ML18057A787
| ML18057A787 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/07/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A786 | List: |
| References | |
| 50-255-91-01, 50-255-91-1, NUDOCS 9103180049 | |
| Download: ML18057A787 (22) | |
See also: IR 05000255/1991001
Text
INITIAL SALP REPORT
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
Inspection Report No. 50-255/91001
Consumers Power Company
Palisades
September 1, 1989 through December 31, 1990
049 91fl307
CJ103180
. 05000255
ADOCK
Q
SALP 10
TABLE OF CONTENTS
Page No.
I.
INTRODUCTION ....................... *. . . . . . . . . . . . . . . . . . . .
1
II.
SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .
2
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2
III. PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3
A.
Pl ant Ope rat i ans ................................. .
B.
Radiological Controls ............................ .
C.
Maintenance/Surveillance ......................... .
D.
Emergency Preparedness ........................... .
E.
Security ......................................... .
F.
Engineering/Technical Support .................... .
G.
Safety Assessment/Quality Verification ........... .
3 - 5
5 - 8
8 -
10
10 - 11
12 - 13
13 - 16
16 - 18
IV.
SUPPORTING DATA AND SUMMARIES ..........................
18
A.
Licensee Activities .............................. .
B.
Inspection Activities ............................ .
C.
Escalated Enforcement Actions ..................... .
- D.
Confirmatory Action Letters (CALs) ................ .
E.
Licensee Event Reports ............................ .
18 - 19
19 - 20
20
20
20
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an integrated
NRC staff effort to collect available observations and.data on a periodic basis
and to evaluate licensee performance on the basis of this information.
The
program is supplemental to normal regulatory processes used to ensure compliance
with NRC rules and regulations. It is intended to be sufficiently diagnostic
to provide a rational basis for allocating NRC resources and to provide
meaningful feedback to the licensee
1 s management regarding the NRC 1 s assessment
of the facility 1s performance in each functional area.
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February 13 and 21, and on March 4, 1991, to review the observations and
data on performance, and to assess licensee performance in accordance with
the guidance in NRC Manual Chapter 0516,
11Systematic Assessment of Licensee
Performance.
11
This report is the NRC 1s assessment of the licensee 1 s safety performance at
Palisades for the period September 1, 1989, through December 31, 1990.
The SALP Board for Palisades was composed of the following individuals:
Board Chairman
T. 0. Martin, Director, Division of Reactor Safety
Board Members
H. J. Miller, Director, Division of Reactor Projects
W. L. Axelson, Deputy Director, Division of Radiation Safety and
Safeguards
L. B. Marsh, Director, Project Directorate III-1
H. B. Clayton, Chief, Projects Branch 2
B. E. Holian, Licensing Project Manager
J. K. Heller, Senior Resident Inspector
Other Attendees at the SALP Board Meeting
A. B. Davis, Regional Administrator
W. G. Snell, Chief, Radiological Controls and Emergency Preparedness
Section
D. H. *Danielson, Chief, Materials and Processes Section
B. L. Jorgensen, Chief, Projects Section 2A
E. R. Schweibinz, Senior Project Engineer
C. F. Gill, Senior Reactor Programs Specialist
J. A. Gavula, Reactor Inspector
J. R. Kniceley, Security Specialist
A. W. Markley, Radiation Protection Specialist
D. M. Barss, Emergency Planning Specialist
T. J. Kozak, Radiation Specialist
R. L. Bywater, Jr., Reactor Engineer
II.
SUMMARY OF RESULTS
Overview
The liceniee 1 s overall performance level during this assessment period was
acceptable in all areas.
The degree of management attention and effectiveness
ranged from commendable in some areas to needing attention in others. Overall,
the conduct of activities was appropriately directed to assurance of safety.
Management appeared proactive and effective in demonstrating a conservative
operat~ng phil~sophy an~ esta~~~shing hi~h standards ~f ~erforman~e in
opera"t;1ons, ma1n"t;enam:;e1surve111anc;e, anu sec;ur1"t;y.
r-er1un11a11c;e 11111.a*uveu i;.u
C1
Category 1 level in the former two areas. While some significant problems were
identified by the licensee with its fitness-for-duty program, performance in
the security area was strong enough overall to maintain a Category 1 rating.
Declining performance was noted in areas of emergency preparedness and
engineering/technical support.
Emergency preparedness was downgraded from
a Category 1 to a Category 2 with a declining trend.
Significant among the
weaknesses identified in this area was the failure of the licensee to ensure
that trained individuals were available to fill critical emergency preparedness
positions.
Engineering/technical support was rated a Category 2 as it was last
assessment period but with a declining trend. Significant weaknesses were
noted in design control and technical oversight of contractors.
Some strengths
were noted in engineering activities in support of maintenance.
However,
increased management attention is suggested in the engineering/technical
support functional area, especially since design control problems were identified
in the last assessment period and licensee actions to address these were not
fully effective.
Strong involvement in radiation protection for the steam generator replacement
project was observed.
It is suggested that lessons learned from the replacement
project be reviewed for incorporation in the routine radiation protection
program.
Material and personnel resources were generally adequate in all areas.
The performance ratings during the previous assessment period and
this assessment period according to functional areas are given below:
Functional Area
Plant Operations
Radiological Controls
Maintenance/Surveillance
Security
Engineering/Technical Support
Safety Assessment/Quality
Verification
Rating Last
Period
2 Improving
2
2 Improving
1
1
2
2
2
Rating This
- Period
1
2
1
2 Declining
1
2 Declining
2
III. PERFORMANCE ANALYSIS
A.
Operations
1.
Ana,Ysis
Evaluation of this functional area was primarily based on the results of 11
routine inspections by the resident inspector. A total of 1,323 inspection
hours were expended in this functional area, comprising 20.4 percent of the
total inspection hours.
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high standard established during the previous assessment period.
Inspectors
identified one Severity Level V violation for failure to maintain control of
flammable liquids. Its safety significance was minor, it did not indicate a
programmatic breakdown, and no similar violation was identified during the
previous assessment period.
Several licensee event reports (LERs) issued during this assessment period were
applicable to this functional area. A few LERs were attributed to various
personnel errors, but the effect of these errors on safety was minimal.
The
other LERs documented power reactor trips. One was a manual trip following a
main feedwater pump trip and the other was a variable high power trip during a
transient initiated by a main feedwater pump trip.
The operators' response to the two reactor trips and to the significant
depressurization event demonstrated their ability to respond to.plant transients.
Operators manually initiated the first trip (a conservative action) after the
operating main feedwater pump tripped.
For the second trip, the operators
properly responded to the initiating event (loss of a main feedwater pump) by
rapidly reducing plant power to a level at which sufficient steam generator
feedwater could be supplied by the operating pump.
Following the power
reduction, the increase of feedwater resulted in a power rebound to a variable
power trip setting.
The operators could have manually reset the trip setting,
but appropriately chose not to, because conditions were_still transient.
Because of preparations to replace the steam generators and the beginning of
the replacement outage, the unit was cycled for three preplanned outages.
Each of these shutdowns and startups was performed without incident.
Handling
the heatups and cooldowns also demonstrated evidence of consis~ent planning and
assignment of priorities. The department's procedures for conduct of activities
were well stated, controlled, and explicit.
In addition to the two reactor
trips previously discussed, other transients included the failure of a.
pressurizer heater transformer that de-energized half of the pressurizer
heaters, a trip of all cooling tower fans, an actuation of a main steam
atmospheric relief valve, and a number of minor transients.
Loss of the
pressurizer heater transformer placed the plant in a limiting condition for
operation (LCO) that required a shutdown.
The licensee's conservative operating
policy resulted in a controlled shutdown well within the LCO time limit.
Appropriate planning of the repairs revealed that they could not be completed
without exceeding the LCO time limit for cold shutdown.
This planning was
instrumental in establishing early communication with the NRC to permit use of
the temporary waiver of compliance policy and prevented an unnecessary
3
temperature transient on the plant.
Proper onshift response to the cooling
tower transient resulted in a controlled power reduction and reestablishing
cooling tower operation before a plant trip occurred.
During past assessment
periods, a cooling tower trip resulted in a reactor trip. Actuation of a main
steam atmospheric relief valve had been an occasional problem under certain
plant conditions during a startup.
During this period, a startup was halted to
permit trouble shooting and root-cause analysis.
Management involvement and control of quality consistent.ly demonstrated a
conservative and safety-oriented operating philosophy as noted in the previous
examples.
Licensee control during plant manipulations was routinely demonstrated
wit.ii usua11y exce11ent, result.s.
1ne t'1ant. iyianay~r duu uµ~rdl;,iuu~ i*idudy~r
routinely visited the control room during normal and off-normal plant operation.
In addition, the Operations Superintendent relocated his office to the control
room complex and was routinely observed in the control room during all phases
of plant operation.
Operations management i nvo*l vement and control in ensuring quality were
acceptable, as shown by the active role that was taken during administration of
requalification examinations.
Operations management personnel, who were part
of the examination team, provided valuable technical expertise and clear
expectations for operator performance.
Corporate managers routinely visited the site to provide direct assessment of
control room and plant activities.
The Vice Presidents (Nuclear and Special
Projects) both performed weekly plant tours.
The Chief Executive Officer and
Senior Vice President conducted tours of the site at least quarterly.
Licensee
managers (both plant and corporate) kept cognizant of plant parameters by
attending daily meetings (morning and afternoon), directly observing activities,
- and reviewing daily plant reports and monthly trend graphs.
The licensee's approach to resolving potential safety issues was routinely
demonstrated by the gains made in plant material condition. Painting and floor
recoating projects were nearly complete.
The coating improved postmaintenance
cleanup activities and decontamination efforts.
However, one drawback to the
coating is that the color and gloss have a tendency to hide potentially
contaminated wet spots.
During the previous assessment period, inspectors
noted a weakness involving containment cleanliness following outages.
The
licensee established a chain of responsibility for cleanup and postoutage
inspection.
These actions resulted in continuing improvement in the postoutage
cleanliness of the containment.
The fire protection program was challenged at the start of the steam generator
replacement outage.
Several minor fires occurred early in the outage due to
improper control of work.
The licensee recognized that these fires could be a
precursor to more serious fires because of the scope of the outage and the size
of the contractor work force.
Measures implemented were re-education of work
force, re-evaluation of procedures, use of stop work orders, and assignment of
fire protection specialists to provide 24-hour coverage.
The Operations Department had a strong program for tracking and analyzing
various plant parameters for determining trends and for implementing early
corrective action.
For example, trends for safety injection tank levels
4
revealed the need for corrective maintenance and the need to increase the
sampling frequency to prevent a tank being rendered inoperable as a result of
its low concentration or level. Another example involved leakage of chargi~g
pump seals and the ability to predict degraded seals.
Thus, repairs for these
seals were scheduled on a preventive basis, versus waiting until the seal
failed.
The staffing and experience levels of the operations department personnel
exceeded Technical Specification requirements.
A 5-shift rotation was utilized
that allowed for proper support of the operator requalification training
program without excessive overtime.
The remote location of the simulator was discussed during the last assessment
period.
At that time, the licensee acknowledged the NRC observations and
stated that the simulator would be moved to the Palisades site after to the
steam generator replacement outage;
The building that will house the simulator
has been built, and the move is expected to occur during the next SALP assessment
period.
2.
Performance Rating.
The licensee's performance is rated Category 1 in this area.
The licensee's
performance was rated Category 2 and improving during the previous two
assessment periods.
3.
Recommendations
None.
8.
- Radiol6gical Controls
1.
Analysis
Evaluation of this functional area was based on the results of seven inspections
performed by region-based inspectors and observations made by resident
inspectors.
A total of 843 inspection hours were expended in this functional
area, comprising 13 percent of the total inspection hours.
Enforcement-related performan4e in this functional area was adequate; two
violations were identified.
An enforcement conference was held to discuss
access controls for high-radiation areas and record falsifications in the
general employee training and chemistry quality control programs.
This
enforcement conference resulted in one Severity Level IV violation for the
willful violation of access-control requirements for high-radiation areas. A
second Severity Level IV violation of high radiation area access control
requirements was also identified during this assessment period.
Although no
violations associated with the record falsification issues were cited - in
part, because they were licensee identified - they represented a concern
because the NRC must be able to reasonably rely on the integrity of licensee
personnel.
5
Staffing levels and qualifications were adequate to implement the radiation
protection, radwaste, chemistry,*and radiological environmental monitoring
programs.
Replacement of the Radiological Services Manager during this
assessment period did not have a discernable effect on .program implementation
or performance.
Laboratory supervisors appointed during this assessment period
were knowledgeable and committed to implementing needed improvements in the
quality assurance and quality control (QA/QC) program.
The licensee contracted
additional management and technical staff to handle the demands of the steam
generator replacement project (SGRP).
The licensee developed a parallel
radiation protection organization with distinct responsibilities and established
lines of authority for the SGRP.
The licensee employed a consultant to promote
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org*nizations. This effort was successful in promoting effective communications
between the two organizations.
The effectiveness of training and qualification programs was adequate.
In
general, the licensee's staff was adequately trained and qualified to perform
assigned duties.
Proficiency and continuity continued to improve.
However,
as-low-as-is-reasonably-achievable (ALARA) concepts were not fully incorporated
into the training program, including lesson plans and procedures for general
workers and radiological safety technicians.
The licensee's radiation protection
(RP) and ALARA supervisors and professional staff maintained proficiency by
attending numerous professional workshops and seminars.
The licensee's
ut1lization of mock-up training for major SGRP activities was excellent.
Management's involvement and control in ensuring quality was inconsistent
during this assessment period, particularly in the area of ALARA.
considerations for non-SGRP activities were not well integrated into work
planning. Administrative controls in the ALARA area were weak and indicative
of a lack of a firm ALARA commitment.
With some exceptions, an attitude
existed that ALARA activities and concerns were solely the responsibility of
the Radiological Services Department.
In contrast, management support was very
good for ALARA initiatives for the SGRP activities.
The radiation source term *
reduction program also received inconsistent management support.
Positive
aspects of the program included implementation of a hot-spot reduction program
and a coordinated lithium-boron chemistry pH control system.
Also, the licensee
implemented primary coolant system hydrogen peroxide additions to reduce
incore and some excore cobalt-58 and cobalt-60 levels.
However, little progress
was made in reducing the incore and excore inventory of high cobalt-bearing
materials.
Management support for chemistry QA/QC and water quality programs
remained generally strong; although, the licensee was somewhat slow to implement
the QA/QC program.
This was evidenced by the continuing poor performance in
the nonradiological confirmatory measurements program.
The licensee took
corrective actions to improve technicians performance (following the data
falsification incident) and installed a reverse osmosis system for purification
of steam generator makeup water. Additionally, the licensee's water quality
program was consistent with industry guidelines.
One significant management initiative was an extensive self-assessment review
of the radiation protection program, including ALARA implementation.
Near the
end of this assessment period, the licensee drafted a series ~f action plans to
resolve issues identified by the self-assessment.
6
The licensee's approach to identifying and resolving technical issues from a
safety standpoint was also inconsistent.
Inspectors noted good performance in
the resolution of issues fdentified regarding the Safety Injection and Refueling
Water (SIRW) tank.
Other good practices or initiatives included the
implementation of electronic dosimetry, creative uses of video and communication
equipment, bilingual radiological postings, shielding, and pipe-end
decontamination.
However, the licensee experienced recurrent problems with
access control to high-radiation areas.
The work practices of workers and some
radiological safety technicians for contamination control were poor during the
early stages of the SGRP.
Inspectors also noted that an unusually high number
~f con~amination event~ oc~~rred_in area~ ~ot d~siQna~ed a~ bein~ contamina~ed.
~on~am1na~1on even~s s1gn1r1can~1y exceeaea goa1s aur1ng ~ne ear1y s~ages or
the SGRP; however, the licensee was able to reduce the rate of contaminations
as the outage progressed.
The licensee continued to reduce its gaseous radwaste
effluents.
Liquid radwaste effluents remained well within Technical Specification
limits.
By recognizing that lack of progress on an in-state radwaste disposal
site could affect station operations, the licensee proceeded to minimize the
solid radwaste stored at the site.
No radwaste transportation incidents were
identified.
The licensee's ALARA program was significantly challenged during this assessment
period.
In addition to the maintenance outages during the fall of 1989 and
spring of 1990, the licensee performed an SGRP as well as a routine refueling
outage from September through the end of this assessment period.
The licensee
emphasized the regulatory and exposure performance responsibilities of the
contractor with a system of fee programs and financial incentives.
The 1989
radiation dose total was approximately 314 person-rem.
The estimated 1990
radiation dose total for plant activities, excluding SGRP, was approximately
337 person-rem.
This total for the plant represented adequa~e performance.
The 1990 radiation dose total for the SGRP was approximately 397 person-rem.
This included the major portion of the SGRP, and projected dose totals reflected
good planning and performance.
The licensee's ALARA performance compared
favorable with previous industry SGRP projects. Although the licensee's ALARA
performance for non-SGRP activities improved somewhat during this assessment
period, greater management support for SGRP ALARA initiatives resulted in a
better dose reduction program for SGRP activities than for non-SGRP activities.
Performance in the nonradiological confirmatory measurements program was poor,
achieving 19 agreements out of 30 comparisons initially.
Following instrument
recalibration, the licensee achieved 28 agreements out of 30 comparisons.
The
licensee maintained trend charts for water chemistry parameters.
These
parameters were generally below action levels and were reviewed by laboratory
management daily.
Overall water quality was good.
The chemistry
self-assessment program continued on schedule.
Deficiencies occurred in the
conduct of the Radiological Environmental Monitoring Program.
Flow meters for
two air samplers were operated after their calibration period expired, and air
in-leakage was evident in many of the air samplers.
2.
Performance Rating
The licensee's performance is rated Category 2 in this area.
The licensee's
performance was rated Category 2 in the previous assessment period.
7
3.
Recommendations
None.
C.
Maintenance/Surveillance
1.
Analysis
Evaluation ot this tunct1ona1 area was based on ~he resu1~s u1 ii ruu~1r1~
inspections, 1 special inspection performed by the resident inspectors and
3 routine inspections by regional inspectors. A total of 1,588 inspection
hours were expended in this functional area, comprising 24.5 percent of the
total inspection hours.
Two Severity Level IV violations and one deviation were issued during this
assessment period.
Five Severity Level IV violations were issued during the
previous assessment period.
The two level IV violations were identified at the
beginning of the assessment period and pertained to improper maintenance and
surveillance of a containment penetration and associated piping.
Post-discovery
surveillance activities mitigated the safety signfficance.
However, the
violations did indicate that the plant maintenance staff and engineers were not
appropriately aware of containment integrity requirements and that biennial
review of these procedures did not identify this problem.
Two violations
relating to containment testing occurred during the previous assessment period.
Violations involving failure to follow procedures were noted during the previous
assessment period, but none were identified during the current period.
The
deviation was for failure to implement commitments from a previous violation
and perform additional verification of cold leg tube plugging patterns in the
Several LERs issued during this assessment period were applicable to this
functional area, but the number decreased (approximately half) from the number
issued last period, including the occurrence of personnel errors which caused
reportable events.
None of the LERs had major safety significance.
One
pertained to the violations discussed in the previous paragraph, one pertained
to a personnel error that caused an inadvertent actuation of auxiliary feedwater,
and one pertained to a maintenance activity where the inoperability of boric
acid heat tracing was not communicated to the operations department to permit
proper classification of a Technical Specification time limit.
The remaining
few were less important, were not repetitive, and lacked generic or programmatic
implications.
The licensee continued to manage and successfully implement the Technical
Specification surveillance program with surveillances routinely completed on
time.
The extension of surveillance intervals and permitting use of the "grace
periods" was controlled and documented by the appropriate level of management.
The surveillance procedures were controlled, revised, and maintained by the
engineering, maintenance, or operations group responsible for and most
knowledgeable about the equipment.
This good practice allowed the surveillance
procedures to not only check parameters stated in the Technical Specification
but provide a tool for developing equipment trends and evaluations to determine
long-range maintenance and modification needs.
For example, when an inspector
8
questioned the operability of the air start system for the diesel generator,
the system engineer produced graphs indicating that starting times were slowly
increasing and stated that additional preventive actions were being planned.
The administrative policies for preparing new surveillance procedures were
well stated, disseminated, and apparently understood.
These policies produced
surveillance procedures that were consistent in format, structure, and content
and that had a supporting basis document to explain the assumptions, define the
calculations, and justify the acceptance criteria.
Procedures were routinely
in evidence at the job site. Unexpected equipment responses were immediately
brought to the appropriate level of management and resolved using the corrective
action program.
The only negative observation in this regard concerned the
-
-
-
v101a~1on re1a~1ng ~o con~ainmen~ pene~ra~ion ~es~ing.
Management involvement in ensuring quality remained strong. Efficient use of
planners permitted effective planning of work activities, proper scheduling,
prestaging of parts, and routine visits to the job site by supervisors.
The
licensee used a computerized work order system that permitted easy access to
work order history.
Workers demonstrated the value of detailed work order
summaries by using previous work order summaries at the job site as an aide in
both pre-job briefings and preparing work orders.
This represented improving
performance compared to the previous assessment period. Outages performed
during this assessment were well planned.
During the outages the licensee
utilized onsite Shift Managers.
This was a round-the-clock position staffed by
senior managers or senior plant engineers.
The Shift Manager ensured that
proper attention was directed to the outage work path and that emergent work
was properly evaluated and categorized.
One example of positive management
control was the use of a multi-disciplinary organization, which had a defined.
charter and contingency plans to resolve the injection valves flow path problem
in the hot leg.
Plant management's approach to identifying and resolving technical issues
remained *good.
Both the system engineer and the first line supervisor closely
followed maintenance activities and informed upper management of work progress
on a daily basis.
During these daily meetings, the staff identified any
problems encountered, including unexpected equipment conditions, parts or
personnel shortages, coordination issues, etc. These were usually promptly
evaluated and effectively resolved as previously discussed. However, a defective
component in the boric acid heat tracing system was not promptly evaluated for
compliance with Technical Specification time limits.
The work order backlog, corrective work orders, and preventive maintenance
program were routinely evaluated and adequately controlled.
Preventive
maintenance work orders were normally implemented as scheduled, rarely
deferred or missed.
The licensee established a rework maintenance policy that:
(1) defined 11 repeat 11 maintenance, (2) established a mechanism for identifying
11 repeat 11 maintenance, and (3) established a board of managers and superintendents
to evaluate corrective action for
11repeat
11 maintenance.
Rework did not appear
to be an issue or a problem.
The plant's computerized work order program and
database were very useful for ascertaining equipment history.
The quality of
work performed by the maintenance department was good_, and was confirmed by
challenging post-maintenance testing.
The causes of equipment problems were
usually identified and addressed.
An exception was the unexplained trips of
the main feedwater pump that preceded the reactor trips.
A root-cause could
not be determined.
The inservice inspection program was also considered
adequate.
9
Staffing in this functional area continued to be a licensee strength.
This was*
largely attributed to the low turnover rate in both the worker and supervisory
ranks.
The licensee continued to implement programs to provide temporary
placement of maintenance workers in staff positions for use as planners or QC
inspectors.
Rotations of this type appeared to increase interaction between
work groups.
Overtime was controlled and the licensee administrative procedures
amplified the requirements of their technical specifications, to include plant
and contractor personnel.
A few cases were identified in which the limitations
were exceeded without obtaining proper approval.
The licensee took prompt
corrective action to resolve this issue.
complied with the applicable codes.
The coordination of work and the working
relationship between the security and maintenance departments were excellent.*
The overall effectiveness of the security-related equipment was attributed to
diligent and competent maintenance support.
2.
Performance Rating
The licensee's performance is rated Category 1 in this area.
The licensee's
performance was rated Category 2 improving in the previous assessment period.
3.
Recommendations
None.
D.
1.
Analysis
Evaluation of this functional area was based on the results of two inspections
performed by region-based inspectors and observations made by resident
inspectors.
A total of 132 inspection hours were expended in this functional
area, comprising 2 percent of the total inspection hours.
Enforcement-related performance was relatively weak.
violations were identified during this assessment period, which appeared to
have programmatic implications, as discussed in the following paragraphs.
No
violations were identified during the previous period.
Management was not adequately involved in ensuring.quality in this area during
this assessment period, as indicated by two violations identified near the end
of the assessment period.
Both violations concerned weaknesses identified in
the licensee's staffing and training of the emergency response organization
(ERO).
Management had not effectively monitored the status of ERO qualifications
nor provided sufficient support for the emergency preparedness (EP) training
program.
The licensee's identification and resolution of technical issues from a safety
standpoint were good.
In response to Emergency Plan activations, the licensee
conducted post-activation reviews for each event to identify areas that could
be improved.
Items identified through these reviews of real events, critiques
10
of drills and exercises, internal and external audits, and NRC inspections were *
tracked and resolved in a timely*manner.
The licensee volu.ntarily participated
in the.implementation of the emergencx response data system (EROS).
The
licensee was the first utility in Region III to have an operational EROS.
The licensee's response to operational events was good.
Two events were
classified and reported pursuant to 10 CFR 50.72 as Emergency Plan activations
during this assessment period.
Both of these events were classified as Unusual
Events.
Each event was correctly classified in a timely-manner.
The licensee
appropriately notified the State, counties, and the NRC within the required
time limit for each event.
Staffing of the ERO was inadequate, at times, during this assessment period.
Because of lapsed training, the licensee would have been unable to continuously
staff several ERO positions with trained and qualified personnel.
The licensee
cross-trained many individuals for multiple ERO positions.
Utilizing individuals
who had been cross-trained helped to mitigate the shortages of qualified
individuals.
The emergency plan training program was ineffective because it received
inadequate management oversight.
Numerous ERO members were not fully qualified
for their designated positions because they had not completed required retraining
within allowed time requirements. Although the licensee had a program for
tracking ERO qualification and training needs, and the required training courses
were made available, the courses were poorly attended. Also, the licensee's EP
training matrix was lacking a required course for the position of HP support
group leader.
Due to an administrative error, this course was omitted during a
program revision.
Also, some lesson plans were not reviewed or revised in a
timely manner.
Although the qualification program in general was not effectively
implemented, the licensee did utilize problem sets to provide good practical
exercises for individuals as part of the program.
Performance during the annual EP exercise was generally good.
The scenario,
which involved a tube rupture in the steam generator and a non-isolable break
in the main steam line, was adequate to challenge and involved most of the ERO.
Problems were observed with command and control of the Operations Support
Center and Maintenance Support Center, and the Emergency Operations Facility
was not activated in a timely manner .. Both facilities successfully fulfilled
their respective emergency response roles.
2.
Performance Rating
Licensee performance is rated a Category 2 and declining in this area.
The
licensee was rated a Category 1 during the previous assessment period.
3.
Recommendations
None.
11
E.
Security
1.
Analysis
Evaluation of this functional area was based on the results of three routine
security inspections and two Fitness-For-Duty (FFD) ins*pections by regional
inspectors and observations made by resident inspectors. A total of 186
inspection hours were expended in this- functional area, comprising 2.9 percent
of the total inspection hours.
Enforcement-related performance in the security area was good.
Inspectors
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of some access control search equipment and appeared to be an isolated
occurrence.
The licensee identified FFD problems that were cumulatively
treated as a Severity Level III violation. This violation involved a
significant breakdown in several basic elements of the licensee's FFD program
which was implemented by corporate personnel through the Human Resources
Department.
Once the problems were identified, licensee management initiated
aggressive and effective corrective actions.
Management involvement in ensuring the quality of the security program was
good.
Management support was demonstrated through continual upgrades to the
security program during the SGRP.
These upgrades included additions to the
security staff and security building modifications.
Inspectors considered
management oversight, planning and extensive compensatory measures for the
SGRP, and routine daily security activities a program strength. Security
management was re5porisive to all findings that could strengthen the overall
security program.
Licensee action for these findings was comprehensive and
utilized the coordinated talents of security and contractor personnel.
During
this assessment period, security managers kept both resident inspectors and
regional personnel fully informed of site security issues.
The licensee's approach to identifying and resolving issues was good .. The
licensee demons~rated a cl~ar understanding of the issues throughout the
planning and implementation of security requirements associated with the SGRP.
The implementation included extensive long-term, in-depth compensatory measures;
protected and vital area barrier modifications; .and extensive security plan
revisions.
This 11defense-in-depth 11 philosophy assured the licensee that
in-attentive guards or equipment failure would not become a *Security issue.
The
licensee's program for required reporting of security events was excellent.
Required reports and logs were accurate and timely.
In general, security-related
records were complete, well maintained, and readily available.
Licensee staff resources dedicated to-the security organization were ample
during this assessment period.
The licensee increased the number of security
officers to meet requirements for support of the SGRP and associated activities.
The security resources were effectively utilized and a high level of security
awareness was evident.
The close and effective liaison established among local
law enforcement agencies, the security contractor site management, and licensee
security management was a program strength.
QA audits of the security program
by contractor personnel as well as corporate QA personnel contributed to the.
security organization's overall good performance.
The audits were aggressive,
detailed, broad in scope, and well documented.
Aggressive management/employee
relations programs are partially responsible for a low turnover rate of only
about 3 percent for 1990.
12
The training and qualification program for the security organization was good.
The program was effectively implemented.
Security personnel were competent in
th~ execution of their duties.
The licensee's security organization identified
the need for additional and more effective tactical response training.
However,
due to SGRP support requirements, very little of this training was performed
this assessment period.
During this as~essment period, NRC inspectors reviewed the licensee's FFD
program required by 10 CFR Part 26.
This review indicated that, initially,
portions of the rule either were not addressed or were implemented contrary to
NRC regulations.
The licensee's QA staff identified these problems during an
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was later held and the root causes of the Severity Level III violation appeared
to be inadequate management oversight and too much reliance* on the FFD program,
which was already in place before the implementation of 10 CFR Part 26.
The
licensee took immediate and extensive corrective actions to correct all the
problems once they were identified, and the licensee's FFD program thereafter
appeared to meet the objectives of 10 CFR Part 26.
2.
Performance Rating
The licensee's performance is rated a Category 1 in this area. The licensee's
performance was rated Category 1 in the previous SALP assessment period.
3.
Recommendations
None.
F.
Engineering/Technical Support
1.
Analysis
Evaluation of this functional area was based on one team, one special, and two
routine inspections by regional inspectors; one enforcement conference, one
requalification, and one initia] examination by operator licensing examiners;
several inspections by resident inspectors; and interactions between the
licensee and the staff of NRR.
Overall, 882 inspection hours were expended in**
this functional area, comprising 13.6 p.ercent of the total inspection hours.
Enforcement history included one Severity Level III violation for a programmatic
breakdown in the areas of design control, adherence to procedures, and
corrective action for engineering activities that involved piping and pipe-
support analyses.
These problems occurred prior to the appraisal period.
In
addition, two Severity Level IV violations, one in the area of test control and
the other in the area of environmental qualification of electrical equipment
were identified.
Of the several LERs attributable to this area, all except two were the result
of original design or design change errors performed during prior assessment
periods.
These errors were found by the configuration control project (CCP).
One current LER was the result of an improper work practice and the other
pertained to a design error during a modification.
13
Management involvement in ensuring quality continued to be inconsistent this
period.
On the positive side, the engineering staff was actively involved in
maintenance and operational activities.
In addition, engineering support
personnel continued to be rotated into operator licensing classes.
The CCP,
started during an earlier assessment period, continued to progress well and
disclosed a number of design problems.
A critical self-review of the design
change program was completed, with results confirming the need to strengthen
control of activities in this area.
The licensee modified the requirements of
various service contractors to provide monetary incentives (bonuses and penalties)
for regulatory and safety performance including compliance with fire protection
and security programs and meeting ALARA goals.
The licensee upgraded the
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and enhanced the controlling administrative procedure for facility changes in
order to attain a more consistent approach in technical methodology and
documentation.
However, the effectiveness of these efforts was reduced by the
implementation of a different administrative procedure and project specific
design criteria for the SGRP contractor.
Management involvement in the planning
and assignment of priorities for the SGRP was also evident.*
On the other hand, technical evaluation and oversight for the hydrostatic
pressure testing of plant systems by the HAFA Company was poor.
Management
lacked control of this technical contractor as exemplified by the inadequate
technical review of the implementing procedures, the use of improperly certified
personnel, and the incompleteness of test data and related records.
When the
NRC pointed out the deviations from the NRC-approved concept, the licensee
continued to maintain that the tests were valid, even though they lacked a
technical basis.
Further, management was not aggressive in purs.uing a number
of other engineering or t.echnical issues.
Examples of this include the licensee's
attempt to resolve a welding issue for four branch connections using
circumstantial justification instead of addressing the issue using positive
verification in accordance with their commitments.
Also, for a socket weld
issue, the licensee's initial evaluation of dimensional weld data used an
approach that did not adequately bound the potential significance of the issue.
Engineering activities associated with piping and structural analyses continued
to show weaknesses with design verification. Management's efforts to achieve
programmatic improvements and to communicate quality standards in the area of
design verification, while worthy of mention, were not fully effective.
Reviews of calculations performed near the end of the assessment period continued
to disclose a lack of attention to detail similar to that found during earlier
inspections.
In one case, a piping component in the auxiliary feedwater steam
supply system was changed without considering the impact of the change on the
piping stress analysis.
In another case, an incorrect analytical approach,
noted by the NRC, resulted in the modification of a pipe support in the
containment sump drain system.
These examples demonstrate that the significant
design control deficiencies, which led to the escalated enforcement early in the
period, had not been completely resolved.
The design change program was reviewed with mixed results. Modifications to the
ATWS system, the refueling machine, the pressurizer power operated relief
valves (PORV), and the closure logic to the feedwater valves were reviewed.
Most were performed with satisfactory results, however, the PORV modification
resulted in a design change that was implemented without fully understanding
14
-------
the system configuration and the operating characteristics of the PORV.
This
implementation led to the uncontrolled opening of the PORV during post
modification testing, causing a reactor coolant system pressure transient. A
number of _design changes pertaining to the SGRP were also reviewed.
These
included replacement of feedwater heaters, replacement of steam generators,
replacement of the condenser, addition of steam piping, modification of blowdown
piping, and establishment of the containment construction opening.
These
design changes were generally well planned and effectively implemented.
The
post modification testing was in progress at the conclusion of this assessment
period.
safety standpoint was considered mixed.
Numerous problems with design activities
and calculations, particularly with respect to certain SGRP piping analyses,
were identified during onsite engineering reviews and quality assurance audits.
However, management did not aggressively correct the cause of these problems.
On *the other hand, in the case of the unexpected operation of the atmospheric
dump valves as a result of electrical noise, the engineering staff demonstrated
its ability to resolve a problem once it was identified. Also, the licensee
responded vigorously to investigate and resolve the issues associated with the
uncontrolled opening of the PORV, including close monitoring and control of
the involved technical contractor.
The engineering and technical support staff continued to be relatively stable
and the licensee maintained a strong commitment to the system engineer program.
The level of staffing appeared to be sufficient to handle the engineering
workload, however, as mentioned above, the licensee did not exhibit sufficient
technical oversight of some of its contractors.
Rotations among the engineering
department and other plant departments were accomplished which encouraged a
team concept among plant personnel.
Overall, management performance in the areas of operator requalification and
replacement operator examinations declined from the. previous assessment period.
Inspectors identified deficiencies in the written examination question bank for
requalification examinations similar to those found in the previous assessment
period. The training department did not effectively support the requalification
examinations.
Licensee representatives dedicated to the examination team were
required to participate in collateral activities. This reduced their time
available for examination development and resulted in poor quality of the
written examinations submitted to the NRG for approval, particularly the most
recent examination.
In addition, deficiencies in the written examination
bank, similar to those identified in 1989, were indicative of an inability to
maintain the requalification material.
Improvements were noted during the
requalification retake examination late in the assessment period.
The
licensee's proposed plan to upgrade the quality of their reference material was
comprehensive and well presented.
Performance during requalification examinations was judged satisfactory,
however, the effectiveness of training decreased as exemplified by the fact
that the passing rate for NRG-administered initial and requalification
examinations declined.
One of two licensed operators who failed the
requalification examination also failed the NRG-administered requalification
retake examination, indicating that remedial training was not effective.
15
. 2.
Performance Rating
The licensee's performance is rated Category 2 and declining in this area.
The
licensee's performance was rated Category 2 in the previous assessment period.
3.
Recommendations
None.
G.
Safety Assessment/Quality Verification
1. Analysis
Evaluation of this functional area was based on the results of 11 routine
inspections by the resident inspectors, several routine inspections by regional
inspectors, and a team inspection to review 10 CFR 50.59 evaluations of the
steam generator replacement.
In addition, the NRC considered its staff's
review of licensee submittals and requests for amendments to the operating
licenses. A total of 1,525 inspection hours were expended in this functional
area, comprising 23.6 percent of the total inspection hours.
The enforcement history in this functional area included three Severity Level IV
violations.
The first was for failure to request a Technical Specification
change following a design change.
Compensating maintenance and surveillance
requirements, however, were implemented at the time of the change.
The second
violation involved a change to a procedure that altered the original intent,
yet no safety evaluation was performed.
The third violation involved failure
to take adequate corrective action for a previous violation in the equipment
qualification area.
The violations did not share a common root cause, were not
representative of programmatic breakdowns, and were not the same as any of the
three Severity Level IV violations issued during the last assessment period.
The single LER issued during this assessment period that was attributed to this
functional area was for a personnel error in configuration control that occurred
while verifying wiring.
The error caused an electrical short and a right
channel containment isolation while the plant was in cold shutdown.
This LER
did not indicate a programmatic weakness.
Management involvement in ensuring quality was inconsistent.
Management
conti~ued to support various programs, several of which had begun before and
will continue past this assessment period. These included the configuration
control project (CCP) and the performance of critical self-assessments as a
tool for corporate and plant management to improve work activities. The
self-assessments each involved an assessment team and generated some long term
corrective actions.
To ensure continuity, the team leader is tasked with
tracking and trending all the team items through ultimate closure.
The CCP
consists of retrieving and reconstituting design basis documentation and
confirming safety system design.
Inspectors considered licensee implementation
extensive in both scope and detail. However, the lack of a writer's guide
before beginning the review of the design basis documentation resulted in
16
scheduling delays for completing the CCP.
In addition, the licensee chose to
let the contractor manage overtime, which resulted in some critical personnel
working to the point of exhaustion.
One such individual ev.entually resigned.
Evaluation of his work determined that quality had not been compromised.
During the CCP, the licensee identified numerous technical issues and potential
safety concerns.
Each received a timely evaluation and no immediate safety
concerns were identified. The actions and schedule to correct the many
electri~al design and wiring diagram discrepancies were reasonable, however,
the schedule for resolving other discrepancies has not been determined.
The licensee provided additional resources to disposition all the CCP findings.
The licensee continued to operate a large-volume, low-threshold corrective
action program, focused on timely classification and segregation of significant
items for review by the appropriate level of plant and corporate management.
The corrective action program provided for daily meetings chaired by one of the
managers.
Responsibility for maintaining and resolving discrepancies among
corrective action documents was assigned to individuals instead of a group or
section, which established direct accountability for the end product.
Processing
of corrective actions was generally characterized by proper technical and
safety focus, effective root-cause and trend evaluations, and timeliness.
One notable exception involved a failure to meet a commitment.
The quality of the licensee's evaluations associated with ongoing licensing
actions was generally good.
However, on several occasions, the NRC had to
request additional information in order to properly evaluate a licensing issue.
These requests were responded to in a timely manner, however, th~ number of
such requests indicated a weakness in the licensee's ability to ensure that.
consistent, high-quality evaluations were prepared and reviewed.
NRC questions
about licensing submittals were not always factored into the licensee's planning
process.
The licensee's approach to identifying and resolving technical issues from a
safety standpoint was typified by the general thoroughness of the 10 CFR 50.59
evaluations performed for the SGRP.
These evaluations identified and adequately
addressed the safety issues related to the SGRP.
The only deficiencies were
failures to identify that certain minor Technical Specification changes were
required before startup.
However, during this assessment period, the licensee
submitted its final evaluations regarding TMI Action Plan Item II.D.1,
"Performance Testing of Relief and Safety Valves,
11
for which a number of
concerns had been identified during the previous assessment period.
The
content of the submittals during this assessment period, coupled with
discussions with the licensee's staff, indicated that significant attention and
thorough evaluation were given to the remaining outstanding items for this TMI
issue.
The licensee was proactive in conducting public meetings with local residents
to discuss topics of interest.
Public meetings, pertaining to steam generator
replacement and dry storage of spent fuel, were attended by the resident inspector.
Informal feedback from participants indicated the meetings were helpful in
determining the level of public interest.
Plant and corporate use of QA audits and QC verifications were evident by the
findings made and corrective actions taken.
Positive contributions to good
17
I.
programmatic performance were evitient in the security area.
Early
identification and correction of problems to prevent more significant
deficiencies from developing occurred in the fire protection and FFD programs.
On the other hand, QA audits did not identify training.and qualification
problems that existed in the emergency planning area.
Auditors and inspectors were qualified and technically competent.
The scope
and quality of the audits and inspections met or exceeded requirements and
usually emphasized performance as well as compliance.
Findings were usually
responded to in a thorough, timely, and technically sound manner.
The Onsit~ R~viPw rnmmi++ee wes prop9rly st:ff:d :~d funet1onad wa11.
The
licensee decentralized its licensing function, assigning the duties of a staff
of approximately 10 licensing engineers from the headquarters to the respective
plants.
The transition went smoothly and served to improve licensing staff
access to plant technical staff and hardware.
2.
Performance Rating
The licensee's performance is rated Category 2 in this area.
The licensee's
performance was rated Category 2 in the previous assessment period.
3.
Recommendations
None.
IV.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
Palisades Nuclear Generating Plant operated at the administratively imposed
power level limitation of 80 percent during this SALP assessment period.
The
limitation was imposed by the licensee during the previous assessment period to
resolve NRC questions pertaining to the integrity of steam generator tubes.
The unit was removed from service for three preplanned outages.
Two outages
prepared the unit for the steam generator replacement outage.
The third was
the steam generator replacement and refueling outage that was continuing at the
completion of this assessment period.
In addition, two forced outages occurred.
One pertained to replacement of a faulted pressurizer heater transformer and
the second was a continuation of a preplanned outage when a PORV failed to
function properly.
Palisades experienced eight engineered safety feature (ESF) actuations and four
Two trips occurred while operating at .greater than 15 percent
power and two occurred with control rods already inserted.
Both power trips
were preceded by inadvertent trips of main feedwater pumps.
The other two did
not involve co.ntrol rod movement--one was caused by implementation of a design
modification that did not consider plant operating characteristics and the
other was due to an incorrect test procedure.
18
f
Significant outages and events that occurred during the assessment period are
summarized below.
- 1.
On 10/01/89, the plant was shut down to prepare for the steam generator
replacement.
This shutdown became a forced outage on 11/26/89 when a PORV
and block valve failed to function as intended.
The outage was extended
to 12/20/89 at which time the plant was returned to service.
2.
During 01/08-10/90, the plant reduced power for main condenser maintenance.
On 01/09/90, the plant was manually tripped from 35 percent power when the
11A
11 main feedwater pump tripped for unknown reasons.
The plant was
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On 02/28/90, an inadvertent loss of the 118
11 main feedwater pump occurred
when the plant was at 80 percent power.
During recovery actions, the
plant tripped from approximately 59 percent power because of a variable
high power trip. The plant was returned to power operations on 03/03/90.
4.
On 09/15/90, the unit was removed from service for a planned 150-day
refueling and steam generator replacement outage. This outage extended
through the end of the assessment period.
B.
Inspection Activities
Forty-one inspection reports are discussed in this SALP (09/01/89-12/31/90) and
are listed below.
Significant inspection activities are listed in Paragraph 2 .
. 1.
Inspection Data
Facility Name:
Palisades Nuclear Power Plant Docket No.:
50-255
Inspection Reports:
89024, 89026 through 89034, 90002 through 90006, 90008
through 90019, 90021 through 90025, 90027 through 90031, 90034, 90035, 90037
and 90038.
2.
Special Inspection Summary
a.
During 08/14-12/08/89, a special.safety inspection was conducted of the
licensee's snubber reduction program.
This inspection resulted in an
enforcement conference and a civil penalty pertaining to a programmatic
breakdown in the control of design activities, compliance with procedures,
and corrective action.
(Inspection Report 255/89024 and 255/90002).
b.
During 07/19-09/05/89, a special inspection was conducted pertaining to
containment integrity and reportable events.
(Inspection Report 255/89027).
c.
During 11/23-12/15/89, a special team inspection was conducted to evaluate
the inadvertent depressurization event on 11/21/89 (Inspection Report
255/89033).
19
'
d.
During 05/21-25/90 the annual EP exercise was conducted (Inspection
Report 255/90011).
e.
During 05/13-31/90, a special assessment of the ALARA program was conducted
(Inspection Report 255/90013).
f.
During 07/30-08/03/90, a special team inspection was conducted to evaluate
the 10 CFR 50.59 review process for the SGRP (Inspection Report 255/90017).
g.
During 08/13-09/19/90, a special safety inspection was conducted of
circumstances associated with falsification of training records by an
instructor and fal,ifir::itinn 0-F
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This inspection resulted in an enforcement conference.
(Inspection
Reports 255/90019, 255/90028, 255/90030 and 255/90035).
h.
During 10/15-19/90, a special safety inspection was conducted of the
licensee's FFD program.
This inspection resulted in an enforcement
conference and a civil penalty (Inspection Report 255/90027).
C.
Escalated Enforcement Actions
1.
A Severity Level III Notice of Violation and a proposed $75,000 civil
penalty were issued on 02/20/90 for a programmatic breakdown in the
control of design activities, compliance with procedures, and corrective
actions.
(Enforcement Action EA 89-251 and Inspection Report 255/90002).
2.
A Severity Level III Notice of Violation (with no civil penalty) was
issued on 12/14/90.
This action was based on problems associated wit~ the
licensee's FFD program.
(Enforcement Action EA 90-189 and Inspection
Report 255/90027).
D.
Confirmatory Action Letters
None.
E.
Licensee Event Reports
LERs 89021 through 89025 and 90001 through 90021 (including "voluntary"
LER 89022) were issued during this assessment period.
20