23 Conduct 4.02 Control of Equipment Revision 18

Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0201565 Scaffold/Shielding Installation Interferes with Valve Chain Operator CPAL0201549 Storage Racks for Handrails not Removed When Floor Plugs Removed Creating a Safety Hazard CPAL0201548 Storage/ of Cleaning/Deconning Supplies on Safety-Related Equipment 1R05 Fire Protection Plant Procedures ONP-12 Off-Normal Procedure - Acts of Nature Revision 17 AP-4.02 Administrative Procedure - Control of Equipment Revision 18 ONP-25.1 Off-Normal Procedure - Fire Which Threatens Revision 11 Safety-Related Equipment ONP25.2 Off-Normal Procedure - Alternate Safe Shutdown Revision 17 Procedure Miscellaneous Documents EA-PSSA-00-001 Palisades Plant Post Fire Safe Shutdown Revision 1 Summary Report, for Fire Areas 2, 23, 4, 11, and 6 Palisades Plant Analysis for Fire Areas 2, 23, 4, 11, 6 Revision 4 Fire Hazards Analysis EA-APR-98004 Engineering Analysis - Analysis of Problems June 30, 1998 Concerning Fire Doors RP0686-0269A- Engineering Analysis - Generic Letter 86-10 PPO3 Analysis of Fire Door Between Switchgear Room 1-C and 590' Elevation Auxiliary Building Corridor BTP ASB 9.5-1 U.S. NRC Branch Technical Position 9.5-1 - Revision 1 Guidelines for Fire Protection for Nuclear Power Plants Consumer Power Company - List of Changes Revision 2 and Response to Appendix A to Branch August 24, 1996 Technical Position APCSB 9.5-1 and Regulatory Guides 1.78 and 1.101

FSAR 9.6 Final Safety Analysis Report, Section 9.6 - Fire Revision 23 Protection U.S. NRC Fire Protection Safety Evaluation September 1, 1978 Report by the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission in the Matter of Consumers Power Company Palisades Plant Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0201341 Condition Report CPAL0201160 Classified at a Lower Significance Level than Appropriate CPAL0201414 Inappropriate Significance Level Assigned to Corrective Action Documents 1R06 Flood Protection Periodic and Predetermined Activity (Preventative Maintenance)

PPAC MSM071 Annual Inspection of Watertight Barriers August 24, 1999; December 12, 2001 PPAC X-OPS014 Engineering Safeguard Pump Lube and Test March 26, 2002 PPAC MSM091 5 Year Inspection of Watertight Barriers June 22, 1998 PPAC RWS215 Clean and Test LS-5211 For Alarm ED-1354 December 27, 2000 and Pump Start/Stop Miscellaneous Documents DBD-7.08 Design Basis Document, Plant Protection Revision 3 Against Flooding Staff Evaluation Report of Individual Plant April 22, 1999 Examination of External Events Submittal on Palisades Nuclear Plant MSM-M-16 Permanent Maintenance Procedure, Revision 9 Inspection of Watertight Barriers FSAR 2.2.2 Final Safety Analysis Report, Section 2.2.2, General Lake Hydrology SOP-3, CL 3.4 Standard Operating Procedure 3, Checklist Revision 47 3.4, Plant Flood Door System Checklist

Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0202352 Inspection Discrepancy Results for Expansion Joints XJ-0432 In MSM-M-16 Performed In June 1998 Condition Reports Reviewed to Assess Corrective Actions CPAL0100185 Back-up Specific Documentation Supporting Pump/Motor Operability to a Flood Level of 594' 8" Can Not Be Found CIED0201277 MNGP 3/15/02: Monticello NRC Flood Inspection Issues 1R11 Licensed Operator Requalification ONP-3 Off Normal Procedure - Loss of Main Revision 18 Feedwater EOP-1 Standard Post Trip Actions Revision 12 EOP-6 Excess Steam Demand Event Revision 13 LOR.SU.SEG Simulator Exercise Guide, Startup Training Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0202319 Missed Opportunities During Simulator Scenario 1R12 Maintenance Rule Implementation Control Room HVAC Maintenance Rule Scoping Revision 2 Document and Associated Maintenance Rule Performance Indicators Control Room HVAC System Health Assessments Component Cooling Water System Maintenance Revision 2 Rule Scoping Document and Associated Maintenance Rule Performance Indicators Component Cooling System Health Assessments - 1st/2nd Quarter 2001 480 Volt AC Maintenance Rule Scoping Revision 2 Document and Associated Maintenance Rule Performance Indicators 480 Volt AC Power System Health Assessments EM - 25 Maintenance Rule Program Revision 3

Condition Reports Reviewed to Assess Maintenance Rule Evaluations CPAL0101283 Unexpected EK-0239 Alarm, A CRHVAC RIA1818A Hi-Rad/Fail CPAL0101621 VDC-10 CRHAVC Condensing Unit Failed to Start CPAL0104212 Unusual Noise and Smoke Coming from VC-11, Control Room HVAC Condensing Unit CPAL0201122 Two Load Control Center 91 Breakers Were Sticking During Cycling for PPAC CPAL0103999 Motor Control Center 5 Feeder Breaker 52-1303 Failed Closing and Trip Operation Test CPAL0101346 X-Phase Failed to Connect During Breaker Swap CPAL0102271 Breaker 152-116 (CCW P-52C) Failed to Close CPAL0200014 CCW P-52C Breaker Tripped Open on Time Overcurrent CPAL0200526 CCW Pump P-52C Failed Tech Spec Surveillance CPAL0200527 Pieces of Hard Black Rubber Found Inside Pump Casing During Disassembly CPAL0200546 Valve Seat Material Found Loose in CCW System CPAL0200127 As Found Y Phase Time Overcurrent Relay for Breaker 152-116 Pump 52C HDO Setting Low Miscellaneous Documents EOP Supplement Emergency Operating Procedure - Align Revision 6 25 Feedwater Purity Building Air to Plant Instrument Air Header PPAC X-OPS392 Periodic and Predetermined Activity Control -

Cycle Breakers on Load Center 91 completed on August 6, 1999 and March 21, 2002 Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0202347 Incorrect Maintenance Rule Determination for Breaker 52-9107 Condition Documented on CPAL0201122 CPAL0202383 PPACS X-OPS392(LC-91) & X-OPS396(lC-90)

May Mask Breaker Functional Failures

1R13 Maintenance Risk Assessments and Emergent Work Evaluation Plant Procedures Admin. 4.02 Administrative Procedure 4.02 - Control of Revision 18 Equipment Other Documents Operators Risk Reports and Shift Supervisor Log Entries for April 1 through 5, 2002, During Maintenance Activities on High Pressure Safety Injection Pump P-66A and Service Water Pump P-7B Operators Risk Reports and Shift Supervisor Log Entries for April 15 through 19, 2002, During Emergent Maintenance Activities on Switchyard Breakers and Inclement Weather Operators Risk Reports, Shift Supervisor Log Entries, and Daily Work Schedules for May 6 Through 9, 2002, During Planned Maintenance Activities on Emergency Diesel Generator 1-1 with Ongoing Switchyard Work Operators Risk Reports, Shift Supervisor Log Entries, and Daily Work Schedules for June 10 Through 12, 2002, During Emergent Maintenance Activities for Loss of Switchyard R Bus and Emergent Cooling Tower Pump P-39B Trip.

Murray and Trettel Storm Warning Sheet April 17, 2002 Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0201511 Lack of Criteria Requiring Reevaluations of EOOS Risk Assessment for Severe Weather CPAL0201425 Switchyard Breaker ABB 29H9 Removed from Service Due to Current Transformer Oil Leak CPAL0201446 Work Week 2215, Emergency Diesel Generator 1-2 Outage Deferred Due to Degraded Switchyard Condition CPAL0201551 Inadequate Bus Voltage Margin to Remove Front Bus from Service 1R14 Non-Routine Plant Evolutions and Events

EOP Supplement Emergency Operating Procedure - Restoration of Revision 6 21 F or R Buses ONP-3 Off-Normal Procedure - Loss of Main Feedwater Revision 18 SOP-8 System Operating Procedure - Main Steam Revision 54 System SOP-30 System Operating Procedure - Station Power Revision 32 Troubleshooting Plans for the Loss of R Bus June 11, 2002 ONP-14 Off-Normal Procedure, Loss of Condenser Revision 10 Vacuum ONP -26 Off-Normal Procedure, Rapid Power Reduction Revision 1 ONP-1 Off-Normal Procedure, Loss of Load Revision 6 ONP-3 Off-Normal Procedure, Loss of Main Feedwater Revision 17 Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0202236 Loss of 'R' Bus Due to Y-Phase Fault CPAL0202238 Breaker 72-132 Trip CPAL0202250 Trip of Cooling Tower Pump P-39B at Full Power CPAL0202253 Unexpected Spike on P-50D Primary Coolant Pump LIA-0146B CPAL0202254 Spurious Rod Drop Alarms During Rapid Downpower Event CPAL0202280 Inadvertent Actuation of Under-Voltage Relay 227X-4 Causes P-39B Trip CPAL0202287 While Installing Start-Up Power Breaker (152-106) into 1C Bus Nicked HS-152-106RLTS CPAL0202288 Bent Retaining Ring Found on One of the Finger Assembly Clusters Associated with Circuit Breaker 152-202 (2400 Volt Bus 1D Startup Transformer Incoming Breaker).

CPAL0202320 Spurious Closures and Reopenings of CV-0540,

1. 2 Intercept Valve from Moisture Separator Reheater E-9A to A-Low Pressure Turbine CPAL0202321 Wiring to Solenoid Valve 0540, #2 Intercept Valve Found Swapped

1R15 Operability Evaluations CPAL0103481 Assumed Isolation Capability of Primary Coolant Pump Controlled Bleed-Off Header per Emergency Operating Procedures is Invalid CPAL0104082 High Pressure Safety Injection Pump P-66B Closing Coil Fuse/A113-2 Blew During Work Order Steps CPAL0102086 CV-0869 Containment Air Cooler Inlet Valve Will Not Isolate Flow CPAL0202278 Potentially Unacceptable Material Left in Conduit Associated with Fire Penetration FZ-0126 in the Cable Spreading Room Miscellaneous Documents EOP-3.0 Emergency Operating Procedure - Station Revision 9 Blackout Recovery Basis QO-19 Technical Specification Surveillance Test - Revision 22 Inservice Test Procedure - HPSI Pumps and ESS Check Valve Operability Test completed December 16, 2002 WO 24607385 Work Order - Troubleshoot/Identify All Wiring Within Breaker Cubicle 152-113 Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0201413 Condition Reports Not Generated as Required 1R16 Operator Workarounds PPAC X-OPS589 Assessment of Operator Workarounds March 27, 2002 PPAC X-OPS589 Assessment of Operator Workarounds April 29, 2002 PPAC X-OPS589 Assessment of Operator Workarounds February 27, 2002 Palisades Operator Challenges and Workarounds Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0201295 EARs Tracking Operator Workarounds and Challenges that Have Not Been Through the Work Review Group CPAL0202421 Vaguely Worded Accident Analysis Description in FSAR

Condition Reports Reviewed to Assess Corrective Actions CPAL0104051 Apparent Conflict Between Chapter 14 Loss of Feedwater Analysis and EOPs CPAL0101904 DEH Control System Presents Unnecessary Challenges to Operators 1R19 Post Maintenance Testing Plant Procedures SOP-30 System Operating Procedure - Station Power Revision 32 SPS-E-1 2400 Volt and 4160 Volt Allis Chalmers Circuit Revision 12 Breaker Auxiliary Switch Adjustments WI-SPS-E-02 Insulation Resistance Testing of Electrical Revision 1 Equipment SPS-E-4 Maintenance for 4160/2400 Volt Switchgear Revision 10 Work Orders WO 24113474 MV-ES3221, Dry Boric Acid at Packing, Clean/Adjust/Cycle WO 24111914 PM 152-112 Breaker (Feeds P-54B Motor)

WO 24211931 Region Repair Testing of Transformer EX-04 (Startup Transformer 1-2)

WO 24211977 Replace Bent Retainer Ring on Breaker 152-202, 2400Volt Bus 1D to Startup Transformer Incoming Breaker WO 24211932 Region Repair Testing of Transformer EX-05 (Startup Transformer 1-3)

WO 24211930 Region Repair Testing of Transformer EX-03 (Startup Transformer 1-1)

WO 24112919 Manual Valve MV-FP612 - Valve is Sticking in Mid-Position, Repair Valve WO 24112539 Manual Valve FP-531 is Leaking By, Repair/Replace Valve WO 24211745 Repack Diesel Driven Fire Water Pump P-41 WO 24211012 Fuel Oil Leaking from Fuel Pump on Diesel Driver K-10 for Fire Water Pump P-41 WO 24112712 D-26, Replace V-24A Back Draft Damper

WO 24112713 D-27, Replace V-24B Back Draft Damper WO 24113144 K-6A, Oil Supply to Top of Cylinder 9R Leaking WO 24114302 K-6A, Fuel Oil Pump, Cylinder 9L Leaks WO 24210117F K-6A, Remove and Replace Fuel Injector Pumps on Cylinder 1L WO 24210117B K-6A,Remove and Replace Fuel Injector Pumps on Cylinder 9R WO 24113585 ASM-1B, Air Start Motor Replacement PM WO 24210117H K-6A, Adjust Pump Timing On All 18 Cylinders Completed Post Maintenance Tests QO-16 Technical Specification Inservice Test Revision 20 Procedure, Containment Spray Pumps completed May 10, 2002 MO-7B Technical Specification Surveillance Test Revision 25 Procedure - Fire Water Pumps P-9A, P-9B, and P-41 completed June 12, 2002 MO-7A-1 Technical Specification Surveillance Test Revision 55 Procedure - Emergency Diesel Generator 1-1 completed on May 9, 2002 Condition Reports Reviewed to Assess Problem Identification Characterization and Corrective Actions CPAL0200014 Component Cooling Water Pump P-52C Breaker Tripped Open on Time Overcurrent CPAL0202218 Un-Annotated Sticky Note Attached to Tagging Order CPAL0201888 Error In Calculation Results in Rework During Performance of Procedure SPS-E-1 on Breaker 152-112 (Containment Spray Pump P-54B)

CPAL0201708 Inadequate Mechanical Maintenance Planning for 1-1 EDG - P-67B Outages CPAL0201830 K-6A, Cylinder 9L Banjo Joint To Fuel Oil Pump Leaked Extensively During Post Maintenance Testing of Diesel CPAL0201806 Unable to Perform Scheduled Work Due to Equipment Condition

1R22 Surveillance Testing Completed Technical Specification Surveillance Tests RT-71I Auxiliary Feedwater Class 2 and 3 System Revision 5 Functional/Inservice Test completed April 29, 2002 QO-1 Safety Injection System completed on May 24, Revision 47 2002 RO-128 Technical Specification Surveillance Test - Revision 5 Diesel Generator 1-2 24-Hour Load Run, Competed June 20, 2002 Miscellaneous Documents QO-1 Technical Specification Surveillance Test Basis Revision 3 Document - Safety Injection RO-128-2 Technical Specification Surveillance Test Basis Revision 2 Document - Diesel Generator 1-2 24-Hour Load Run Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0202444 Procedure Step Inadvertently Deleted from Surveillance Test Section 6.0 Acceptance Criteria CPAL0202382 Procedure Step References Wrong Time for RO-128-1&2 24-Hour Load Time CPAL0202394 Received Alarm EK-0557, Diesel Gen No. 1-2 Trouble Unexpectedly During RO-128-2 CPAL0202395 Received Alarm EK-0560, Diesel Gen Day Tank T-25B High/Low Level Unexpectedly During RO-128-2 CPAL0202396 Three Hours of 1-2 EDG Exhaust Temperature Logs Not Taken During RO-128-2 CPAL0202398 Digital Thermometer Model DT-300 Could Not Function in Diesel Generator Room 1-2 During RO-128-2 "Diesel Generator 1-2 24-Hour Load Run 1E06 Emergency Plan Drill Evaluation PRACTEX2002 Exercise Scope and Objectives for May 1 2002, and May 22, 2002

Emergency Notification Forms completed during drills on May 1 2002, and May 22, 2002 EI-1 Emergency Implementing Procedure 1, Revision 40 Emergency Classifications and Actions EI-6 Emergency Implementing Procedure 6, Offsite Revision 9 Dose Calculations and Recommendations for Protective Actions EI-3 Emergency Implementing Procedure 3, Revision 18 Communications and Notifications Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0201783 Information Missing from Revision 10 of Emergency Implementing Procedure EI-6.13, Protective Action Recommendations for Offsite Populations CPAL0201782 Failed Exercise Objective Regarding Protective Measures for Plant Personnel During PALEX2002 Drill CPAL0201781 Unclear Communications Regarding Evacuation of Personnel During PALEX2002 Drill CPAL0201780 During PALEX2002 Drill, Transfer of Command and Control Between the Site Emergency Director and the EOF Director Was Not Timely CPAL0201779 TSC Communication Equipment Problems During PALEX2002 Drill CPAL0201778 Discrepancy Between Utility Protective Action Recommendations and the State Protective Action Order During PALEX2002 Drill CPAL0201772 Scenario Did Not Include Guidance for Conclusion of Evacuation of Non-Essential Personnel CPAL0201771 PRACTEX2002 Drill Scenario and Scenario Control Did Not Provide Sufficient Data and Direction CPAL0201770 PRACTEX2002 Drill Scenario Radiation Data and Plant Process Computer Did Not Agree CPAL0201768 Notifications Were Not Made in 15-Minute Intervals to the State During the PRACTEX2002 Drill

CPAL0201767 Site Area Emergency Classification Notification Was Not Communicated to the State During the PRACTEX2002 Drill CPAL0201766 Classification for General Emergency Was Not Timely During the PRACTEX2002 Drill CPAL0201731 Site Siren Sound Fire Siren During Nuclear Drill CPAL0201793 Failed PRACTEX2002 Drill Objective 5c, Complete Site Accountability Within Approximately 30 Minutes of the Alert CAPL0201794 PRACTEX 2002, Service Building Lunchroom is Not Adequate to Establish an Operations Support Center 3PP3 Physical Protection Palisades Safeguards Event Logs October 2001 -

March 2002 STQP-1 Requirements for Weapon Qualification and Revision 19 Requalification Vital Target Success Path Security Reference Manual Table Top Exercise Evaluations (21) January-May 2002 Defensive Position Response Evaluation (64) January-May 2002 Tactical Movements and Weapon Use January-May 2002 Evaluation (45)

Condition Reports (Security Related) October 2001-May 2002 Security Personnel Training Files (11)

4OA2 Identification and Resolution of Problems Condition Reports Reviewed to Assess Corrective Actions CPAL0103678 SM&CS Laboratory Procedures Not Included in Administrative Procedure 10.41, Procedure Initiation and Revision, as Requiring Periodic Reviews Condition Reports Reviewed to Assess Problem Identification Characterization CPAL0201265 Inappropriate Result from the Analysis in Support of an Assigned Corrective Action

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