IR 05000255/2002002

IR 05000255/2002-002 on 02/10/2002 - 03/31/2002, Nuclear Management Company, LLC, Palisades Nuclear Generating Plant. Maintenance Rule, Identification and Resolution of Problems, and Event Follow-up

ML021080831
Person / Time
Site:	Palisades
Issue date:	04/18/2002
From:	Anton Vegel NRC/RGN-III
To:	Cooper D Nuclear Management Co
References
IR-02-002
Download: ML021080831 (45)

Text

ril 18, 2002

SUBJECT:

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

Dear Mr. Cooper:

On March 31, 2002, the NRC completed an inspection at your Palisades Nuclear Generating Plant. The enclosed report documents the inspection findings which were discussed on April 11, 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 inspector reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, we identified three 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/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Anton Vegel, Chief Branch 6 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

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

REGION III==

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

Licensee: Nuclear Management Company, LLC Facility: Palisades Nuclear Generating Plant Location: 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Dates: February 10 through March 31, 2002 Inspectors: J. Lennartz, Senior Resident Inspector R. Krsek, Resident Inspector H. Peterson, Senior Operations Engineer (Lead Inspector)

M. Morris, License Examiner H. Walker, Reactor Engineer Approved by: Anton Vegel, Chief Branch 6 Division of Reactor Projects

SUMMARY OF FINDINGS IR 05000255/02-02 on 02/10/2002 - 03/31/2002, Nuclear Management Company, LLC, Palisades Nuclear Generating Plant. Maintenance Rule, Identification and Resolution of Problems, and Event Follow-up.

This report covers a 6-week routine inspection, and a baseline licensed operator requalification inspection. The inspections were conducted by resident and specialist inspectors.

A. Inspector Identified Findings Cornerstone: Mitigating Systems C Green. The inspectors identified one Green finding that is being treated as a Non-Cited Violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions. Licensee personnel failed to promptly identify and correct repetitive failures of high pressure air system Check Valve CK-CA476, which had been occurring since the 1996 time frame. In addition, the most recent failure which occurred in April 2001, was a condition adverse to quality for which no apparent or root cause had been performed in accordance with the licensees corrective action program.

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 based on as-found check valve leakage; (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; (5) the finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event; and (6) while the finding could potentially be a design or qualification deficiency, the licensees operability determinations confirmed that the check valve leakage did not result in a loss of function per Generic Letter 91-18, Revision 1. (Section 1R12.1)

C Green. The inspectors identified one Green finding that is being treated as a Non-Cited Violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions. Licensee personnel failed to identify during an apparent cause evaluation completed on February 4, 2002, for Condition Report CPAL0200059, Fire Pump P-9A Tripped After Running For Approximately Three Minutes, that inadequate post maintenance testing activities were specified in a work order following electrical breaker maintenance for Fire Pump P-9A. Because the licensees apparent cause failed to identify the inadequate post maintenance testing, there were no corrective actions developed to ensure that appropriate post maintenance testing would be specified on subsequent work orders for electrical breaker maintenance similar to that conducted on Fire Pump P-9A.

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 in that two other fire pumps were always available; (3) fire protection pumps are not in the Technical Specifications, and therefore 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 in that two other fire pumps were always available; (5) the finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event in that the finding did not involve the loss of degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather initiating event; and (6) the finding did not involve the loss of a safety function that contributed to external event initiated core damage accident sequences from fires in that two fire pumps were always available. (Section 4OA2)

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 III, Design Control, for the failure to ensure that the measures for verifying and checking the adequacy of the design for Specification Change SC-94-130 assured that the applicable regulatory requirements and the design basis of the containment sump check valves were met.

This inspector identified finding was determined to be of very low safety significance (Green) by the significance determination process, because the finding was a design deficiency confirmed not to result in a loss of function per NRC Generic Letter 91-18, Revision 1. The licensees past operability analysis credited the use of containment overpressure and calculated plant parameters following a design basis accident and concluded that the available net positive suction head was above that required for all engineered safeguards system pumps considering the most limiting design basis accident conditions. Therefore, the engineered safeguards system pumps would have been able to perform the intended safety function and were operable, but nonconforming in accordance with Generic Letter 91-18, Revision 1. (Section 4OA3.1)

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 essentially at full power for the duration of the inspection period. Power was reduced and maintained at 99.5 percent to address issues with a relief valve on the balance of plant system (non-nuclear safety related system).

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 1R04 Equipment Alignment (71111.04)

.1 Quarterly Equipment Alignment Walkdowns a. Inspection Scope The inspectors performed partial walkdowns of the East Safeguards High Pressure Air System, and the High Pressure Safety Injection Pump P-66B. The inspectors performed the walkdowns to verify proper system lineup while redundant plant equipment was out of service. 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 selected condition reports that had been entered into the licensees corrective action program to verify that the corrective actions were reasonable and had been implemented as scheduled.

b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05Q)

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

• Control Room Complex (Fire Area 1); and

• Auxiliary Building 590-Foot Level Corridor (Fire Area 13).

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.

b. Findings No findings of significance were identified.

.2 (Closed) Temporary Instruction (TI) 2515/146: Hydrogen Storage Locations a. Inspection Scope The inspectors completed the inspection requirements of the TI to confirm that distances between any hydrogen storage capacity and ventilation intakes or risk significant tanks, systems, structures, or components were greater than 50 feet. The inspectors reviewed documents to verify that minor issues identified during the inspection were entered into the licensees corrective action system.

b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification (71111.11)

.1 Facility Operating History a. Inspection Scope The inspectors reviewed the plants operating history from January 2001 through January 2002, to assess whether the Licensed Operator Requalification Training (LORT) program had addressed operator performance deficiencies noted at the plant.

b. Findings No findings of significance were identified.

.2 Licensee Requalification Examinations a. Inspection Scope The inspectors performed a biennial inspection of the licensees LORT program. The inspectors reviewed the annual requalification operating and written examination material to evaluate general quality, construction, and difficulty level. The operating portion of the examination was inspected during February 25 - March 1, 2002. The operating

examination material consisted of two dynamic simulator scenarios and five job performance measures (JPMs). No written examination was administered during this annual requalification examination. However, the 2001 biennial written examination material and overall results were reviewed. The biennial written examination consisted of 30 open reference multiple choice questions. The inspectors reviewed the methodology for developing the examinations, including the LORT program two year sample plan, probabilistic risk assessment insights, previously identified operator performance deficiencies, and plant modifications. The inspectors assessed the level of examination material duplication during the current year annual examinations and with last years annual examinations. The inspectors also interviewed members of the licensees management, operations, and training staff and discussed various aspects of the examination development.

b. Findings No findings of significance were identified.

.3 Licensee Administration of Requalification Examinations a. Inspection Scope The inspectors observed the administration of the requalification operating test to assess the licensees effectiveness in conducting the test and to assess the facility evaluators ability to determine adequate performance using objective, measurable performance standards. The inspectors evaluated the performance of one staff crew and one operating shift crew during two dynamic simulator scenarios in parallel with the facility evaluators. In addition, the inspectors observed licensee evaluators administering five JPMs on a select number of operators. The inspectors observed the training staff personnel administering the operating test, including pre-examination briefings, observations of operator performance, individual and crew evaluations after dynamic scenarios, and techniques for JPM cuing. The final evaluation briefing for licensed operators was scheduled for the following week and was not observed. The inspectors noted the performance of the simulator to support the examinations. The inspectors also reviewed the licensees overall examination security program.

b. Findings No findings of significance were identified.

.4 Licensee Training Feedback System a. Inspection Scope The inspectors assessed the methods and effectiveness of the licensees processes for revising and maintaining its LORT program up to date, including the use of feedback from plant events and industry experience information. The inspectors interviewed licensee personnel (operators, instructors, training management, and operations management) and reviewed the applicable licensees procedures. In addition, the inspectors reviewed the licensees quality assurance/quality control oversight activities,

including licensees training and operations department self-assessment reports, to evaluate the licensees ability to assess the effectiveness of its LORT program and to implement appropriate corrective actions.

b. Findings No findings of significance were identified.

.5 Licensee Remedial Training Program a. Inspection Scope The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the previous annual requalification examinations and the training planned for the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations.

The inspectors reviewed remedial training procedures and individual remedial training plans, and interviewed licensee personnel (operators, instructors, and training management). In addition, the inspectors reviewed the licensees current examination cycle remediation packages for unsatisfactory operator performance on the written examination and operating test to ensure that remediation and subsequent re-evaluations were completed prior to returning individuals to licensed duties.

b. Findings No findings of significance were identified.

.6 Conformance with Operator License Conditions a. Inspection Scope The inspectors evaluated the facility and individual operator licensees' conformance with the requirements of 10 CFR Part 55. The inspectors reviewed the facility licensees program for maintaining active operator licenses and to assess compliance with 10 CFR 55.53(e) and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators and which control room positions were granted credit for maintaining active operator licenses. The inspectors also reviewed six licensed operators medical records maintained by the facility for ensuring the medical fitness of its licensed operators and to assess compliance with medical standards delineated in ANSI/ANS-3.4 and with 10 CFR 55.21 and 10 CFR 55.25. In addition, the inspectors reviewed the licensees LORT program to assess compliance with the requalification program requirements as described by 10 CFR 55.59(c).

b. Findings No findings of significance were identified.

.7 Quarterly Resident Inspector Licensed Operator Performance Observations a. Inspection Scope (71111.11Q)

The inspectors observed licensed operator performance during annual requalification examinations on in-plant job performance measures 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.

1R12 Maintenance Rule Implementation (71111.12Q)

.1 Inadequate Corrective Actions for Repetitive Failures of a High Pressure Air System Check Valve a. Inspection Scope The inspectors reviewed the licensees Maintenance Rule Scoping Document for the High Pressure Air System, which was designated as having high safety significance.

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 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 repetitive failures of High Pressure Air System Check Valve CK-CA476.

Check Valve CK-CA476, a Q safety system component, was located in a high pressure air line used to cross-connect the nonsafety-related turbine building high pressure air system with the safety-related high pressure air system in the East and West Engineered Safeguards Rooms. The safety function of Valve CK-CA476 was to close in the event

that the Turbine Building high pressure air system failed while cross-connected to the safety-related air system. The closed check valve would prevent air leakage to the failed Turbine Building system.

The Turbine Building high pressure air system was normally isolated from the safety-related high pressure air system in the East and West Engineered Safeguards Rooms with locked closed manual valves. The safety- and nonsafety-related portions of the high pressure air system were only cross-connected for short periods of time when the associated East or West Safeguards air compressors were taken out of service for maintenance.

The inspectors reviewed the corrective actions associated with Condition Report CPAL0101229, Check Valve CK-CA476 Soft Seat (O-Ring) Disengaged from Plug, and Piston Bore Found Unsatisfactorily. The inspectors noted that the significance level assigned to this condition report was a Level 4, which only required trending and if necessary, remedial action, with no apparent or root cause required.

The inspectors reviewed work order and condition report histories for this valve which revealed the following failure history associated with Check Valve CK-CA476:

C In December 1996, Condition Report CPAL9601793 was initiated and documented that Check Valve CK-CA476 failed the test acceptance criteria; C In May 1998, Condition Report CPAL9800785 was initiated and documented that Check Valve CK-CA476 failed the test acceptance criteria; C In October 1999, Condition Report CPAL9902216 was initiated and documented that Check Valve CK-CA476 failed the test acceptance criteria; C In November 1999, Condition Report CPAL9902778 was initiated and documented that when the Turbine Building and East Engineered Safeguards High Pressure Air Systems were cross-connected Check Valve CK-CA476 exhibited leakby; and C In April 2001, Condition Report CPAL0101229 was initiated and documented that the soft seat O-Ring of Check Valve CK-CA476 was found on the valve stem vice the soft seat thread.

The inspectors noted that while the valve failed the test acceptance criteria, the licensees operability determinations documented that the exhibited as-found leakage had not yet affected the overall operability of the high pressure air system. However, the inspectors noted that in the last condition report (CPAL0101229), neither an apparent nor root cause was performed to determine the nature of the repetitive failures. Without an apparent or root cause, the inspectors also could not determine if the active Engineering Assistance Requests would correct the repetitive nature of the check valve failures. The inspectors noted that all condition reports associated with Check Valve CK-CA476 were closed out in the corrective action system as 100-percent complete.

The inspectors determined that the failure to promptly identify and correct conditions adverse to quality regarding the repetitive failures of High Pressure Air System Check Valve CK-CA476 and had a credible impact on safety and was more than a minor concern. The inspectors determined that the failures could credibly affect the availability, reliability or function of a mitigating system, during periods of time when the engineered safeguards high pressure air system was cross-connected to the turbine building high pressure air system. The East and West Safeguards High Pressure Air Systems provide the safety-related motive force for the opening and closing of safety-related valves in the respective trains of the Emergency Core Cooling System.

The inspectors used Manual Chapter 0609, Significance Determination Process, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. The inspectors determined that:

C The finding did not represent an actual loss of safety function based on as-found check valve leakage; 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; C The finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event; and C While the finding could potentially be a design or qualification deficiency, the licensees operability determinations confirmed that the check valve leakage did not result in a loss of function per Generic Letter 91-18, Revision 1.

Therefore, the finding screened as Green and was of very low safety significance.

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 promptly identify and correct the repetitive failures of the high pressure air system Check Valve CK-CA476. 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 50-255/02-02-01)

This finding is in the licensees corrective action program as Condition Report CPAL0201343.

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

C Control Rod Drive System; and C 2400-Volt AC Power System.

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 the plant equipment necessary to minimize plant risk was operable and/or available as required. The inspectors randomly conducted plant tours to verify that the appropriate equipment was available for use during the following planned and emergent maintenance activities:

C Emergent failure of Component Cooling Water Pump P-52C Motor; and C Planned maintenance on High Pressure Safety Injection Pump P-66A.

The inspectors discussed the shutdown operation equipment checklists and plant configuration control for the maintenance activities with operations, maintenance and work control center staff to verify that necessary steps were taken to control the work activities.

In addition, the inspectors reviewed select condition reports to verify that identified 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.

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:

• Component Cooling Water System Debris; and

• Past Operability for the Containment Sump Recirculation Check Valves CK-ES3181 and CK-ES3166.

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.

1R17 Permanent Plant Modifications (71111.17)

a. Inspection Scope The inspectors reviewed the engineering analyses, modification documents and design change information associated with the following permanent modification to the Component Cooling Water System Technical Specification Bases:

• Technical Specification Bases Change for Technical Specification 3.7.7 which removed Component Cooling Water Pump P-52C from the Bases.

The inspectors discussed the modifications with the responsible engineers, licensing and operations staff. In addition, the inspectors reviewed the applicable sections of the Technical Specifications and Updated Final Safety Analysis Report to verify that the modifications would not adversely impact the systems safety functions.

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

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:

C High Pressure Safety Injection Pump P-66A; and C Control Room Heating and Ventilation System, Train A.

The inspectors reviewed post maintenance testing criteria specified in the applicable preventive and corrective work orders 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:

C Battery Charger No. 1; C Emergency Diesel Generator 1-2; C Safety Injection System Logic; C Reactor Protection System Trip Units; and C Component Cooling Water Flow Verification Test to the Emergency Core Cooling System.

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.

1R23 Temporary Plant Modifications a. Inspection Scope The inspectors reviewed the temporary modification package and associated 10 CFR 50.59 evaluation for the following temporary modification:

• TM 2001-014, "Due to damaged detectors, change locations of cabling at the reactor head for the incore detectors to provide the required 16 totally qualified detector installations. Also make corresponding changes to the addresses to provide proper signals to the PPC.

The licensee installed this temporary modification to relocate environmentally qualified cables to undamaged connections on the reactor vessel head.

In addition, the inspectors reviewed condition reports concerning this temporary modification to verify that identified problems were appropriately characterized and evaluated.

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 safety system functional failure performance indicator. 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 January through December 2001, to verify that the licensee had accurately reported the performance indicator for these quarters.

In addition, the inspectors discussed the data with the licensee staff responsible for gathering and reporting the information related to this performance indicator. Further, the inspectors reviewed condition reports regarding performance indicator data to verify that identified problems were appropriately characterized.

b. Findings No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Inadequate Corrective Actions for Post Maintenance Testing Activities a. Inspection Scope The inspectors reviewed the apparent cause evaluation for Condition Report CPAL0200059, Fire Pump P-9A Tripped After Running For Approximately Three Minutes, that was completed by licensee personnel on February 4, 2002. The apparent cause evaluation was selected for review because the Fire Protection System was designated as a high safety-significant system within the Palisades Systems Maintenance Rule Safety-Rankings. The inspectors reviewed the evaluation to determine if the identified causes for Fire Pump P-9A to trip after running for only three minutes were appropriate and to determine if the resultant corrective actions were reasonable.

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 post maintenance testing activities on Fire Pump P-9A.

Licensee personnel generated Condition Report CPAL0200059, Fire Pump P-9A Tripped After Running For Approximately Three Minutes, and entered the problem into the corrective action program. The events and circumstances pertaining to Fire Pump P-9A tripping after running for only 3 minutes were previously documented in Inspection Report 50-255/01-17(DRP), Section 1R19.

The apparent cause evaluation that licensee personnel completed for CPAL0200059 concluded that Fire Pump P-9A tripped after running for only 3 minutes because the long time trip relays on the associated electrical supply breaker were set improperly due to a lack of clarity on the retest record. Licensee personnel also concluded that maintenance technicians did not validate assumptions made during the maintenance activity and that the pre-job brief was ineffective.

The inspectors noted that the corrective actions appeared reasonable for the apparent causes that were identified by licensee personnel in their evaluation. However, the inspectors determined that the licensee failed to identify an apparent cause of inadequate post maintenance testing designated on the work order (WO2411415) that was utilized to set the long time overcurrent trips on the breaker.

The work order specified that post maintenance testing to be completed per Permanent Maintenance Procedure SPS-E-17, Temporary Installation and Removal of Spare Circuit Breakers. However, Procedure SPS-E-17 contained no post maintenance testing instructions. Instead, the work order should have specified post maintenance testing to be done in accordance with Administrative Procedure 5.19, Attachment 2, Guidelines for Post Maintenance Testing Electrical Maintenance.

The inspectors determined that the failure of licensee personnel to identify in their apparent cause evaluation that inadequate post maintenance testing activities were designated on WO2411415 was more than minor and had a credible impact on safety.

Because the licensees apparent cause failed to identify the inadequate post maintenance testing, there were no corrective actions developed to ensure that appropriate post maintenance testing activities would be specified on subsequent work orders for electrical breaker maintenance similar to that conducted on Fire Pump P-9A.

The inspectors used Manual Chapter 0609, Significance Determination Process, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, and concluded that this finding was of very low safety significance. The inspectors determined that the issue affected the mitigating system cornerstone in that the Fire Protection System was a backup for the Auxiliary Feedwater System. 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 in that two other fire pumps were always available; C Fire protection pumps are not in the Technical Specifications, and therefore 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 in that two other fire pumps were always available; C The finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event in that the finding did not involve the loss of degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather initiating event; and C The finding did not involve the loss of a safety function that contributed to external event initiated core damage accident sequences from fires in that two fire pumps were always available.

Therefore, the finding screened as Green and was of very low safety significance.

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 identify during an apparent cause evaluation completed on February 4, 2002, for Condition Report CPAL0200059, Fire Pump P-9A Tripped After Running For Approximately Three Minutes, that inadequate post maintenance testing activities were specified in WO2411415 following electrical breaker maintenance for Fire Pump P-9A. Because the licensees apparent cause failed to identify the inadequate post maintenance testing, there were no corrective actions developed to ensure that appropriate post maintenance testing activities would be specified on subsequent work orders for electrical breaker maintenance similar to that conducted on Fire Pump P-9A.

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 50-255/02-02-02)

This finding is in the licensees corrective action program as Condition Report CPAL0200622.

4OA3 Event Follow-up (71153)

.1 (Closed) Unresolved Item 50-255/01-14-01, Licensee Event Report 01-005-00 and Associated Licensee Event Report Retraction: Containment Sump Check Valves/

Reduced Available Net Positive Suction Head.

The inspectors identified a Green finding that is being treated as a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to ensure that the measures for verifying and checking the adequacy of the design for Specification Change SC-94-130 assured that the applicable regulatory requirements and the design basis of the containment sump check valves were met.

The licensee made Event Notification 38477 and Licensee Event Report 01-005-00 based on the preliminary analyses of test data for the Containment Sump Check Valves CK-ES3166 and CK-ES3181. The mock-up testing of a full scale containment sump check valve was conducted to address the licensees questioning of the ability of the containment sump check valves to go full open for the design basis accident, following a Recirculation Actuation Signal.

The testing performed discovered that the head loss through the containment sump check valves was greater than previously assumed; therefore, the increased head loss would have resulted in less than required available net positive suction head (NPSH) for the engineered safeguards system pumps during recirculation mode following a postulated loss of coolant accident. The licensees design basis accident analyses had previously assumed the containment sump recirculation check valves would have fully open (resulting in minimal head loss through the containment sump check valves) during recirculation mode following a design basis accident, based on original vendor documentation supplied for the check valves.

The testing performed was a result of a corrective action to address an issue identified in Condition Report CPAL0100764, Performance of Containment Sump Check Valves During Post-Design Basis Accident Recirculation Mode May Not Be Acceptable.

However, the licensees evaluation of the circumstances surrounding this issue revealed that concerns were raised regarding the potential for higher than assumed head loss values through the containment sump check valves as early as 1996.

Licensee personnels subsequent evaluation of past operability of the engineered safeguards system pumps concluded that the pumps were operable, but nonconforming in accordance with NRC Generic Letter 91-18, Revision 1. Licensee personnel reached this conclusion through engineering analysis and evaluations which credited containment pressure and calculated plant parameters following postulated design basis accident scenarios. The credit of containment overpressure increased the available NPSH to greater than the required NPSH for the engineered safeguards system pumps considering the most limiting postulated post-accident conditions and scenarios.

As follow-up to the circumstances surrounding this issue, the inspectors reviewed the past history of the containment sump check valves as well as the results of the testing of the containment sump check valve mock-up performed in October 2001. The inspectors also reviewed design modifications made to the containment sump check valves since original plant installation. The inspectors noted that Specification Change SC-94-130 was implemented in 1995 and added an external lever arm and stuffing box assembly to Check Valves CK-ES3166 and CK-ES3181 to allow the valves to be stroke tested per Section XI of the American Society of Mechanical Engineers (ASME) Code. The inspectors noted this design change did not consider the potential effects on the operation of the check valve with the addition of the external lever arm and stuffing box assembly.

The licensees mock-up test performed in October 2001 demonstrated that the operation of the check valve was significantly affected due to the addition of the stuffing box assembly and associated valve packing in 1995. The increased head loss through the containment sump check valves as a result of the 1995 design modification would have resulted in less than required available NPSH for the high pressure safety injection and the containment spray pumps during recirculation mode following a postulated design basis accident.

Therefore, the inspectors concluded that the licensees failure to ensure that measures for verifying and checking the adequacy of the design for Specification Change SC-94-130 to assure that the applicable regulatory requirements and the design basis of the containment sump check valves were met was a violation of 10 CFR 50, Appendix B, Criterion III, Design Control, and was more than minor. Specifically, the failure to meet the applicable regulatory requirements and the design basis of the containment sump check valves could have credibly affected the operability, reliability or function of the high pressure safety injection and containment spray mitigating systems.

The inspectors used Manual Chapter 0609, Significance Determination Process, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, and concluded that this finding was of very low safety significance. The inspectors determined that the finding was a design deficiency confirmed not to result in a

loss of function per NRC Generic Letter 91-18, Revision 1. The licensees past operability analysis credited the use of containment overpressure and calculated plant parameters following a design basis accident and concluded that the available NPSH was above that required for all pumps considering the most limiting postulated conditions.

Therefore, the engineered safeguards system pumps would have been able to perform the intended safety function and were operable, but nonconforming in accordance with Generic Letter 91-18, Revision 1.

The inspectors reviewed the licensees engineering analysis and evaluations for past operability to verify the adequacy of crediting containment overpressure and calculated plant parameters for this issue. In addition, the inspectors reviewed the licensees engineering analysis with NRC Regional personnel and the Office of Nuclear Reactor Regulation technical staff to verify the licensees utilization of containment overpressure and calculated plant parameters was appropriate. The inspectors concluded the licensees use of containment overpressure and calculated plant parameters was appropriate.

Therefore, the finding screened as Green and was of very low safety significance.

10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, measures shall provide for verifying and checking the adequacy of the design. Contrary to this, the licensee personnel failed to ensure that the measures for verifying and checking the adequacy of the design for Specification Change SC-94-130 assured that the applicable regulatory requirements and the design basis of the containment sump check valves were met. 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 III, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 50-255/02-02-03)

This finding is in the licensees corrective action program as Condition Reports CPAL0100764, and CPAL0103563.

The licensee completed corrective actions to address this condition prior to the startup of the plant from an extended outage in January 2002. The licensee modified plant equipment and procedures without further reliance on crediting containment overpressure, to ensure the Design Basis and Design Function of the Engineered Safeguards System were met in accordance with the facilitys license.

.2 (Closed) Escalated Enforcement Item 50-255/01-06-01: On June 27, 2001, the NRC issued a Notice of Violation and Imposed a Civil Penalty for the violation of 10 CFR 50.9, completeness and accuracy of information. The NRC issued the violation for the failure to provide complete and accurate information regarding the licensees submittals for a Notice of Enforcement Discretion and exigent Technical Specification Change Request which the NRC granted in February 2000 to remove an underground (backup) steam supply to Auxiliary Feedwater Pump P-8B.

The inspectors reviewed the licensees root cause and corrective actions for this violation to verify the following: 1) the root cause for this finding was identified; 2) the proposed corrective actions addressed the root cause and scope of problems identified by the

licensee during the review of this issue; and 3) corrective actions were implemented as scheduled. The inspectors identified that the actions taken and planned by the licensee addressed the root cause and causal factors of this issue.

In addition, the inspectors reviewed a random sample of seven licensee submittals made to the NRC from May 2001 through March 2002, and the inspectors verified that the licensees corrective actions addressed the issue of completeness and accuracy of licensee submittals to the NRC. The inspectors have no further concerns on this issue and considered this inspection follow-up item closed.

.3 (Closed) Inspection Follow-up Item 50-255/97201-22: Potential non-conservative compliance with Technical Specification Section 4.7.2c. During NRC Inspection 50-255/97201, the licensee performed an operability determination which concluded that the 4-hour station blackout battery load profile enveloped the 2-hour Design Basis Accident load profile. Licensee personnel completed a formal analysis of battery loading which considered the battery chargers in an alternate alignment, a combined event of LOCA/LOOP, and a single failure of AC power.

The inspectors reviewed the completed corrective actions for Condition Reports CPAL9701537, CPAL9701538, and CPAL9701582, as well as Action Item Record A-PAL-98-037, which documented the issue and the inspection follow-up item.

Engineering Analyses EA-ELEC-LDTAR-009 and EA-ELEC-VOLT-026, which also addressed and evaluated the issue, were also reviewed. Completed documentation for two station battery surveillance tests, Surveillance Procedure FE-5A, Revision 9 and Surveillance Procedure RE-83A, Revision 12, were reviewed to verify that the actions taken by the licensee were effective. The inspectors have no further concerns on this issue and considered this inspection follow-up item closed.

.4 (Closed) Licensee Event Report Supplement 01-004-01: The inspectors reviewed the licensees supplement to Licensee Event Report 01-004-01, Control Rod Drive Mechanism Upper Housing Assembly Crack Indications, dated March 14, 2002. The inspectors noted the supplemental report identified two additional licensee commitments and the inspectors did not identify any concerns with the accuracy or commitments contained in the submittal. The closure of the initial Licensee Event Report was documented in NRC Inspection Report 50-255/01-15 and supplemental response 01-004-01 is considered closed.

4OA4 Cross-Cutting Issues Corrective Actions While no new cross-cutting findings were identified during this inspection period, the inspectors identified examples of the continuing nature of the corrective action cross-cutting issue Finding FIN 50-255/01-17-05 documented in NRC Inspection Report 50-255/01-17, regarding the implementation of the licensees corrective action program.

In Sections 1R12.1 and 4OA2.1 of this report two Green findings (50-255/02-02-01 and 50-255/02-02-01) are documented for the failure to promptly identify and correct conditions adverse to quality which affected the Mitigating Systems Cornerstone.

In addition, NRC Inspection Report 50-255/01-15, issued March 4, 2002, documented a Green finding (50-255-01-15-02) for the failure to take corrective actions to prevent recurrence for a significant condition adverse to quality which affected the Barrier Integrity Cornerstone.

4OA6 Meeting Exit Meetings The inspectors presented the inspection results to M and other members of licensee management on April 11, 2002, after the inspection period ended. Licensee staff acknowledged the findings presented. No proprietary information was identified at the exit meeting.

Exit Meeting Senior Official at Exit: Douglas E. Cooper, Site Vice President Date: March 01, 2002 Proprietary (explain yes) No Subject: Results of an Inspection of the Licensees Licensed Operator Requalification Program Change to Inspection Findings: No

KEY POINTS OF CONTACT Licensee B. Benson, Unit Supervisor 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 G.W. Hettel, Manager, Maintenance and Construction L. Lahti, Licensing Manager D. G. Malone, Supervisor, Regulatory Assurance D. J. Malone, General Plant Manager G. Packard, Operations Superintendent K. Smith, Operations Manager Licensee G. Baustian, Operations Training Supervisor R. Bender, Operations Requal Training Supervisor L. Bogue, Director, Training D. Cooper, Site Vice President B. Dotson, Licensing Analyst D. G. Malone, Regulatory Compliance Supervisor P. Harden, Director, Engineering N. Haskell, Nuclear Oversight Manager L. Lahti, Licensing Manager M. Lake, Nuclear Control Operator C. Main, Shift Engineer/ STA D. Malone, Plant General Manager K. Marbaugh, Nuclear Oversight M. Menarick, Operations Training Coordinator G. Packard, Operations Superintendent P. Russell, Performance Improvement Manager W. Townes, Nuclear Control Operator J. Wicks, Shift Supervisor NRC J. Lennartz, Senior Resident Inspector, Palisades NRC D. Hood, Project Manager, NRR

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-255/02-02-01 NCV Green. 10 CFR 50, Appendix B, Criterion XVI. Licensee personnel failed to promptly identify and correct the repetitive failures of the high pressure air system Check Valve CK-CA476, which had been occurring since the 1996 time frame.

50-255/02-02-02 NCV Green. 10 CFR 50, Appendix B, Criterion XVI. Licensee personnel failed to identify during an apparent cause evaluation that inadequate post maintenance testing activities were designated for Fire Pump P-9A following electrical breaker maintenance. Consequently, no corrective actions were developed to correct the condition adverse to quality.

50-255/02-02-03 NCV Green. 10 CFR 50, Appendix B, Criterion III, Design Control.

Licensee failed to assure that measures for checking the adequacy of a design modification made to the containment sump recirculation check valves in 1995 ensured the overall design function of the valves was not affected.

50-255/01-004-01 LER Supplemental Response to Licensee Event Report (LER)

01-004-01, Control Rod Drive Mechanism Upper Housing Assembly Crack Indications 50-255/01-005-00 LER Containment Sump Check Valves/Reduced Available Net Positive Suction Head and Associated Licensee Event Report Cancellation Closed 50-255/02-02-01 NCV Green. 10 CFR 50, Appendix B, Criterion XVI. Licensee personnel failed to promptly identify and correct the repetitive failures of the high pressure air system Check Valve CK-CA476, which had been occurring since the 1996 time frame.

50-255/02-02-02 NCV Green. 10 CFR 50, Appendix B, Criterion XVI. Licensee personnel failed to identify during an apparent cause evaluation that inadequate post maintenance testing activities were designated for Fire Pump P-9A following electrical breaker maintenance. Consequently, no corrective actions were developed to correct the condition adverse to quality.

50-255/02-02-03 NCV Green. 10 CFR 50, Appendix B, Criterion III, Design Control.

Licensee failed to assure that measures for checking the adequacy of a design modification made to the containment sump recirculation check valves in 1995 ensured the overall design function of the valves was not affected.

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED (Cont.)

Closed (cont.)

50-255/01-14-01 URI Unresolved item to track and assess the completed test results from full scale testing of a containment sump check valve 50-255/97201-22 IFI Potential non-conservative compliance with Technical Specification Section 4.7.2c.

50-255/01-06-01 EEI Severity Level III Violation of 10 CFR 50.9 and associated Civil Penalty for the failure to provide complete and accurate information 50-255/01-004-01 LER Supplemental Response to Licensee Event Report (LER)

01-004-01, Control Rod Drive Mechanism Upper Housing Assembly Crack Indications 50-255/01-005-01 LER Containment Sump Check Valves/Reduced Available Net Positive Suction Head and Associated Licensee Event Report Cancellation LIST OF ACRONYMS USED ANS American National Standard ASME American Society of Mechanical Engineers CFR Code of Federal Regulations CR Condition Report DRS Division of Reactor Safety FSAR Final Safety Analysis Report JPM Job Performance Measure LORT Licensed Operator Requalification Training NCV Non-Cited Violation NPSH Net Positive Suction Head NRC Nuclear Regulatory Commission LIST OF DOCUMENTS REVIEWED 1R04 Equipment Alignment Plant Procedures SOP-3 System Operating Procedure - Safety Injection Revision 46 and Shutdown Cooling System

SOP-3 Attachment 17, Checklist 3.8 - Engineered Revision 46 Safeguards System Checklist (Heatup)

SOP-3 Attachment 18, Checklist 3.9 - Engineered Revision 46 Safeguards Administrative Control Verification SOP-20 System Operating Procedure - High Pressure Revision 19 Control Air System EOP Emergency Operating Procedure - High Revision 5 Supplement - 4 Pressure Safety Injection and Low Pressure Safety Injection Flow Curves Admin. 4.02 Administrative Procedure - Control of Equipment Revision 18 Miscellaneous Documents DBD-2.02 Design Basis Document - High Pressure Safety Revision 6 Injection System Final Safety Analysis Report, Section 6.1-Safety Revision 22 Injection System PPAC X-OPS-590 Predetermined and Periodic Activity Control -

Blowdown Low Points in High Pressure Air System, completed activities from July 2001 through February 2002 Condition Reports Reviewed To Assess Problem Identification Characterization CPAL0201121 High Pressure Air Dryer M-9A Humidity Sensor Found Isolated by NRC CPAL0201086 Valves Not Locked in Accordance with Administrative Procedure 4.02, More Than One Turn Possible 1R05 Fire Protection Plant Procedures ONP-12 Off-Normal Procedure - Acts Of Nature Revision 16 AP-6.02 Administrative Procedure - Control Of Equipment Revision 17 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 1, 13, and 23 Palisades Plant Analysis for Fire Areas 1, 13, and 23 Revision 4 Fire Hazards Analysis NFPA 50A National Fire Protection Association Standard 1969 and 1978 50A - Gaseous Hydrogen Systems of Consumer Standards Sites 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 TI 2515/146 U.S. NRC Temporary Instruction - Hydrogen December 14, 2001 Storage Locations 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 CPAL0200926 Incorrect Label on Turbine Building Exhaust Fan V-21R

CPAL0200606 Pressure Switch PS-1602A Sprinkler Header Air Pressure Switch to Volume Reduction System is Not Accurately Described in the AMMS Equipment Database CPAL0201015 Diesel Driven Fire Pump P-9B Packing Overheated During Performance of Technical Specification Surveillance Test MO-7B CPAL0201160 NRC Identified Diesel Generator Corridor Fire Door Frames Are Not in Compliance With Our 1978 Safety Evaluation Report Licensing Basis CPAL0200988 MO-7B - Fire Water Pump P-9B Test Failed Due to Overheated Pump Packing CPAL0201223 Attempt to Start Electric Fire Pump P-9A per SOP-21 Using T-handle was Unsuccessful CIED0201224 Temporary Instruction 2515/146: Hydrogen Storage Locations CPAL02001341 Condition Report 02-01160 Classified at a Lower Significance Level Than Appropriate 1R11 Licensed Operator Requalification Sections 1R11.1 through R11.6 LORT Plan Palisades Licensed Operator Requalification 2000-2002 (PLOR) 2 Year Training Plan Written Exam 2001 Licensed Operator Requalification Biennial June 24, 1905 Written Exam Operating Exam 2002 Two Simulator Scenarios; SPE-13, SPE-31 February 18, Simulator Scenarios 2002 Operating Exam 2002 Five JPMs; TBAM-16, TBAR-JP-04, TBAG- February 18, JPMs (Initial Set) 01, ASFA-01B, ASFE-04 2002 Operating Exam 2002 Five JPMs to Replace Initial Set; TBAM-04, February 21, JPMs (Replacement) TBAB-04, ASHH-01, ASDC-01, ASAC-01A 2002 Palisades Nuclear Licensed Operator Requalification Examination Revision 2 Training (PNT) Development and Administration Procedure No. 13.2 PNT-11.0 Plant Operations Training Program Guides Revision 1

PNT-12.0 Licensed Operator Examination Security Revision 1 PLOR 2000 Cycle Historical List of Training - 06/04/00 thru 12/13/01 Various Program Description Palisades Licensed Operator Requalification Revision 0 Training Program Description Admin Procedure Operations Organization, Responsibilities and Revision 23 No. 4.00 Conduct Admin Procedure Operator Training Revision 18 No. 4.05 Admin Procedure Plant Records Revision 14 No. 10.46 Admin Procedure Plant Training Organization and Responsibilities Revision 17 No. 11.00 Admin Procedure Systematic Approach To Training: Implementation Revision 3 No. 11.40 Admin Procedure Evaluation and Test Item Development Revision 0 No. 13.0 TRRCMS RPT -205 Attendance Records For 12 Classes (Randomly May 15, 2000 Selected) to February 26, 2002 Emergency Plan Emergency Classification and Action Revision 38 Implementing Procedure No. EI-1 Emergency Plan Communications and Notifications Revision 18 Implementing Procedure No. EI-3 Emergency Plan Offsite Dose Calculation - Straight Line Gaussian Revision 5 Implementing (Manual Method)

Procedure No. EI-6.10 Emergency Plan Protective Action Recommendations For Offsite Revision 10 Implementing Population Procedure No. EI-6.13

Cycle 2000F 2001 Annual Performance Exams June 24, 1905 Medical Records Selection of Six Licensed Operator Medical Various Records Medical Records Computer Print Out - Periodic Report on License Various Medical Data (Medical Exam Due Dates)

CPAL0001362 Condition Report Concerning One Operator Failed April 28, 2000 Annual JPM Examination CPAL0103093 Condition Report Concerning Learning Objectives September 26, 2001 CPAL0200850 Condition Report Concerning Emergency Action March 1, 2002 Level Classification CPAL0200790 Condition Report Concerning Exam Security February 26, 2002 CPAL0200828 Condition Report Concerning Canceled Afternoon February 28, JPMs 2002 CPAL0200852 Condition Report Concerning Enhancement to March 1, 2002 Exam Security Procedure CPAL0200853 Condition Report Concerning Enhancement to March 1, 2002 Training Remediation Procedure A-01-016 Nuclear Oversight Department Audit Report on November 1, Palisades Training and Staff Qualifications 2001 Various Matrix on Palisades Operations Training to Satisfy Various Risk Important Operator Actions 2002-001-8-002 Nuclear Oversight Observation Report - Reactor January 30, Startup and Generator Synchronization 2002 2001-004-8-032 Nuclear Oversight Observation Report - Licensed December 14, Operator Simulator Training for Plant Restart 2001 Preparations PNT 7.0, Attn 5A Current Year Simulator Scenario Crew and February 27, Individual Evaluation Reports - One Staff and One 2002 Shift Crews S-00-04 Audit/Surveillance Report on Operations Training March 20, 2000 Records to March 24, 2000 Training 2001-02 Palisades Operations Training Self-Assessment July 23, 2001 to July 27, 2001

Self-Assessment Palisades Nuclear Plant - Comprehensive Self- December 7, Evaluation for Select Training Programs 2000 to December 15, 2000 PNT 7.0, Attn 5 Simulator Scenario Crew and Individual Evaluation December 18, Report - Three Shift Crew Failure and Subsequent 2000 Remediation Evaluation February 15, 2001 March 8, 2001 SDR20-01-034 Palisades Simulator Deficiency Report March 2, 2001 TRRCMS SRN-1300 Various Computer Print Out for Group Attendance September 7, Course Completion and Review 2001 thru October 4, 2001 TRRCMS RPT-210 Computer Print Out - Requirements Completed January 1, Report for Emergency Plan - Dose Assessment 2000 thru Training February 26, 2002 Various Computer Print Outs on Task to Terminal and February 26, Enabling Objectives 2002 TBAH-SEG 1.01C Simulator Exercise Guide - Course Title: September 4, Continued Licensed Operator Training 2001 Various Staff Licensed Operations Proficiency Watch Four Qtrs 2000, Record Four Qtrs 2001, First Qtr 2002 1R11.7 Resident Inspector Quarterly Licensed Operator Requalification Plant Procedures ONP-25.2 Alternate Safe Shutdown Procedure Revision 17 SOP-2A Chemical and Volume Control System Revision 46 EOP Supplement Battery #1 Load Stripping Revision 5

Job Performance Measures TBAR-JP-04 Reduce Station Battery #1 Loading To Less Revision 1 Than or Equal To 150 AMPS

TBAM-16.JPM Re-energize Bus 13 Per The Alternate Safe Revision 1 Shutdown Procedure Miscellaneous Documents Operator Performance Evaluation Examination Results Condition Reports Reviewed To Assess Problem Identification Characterization CPAL0200976 Annual Examination In-plant JPM Invalidated Due To Cuing CPAL0201158 Re-Evaluation of Previously Taken JPM Results in Failure of that JAM CPAL0201414 Inappropriate Significance Level Assigned to Corrective Action Documents 1R12 Maintenance Rule Implementation Control Rod Drive System Maintenance Rule Scoping Document and associated Maintenance Revision 2 Rule Performance Indicators Control Rod Drive System Health Assessments -

1st/2nd Quarter 2001 High Pressure Air System Maintenance Rule Scoping Document and associated Maintenance Revision 2 Rule Performance Indicators 2400 Volt AC Maintenance Rule Scoping Revision 2 Document and associated Maintenance Rule Performance Indicators 2400 Volt AC Power System Health Assessments - 1st/2nd Quarter 2001 EM - 25 Maintenance Rule Program Revision 3 Condition Reports Reviewed To Assess Maintenance Rule Evaluations CPAL0101588 Water Inside Drive Motor of Control Rod Drive No. 35

CPAL0102186 Primary Coolant System Pressure Boundary Leakage, Control Rod Drive No. 21 Support Tube CPAL0104064 Control Rod Drive Mechanism Seal Housing Component Cooling Water Hose Condition May Not Support Operation Until 2003 ReFout CPAL0104204 Special Test T-370 Specifies Non-Conservative Shut-Down Margin CPAL0100934 System Operating Procedure - 20, Attachment 4 Not Updated to Reflect Change Made to Meet Appendix R Concerns CPAL0101229 Check Valve CK-CA476 Soft Seat (O-Ring)

Disengaged from Plug, Piston Bore Found Unsatisfactory CPAL0103600 Compressor C-6C High Pressure Air Compressor Oil Level Cutout Switch Unreliable CAPL0104195 Unable To Realign 2400 V Busses 1C and 1E to the Safeguards Transformer Condition Reports Reviewed To Assess Corrective Actions CPAL0103069 Bus 1D Voltage Below 2300 Volts For Four Minutes CPAL0102505 Inadequate Maintenance Rule Impact Determination For Degraded Grid Voltage CPAL0101065 Inadequate Labeling Inside Junction Box J9400 CPAL0101229 Check Valve CK-CA476 Soft Seat (O-Ring)

Disengaged from Plug, Piston Bore Found Unsatisfactory CPAL9902216 Check Valve CK-CA476 Failed to Meet Test T-278-9C Acceptance Criteria CPAL9902778 Re-work on Check Valve CK-CA476 CPAL9800785 Check Valve CK-CA476 Fails Leak Rate per Test T-278-9C CPAL9601793 Predetermined and Periodic Activity Control PPAC X-OPS432 Verification of Operability of Check Valve CK-CA476

Miscellaneous Documents WO24112495 Work Order - Test Jacks on Switch CC Should July 5, 2001 Be Numbered SOP-30, Section Standard Operating Procedure -30, Station Revision 31 4.2 Power, Voltage Requirements EAR 2001-0524 Engineering Assistance Request, Install Voltage October 18, 2001 Regulator ON Secondary Side of Startup Power Transformer 1-2 (EX-04)

EAR-2001-0371 Engineering Assistance Request - Install New Type of Check Valve at CK-CA476 EAR-99-0332 Engineering Assistance Request - CK-CA476 Failed During Test T-278-C, Install Filtration Upstream of Check Valve CK-CA476 EA-SC-87-273 Completed Engineering Analysis - Replace October 1987 Check Valve CK-CA476 in Response to D-PAL-87-087 WO 24614622 Completed Work Order - CK-CA476 Failed Leak December 15, 1996 Test, Repair as Necessary WO 24811410 Completed Work Order - CK-CA476 Failed Leak May 5, 1998 Rate per Test T-278-9C, CPAL9800785 WO 24913049 Completed Work Order - CK-CA476, Contingent November 2, 1999 Work Request. Replace soft seat in CK-CA476 Tested Unsatisfactory WO 24913581 Completed Work Order - CK-CA476, Check April 8, 2001 Valve Leaks By, Rebuild as Needed C-PAL-99-02778 Vendor File Vendor File - Henry Vogt Machine Co. Care and M0114 0062 Maintenance Bulletin for Forged Steel Gate, Globe, Angle and Check Valves Vendor File Vendor File - Henry Vogt Machine Co.

M0114 0038 Maintenance Instructions and Specifications for Zero Leakage Forged Steel Check Valves Condition Reports Reviewed To Assess Problem Identification Characterization CPAL0201343 Untimely Implementation of Actions to Repair High Pressure Air Check Valve (CK-CA476)

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 February 7 through February 12, 2002, during emergent maintenance activities on Component Cooling Water Pump P-52C Operators Risk Reports and Shift Supervisor Log Entries for March 18 through March 22, 2002, during scheduled maintenance activities on High Pressure Safety Injection Pump P-66A Condition Reports Reviewed To Assess Problem Identification Characterization CPAL0201127 QO-19 Inservice Test for High Pressure Safety Injection Pump P-66A Aborted Due to Packing Leak on MV-ES102 Pump P-66A Miniflow Bypass Valve CPAL0201123 LIC-1001 Primary System Drain Tank T-74 Level Controller Would Not Allow Draining of the Primary System Drain Tank T-74 Which Caused Deletion of Section 5.3 of QO-19, Inservice Test Procedure - High Pressure Safety Injection Pumps and Engineered Safeguards System Check Valve Operability Test CPAL0201455 Lack of Post Maintenance Test Following Hand Switch Cleaning Activities CPAL0201431 Inadequate Post Maintenance Test Requirements/Documentation on CRHVAC Work Orders 1R15 Operability Evaluations CPAL0200546 Operability Recommendation for Condition Report, Valve Seat Material Found Loose In Component Cooling Water System

CPAL0200702 Operability Recommendation for Condition Report, Attempts To Disassemble MV-CC923 Aborted; Restoration Identifies New Condition CPAL013563 Past Operability Recommendation for Condition Report, Containment Sump Check Valve Laboratory Testing Results are Inconsistent with Emergency Core Cooling System Model Miscellaneous Documents Correspondence to U.S. NRC from Nuclear March 4, 2002 Management Company, LLC, entitled, Cancellation of Licensee Event Report 01-005, containment Sump Check Valves / Reduced Available Net Positive Suction Head Reg. Guide 1.1 NRC Regulatory Guide 1.1, Net Positive Suction November 1970 Head for Emergency Core Cooling and Containment Heat Removal System Pumps Reg. Guide 1.82 NRC Regulatory Guide 1.82, Water Sources for May 1996 Long-Term Recirculation Cooling Following a Loss-of-Coolant Accident NUREG-0869, NRC NUREG, Regulatory Analysis for October 1985 Rev. 1 Unresolved Safety Issue (USI) A-43 -

Containment Emergency Sump Performance NUREG-0897, NRC NUREG, Containment Emergency Sump October 1985 Rev. 1 Performance - Technical Findings Related to Unresolved Safety Issue A-43" EA-C-PAL-01- Determination of the Head Loss Characteristics Revision 0 00764-02 of Containment Sump Check Valves CK-ES3166 and CK-ES3181 for the Period from June 1995 to December 2001 Licensee Developed Timeline Entitled, February 2002 Emergency Core Cooling System Net Positive Suction Head Issue Identification, Evaluation and Resolution Timeline Correspondence to U.S. NRC from Consumers Energy, entitled, Response to Generic Letter 97-04 - Assurance of Sufficient Net Positive Suction Head for Emergency Core Cooling and Containment Heat Removal Pumps Condition Reports Reviewed To Assess Problem Identification Characterization

CPAL0200527 Pieces of Hard Black Rubber Found Inside Pump Casing During Disassembly CPAL0200756 Potential Containment Spray Pump Component Cooling Water Flow Rate Anomalies Recorded During 2001 Performance of Special Test T-223 CPAL0200562 CCW Pump P-52C Inboard Pump Bearing Oil Getting Dark CPAL0201139 Engineering Analyses EA-GEJ-2002-01, Revision 0 Not Identified as Potentially Affected by Condition Report CPAL0201099 CPAL0201413 Condition Reports Not Generated as Expected 1R17 Permanent Plant Modifications B3.7.7 Technical Specification Bases - Component August 1, 2001 Cooling Water System FSAR Section 9.3 Component Cooling System Revision 23 DBD 1.01 Design Basis Document - Component Cooling March 17, 2001 Water System SOP-16 System Operating Procedure - 16 - Component Revision 22 Cooling Water System QO-15 Technical Specification Surveillance Procedure - Revision 16 Inservice Test Procedure - Component Cooling Water Pumps QO-15 Technical Specification Surveillance Procedure Revision 10 Basis Document - Inservice Test Procedure -

Component Cooling Water Pumps SDR-02-0110 Safety Determination Review - 10 CFR 50.59 February 9, 2002 Screen - Technical Specification Bases Change for B3.7.7 SER NRC Safety Evaluation Reports for Improved Technical Specification 3.7.7 - Component Cooling Water System

1R19 Post Maintenance Testing Completed Work Orders and Post Maintenance Tests 24113516 TD-1 and TD-4; Inspect and Lubricate March 6, 2002 24113337 V-26A Flow Control March 5, 2002 24210859 FSX-1711: Relay Contacts 1, 7 Are Not Closing March 5, 2002 24113336 Air Handling Unit V-95 Discharge Air Flow March 5, 2002 24112314 PO-1745, General Condition Check March 5, 2002 24113338 VC-11 Discharge Pressure Control March 5, 2002 24113339 HVAC Power Supply P/S-1655 Testing March 5, 2002 24113160 Air Handling Unit V-95 Modulating Damper D-2 March 6, 2002 24113283 Contact Cleaning For HS-1745A March 5, 2002 QO-19 Technical Specification Surveillance and Special Revision 22 Test Procedure - Inservice Test Procedure - High Pressure Safety Injection Pumps and Engineered Safeguards System Check Valve Operability Test, March 21, 2002 Condition Reports Reviewed To Assess Problem Identification Characterization CPAL0201127 QO-19 Inservice Test for High Pressure Safety Injection Pump P-66A Aborted Due to Packing Leak on MV-ES102 Pump P-66A Miniflow Bypass Valve CPAL0201123 LIC-1001 Primary System Drain Tank T-74 Level Controller Would Not Allow Draining of the Primary System Drain Tank T-74 Which Caused Deletion of Section 5.3 of QO-19, Inservice Test Procedure - High Pressure Safety Injection Pumps and Engineered Safeguards System Check Valve Operability Test 1R22 Surveillance Testing Completed Technical Specification Surveillance Tests QI-2 Technical Specification Surveillance Procedure - Revision 1 Reactor Protective Trip Units, March 4, 2002

RE-133 Technical Specification Surveillance Procedure - Revision 2 Performance Test - Battery Chargers, February 12, 2002 RE-132 Technical Specification Surveillance Procedure - Revision 2 Diesel Generator 1-2 Load Reject, February 20, 2002 QO-1 Technical Specification Surveillance Procedure - Revision 3 Safety Injection System, March 2, 2002 QO-16 Technical Specification Surveillance Procedure - Revision 19 Inservice Test Procedure - Containment Spray Pumps, March 12, 2002 Miscellaneous Documents QI-2/QI-2A Technical Specification Surveillance Procedure Revision 1 Basis Document RE-133 Technical Specification Surveillance Procedure Revision 0 Basis Document - Performance Test - Battery Chargers RE-132 Technical Specification Surveillance Procedure Revision 0 Basis Document - Diesel Generator 1-2 Load Reject QO-1 Technical Specification Surveillance Procedure Revision 47 Basis Document - Safety Injection System QO-16 Technical Specification Surveillance Procedure Revision 13 Basis Document - Inservice Test Procedure -

Containment Spray Pumps T-223 Completed Test Results from Special Test T-223

- Component Cooling Water Flow Balance from the 1999 and 2001 Tests Component Cooling Water Flow Data to Engineered Safeguards Pumps Taken During Normal Auxiliary Operator Rounds in March 2000 Condition Reports Reviewed To Assess Problem Identification Characterization CPAL0200883 RPS Inoperability Extended By Burnt Out Light Bulbs CPAL0200864 Unexpected Safety Injection Tank T-82D HI/LO Level Alarm During Safety Injection System Testing

CPAL0200865 DC Bus #2 Ground Discovered During QO-1 Safety Injection Test CPAL0200915 FA-0102D, Low Flow RPS Bistable Trip, Number One Matrix Light Burned Out CPAL0201038 Incorrect System Engineering Guidance Given for QO-16 Revision CPAL0201025 Component Cooling Water Flow Rates to Containment Spray Pump P-54C Below Expected Value CPAL0201026 Component Cooling Water Flow Rates to Containment Spray Pump P-54B Below Expected Value CPAL0201457 No Verification Performed of Critical Voltage Check During Technical Specification Test QI-2, Reactor Protective Trip Units CPAL0201458 Unexpected Delay Occurred During the Performance of Technical Specification Test QI-2, Reactor Protective Trip Units 1R23 Temporary Plant Modifications Admin. 9.03 Administrative Procedure - Temporary Revision 18 Modification Control Engineering Package for Temporary Modification January 4, 2002 No. TM-2001-026, including associated 10 CFR 50.59 Screening W.O. 24114288 Work Order - Installation of Temporary Modification No. TM-2001-026 4OA2 Identification and Resolution of Problems Condition Reports Reviewed To Assess Corrective Actions CPAL0200059 Fire Pump P-9A tripped after running for February 4, 2002 approximately three minutes apparent cause evaluation Condition Reports Reviewed To Assess Problem Identification Characterization CPAL0200622 Inadequate Post Maintenance Testing (PMT)

Specified In Work Order 24114415 (52-1305)

4OA3 Event Follow-up Admin. 3.21 Administrative Procedure - Validation of Revision 1 Correspondence to Regulatory Agencies and INPO Validation and Verification Package for May 25, 2001 Correspondence to U.S. NRC from Consumers Energy Corporation entitled, Supplementary Information Regarding Resolution of Unresolved Item 95004-05" Validation and Verification Package for June 19, 2001 Correspondence to U.S. NRC from Consumers Energy Corporation entitled, Licensee Event Report 01-003, Small Fire of Suspicious Origin Within the Plant Protected Area Validation and Verification Package for July 31, 2001 Correspondence to U.S. NRC from Nuclear Management Company, LLC, entitled, Plan for Implementation of Palisades Plant Emergency Minimum Staffing Changes Validation and Verification Package for August 31, 2001 Correspondence to U.S. NRC from Nuclear Management Company, LLC, entitled, Palisades Plant Response to NRC Bulletin 2001-01 Validation and Verification Package for October 1, 2001 Correspondence to U.S. NRC from Nuclear Management Company, LLC, entitled, Response to NRC Request for Additional Information Regarding Emergency Plan Staffing Changes Validation and Verification Package for January 15, 2002 Correspondence to U.S. NRC from Nuclear Management Company, LLC, entitled, SQUG Outlier Resolution - Revision of Commitment Correspondence to U.S. NRC from Nuclear March 29, 2002 Management Company, LLC, entitled, NRC Bulletin 2001-01:Circumferential Cracking of Reactor Pressure Vessel Head Penetration Nozzles - Updated Response Correspondence to U.S. NRC from Nuclear March 4, 2002 Management Company, LLC, entitled, Cancellation of Licensee Event Report 01-005, containment Sump Check Valves / Reduced Available Net Positive Suction Head

SC-94-130 Specification Change - Addition of Lever Arm and Stuffing Box Assembly to Containment Sump Check Valves CK-ES3166 and CK-ES3181 Reg. Guide 1.1 NRC Regulatory Guide 1.1, Net Positive Suction November 1970 Head for Emergency Core Cooling and Containment Heat Removal System Pumps Reg. Guide 1.82 NRC Regulatory Guide 1.82, Water Sources for May 1996 Long-Term Recirculation Cooling Following a Loss-of-Coolant Accident NUREG-0869, NRC NUREG, Regulatory Analysis for October 1985 Rev. 1 Unresolved Safety Issue (USI) A-43 -

Containment Emergency Sump Performance NUREG-0897, NRC NUREG, Containment Emergency Sump October 1985 Rev. 1 Performance - Technical Findings Related to Unresolved Safety Issue A-43" EA-C-PAL-01- Determination of the Head Loss Characteristics Revision 0 00764-02 of Containment Sump Check Valves CK-ES3166 and CK-ES3181 for the Period from June 1995 to December 2001 Licensee Developed Timeline Entitled, February 2002 Emergency Core Cooling System Net Positive Suction Head Issue Identification, Evaluation and Resolution Timeline Correspondence to U.S. NRC from Consumers Energy, entitled, Response to Generic Letter 97-04 - Assurance of Sufficient Net Positive Suction Head for Emergency Core Cooling and Containment Heat Removal Pumps Condition Reports Reviewed To Assess Problem Identification Characterization CPAL0200906 NRC Commitment Requiring a Modification has no Supporting Engineering Assistance Request

Condition Reports Reviewed To Assess Evaluations and Corrective Actions CPAL0100764 Performance of Containment Sump Check Valves During Post-Design Basis Accident Recirculation Mode May Not Be Acceptable CPAL0103563 Containment Sump Check Valve Lab Testing Results Are Inconsistent with Emergency Core Cooling System Model CPAL0100531 Appendix R Analyses Basis Does Not Adequately Document A Turbine Building Fire Safe Shutdown Path CPAL0100259 Removal of Auxiliary Feedwater Control Valve CV-0522A Supply to Pump P-8B Was Not Adequately Reviewed Against Appendix R Analyses CPAL0100797 Appendix R Program Deficiencies 42