ML18057B397
| ML18057B397 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/25/1991 |
| From: | Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057B395 | List: |
| References | |
| 50-255-91-18, NUDOCS 9112060049 | |
| Download: ML18057B397 (13) | |
See also: IR 05000255/1991018
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION II I
Report No. 50-255/91018(DRP)
Docket No. 50-255
Licensee: Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, MI
Inspection Conducted:
September 24 through November 4, 1991
Inspectors: J. K. Heller
J. R. Roton
Approved By:
Inspection Summary
~*
en, Chief
J cts Section 2A
DATE
License No. DPR-20
11-2~ -y I
Inspection From September 24 through November 4, 1991 (Report No.
50-255/91018(DRP))
Areas Inspected:
Routine unannounced safety inspection by resident inspectors
of actions on previously identified items, plant operations, maintenance,
surveillance, security and reportable events~
No Safety Issues Management
System (SIMS) items were reviewed.
Results: Of the six areas inspected, no cited violations or deviations were
identified in five areas.
One cited violation was identified (para9raph 2.b -
11failure to comply with a Technical Specification action statement") in the
remaining area.
Paragraph 7 "Reportable Events" describes three
non-cited violations that were identified and reviewed during this inspection
period.
Strengths, Weaknesses and open items are discussed in paragraph 9, "Management
Interview.
11
In summary:
The strengths included the licensee's response and enthusiasm during a drill,
the licensee's investigation and preplanning of a repair activity, and the
licensee's evaluation and corrective ~ction for a degrading CROM seal.
The weaknesses included the licensee's control of vendor m~nuals, an example
where the licensee appeared to exceed the scope of a work order, and the
staging of equipment that unnecessarily resulted in degraded fire barriers .
DETAILS
1.
Persons Contacted
Consumers Power Company
- G. B. Slade, Plant General Manager
- P. M. Donnelly, Safety & Licensing Director
- K. M. Haas, Radiological Services Manager
- J. L. Hanson, Operations Superintendent
- R. B. Kasper, Maintenance Superintendent
- K. E. Osborne, System Engineering Superintendent
- 0. D. Hice, Chemistry Superintendent
L. J. Kenaga, Health Physics Superintendent
- C. S. Kozup, Technical Engineer
W. L. Roberts, Senior Licensing Analyst
- R. W. Smedley, Staff Licensing Engineer
- T. J. Palmisano, Administrative & Planning Manager
Nuclear Regulatory Commission (NRC)
- J. K. Heller, Senior Resident Inspector
- J. R. Roton, Resident Inspector
- Denotes some of those present at the Management Interview on November 7,
1991.
Other members of the plant staff and several members of the contract
security force were also contacted during the inspection period.
2.
Actions on Previously Identified Items (92701, 92702)
a.
(Open) Open Item 255/91009-0l(DRP) and Violation
255/91006-03(DRSS):
Control of Vendor Manuals.
These items addressed vendor manual control problems in two plant
disciplines. Consumers Power Company Audit Report QA-91-20, in.
paragraph 3.2, identified a vendor manual control problem in a third
discipline.
The inspector concluded that the licensee's corrective
action for the violation and subsequent open item did not encompass
vendor manual control for all plant disciplines as evidenced by
QA-91-20.
This was discussed at the management interview.
b.
(Closed) Unresolved Item 255/91015-01:
Removal From Service of
Pressure Switch (PS)-0918,
11 Component Cooling Water Pump Discharge
Pressure.
11
This unresolved item addressed two questions.
Tve first concerned
whether a temporary modification was required and the second
pertained to the applicability of the Technical Specifications .
2
. .
3.
The inspector reviewed the following:
(1)
Palisades Final Safety Analysis Report (FSAR), section
9.3.2.3.3,
11 Emergency Operations.
11
(2)
Palisades Technical Specifications 3.4.1 and 3.4.2.
With regard to the question concerning the need to process a
temporary modification when PS-0918 was initially removed from
service, the licensee - by authorizing a temporary modification
subsequent to their reanalysis of this question - has rendered the
issue academic.
No unreviewed safety question existed.
With regard to the question concerning the applicability of
Technical Specifications 3.4.1 and 3.4.2 when PS-0918 was removed
from service, the inspector's assessment was that the Technical
Specifications did apply.
The Palisades FSAR, in section 9.3.2.3.3,
11 Emergency Operations," stated:
11The third pump is sequenced later
but only starts if a low pump discharge pressure is present,
indicating that the other pumps have not started.
11
In the event of
a OBA, one component cooling pump and both heat exchangers are
required.
The opening of the links to PS-0918 on August 27, 1991, rendered
inoperable the interlock provided to automatically start the third
CCW pump.
Palisades Technical Specification 3.4.1.c requires heat
exchangers, valves, piping and interlocks associated with the
containment cooling system and required to function during accident
conditions be operable during plant operations. Technical
Specification 3.4.2 provides limiting conditions for operations and
action requirements if components of TS 3.4.1 are not operable.
The
accident analyses only credit one component cooling water pump
during the injection phase of an accident, although three are
provided, thus mitigating the safety significance. Applicability,
in this case, was determined by FSAR commitment to system design and
operating characteristics. The rendering of PS-0918 inoperatile on
August 27, 1991, and subsequent failure to comply with the action
statements within the time limits specified, is a violation of
Palisades Technical Specifications 3.4.1.c and 3.4.2 (Violation
255/91018-0l(DRP)).
The inspector observations pertaining to control of the maintenance
activity for PS-0918 is discussed in paragraph 4.a,
11Maintenance -
11
One violation and no deviations, unresolved or open items were
identified.
Operational Safety Verification (71707, 71710, 42700)
Routine steady state operating activities were observed as conducted in
the plant and from the main control room.
3
The performance of reactor operators and senior reactor operators, shift
engineers, and auxiliary equipment operators was observed and evaluated.
Included in the review were procedure use and adherence, records and
logs, communications, shift/duty turnover, and the degree of
professionalism of control room activities.
Evaluation, corrective action, and response for off normal conditions or
events were examined.
This included compliance to any reporting
requirements.
Observations of the control room monitors, indicators, and recorders were
made to verify the operability of emergency systems, radiation monitoring
systems, and nuclear reactor protection systems.
Reviews of
surveillance, equipment condition, and tagout logs were conducted.
a.
Genera 1
The unit began and ended the report period at essentially 100
percent power.
The unit experienced an efficiency loss of
approximately 10 MWe when CV-0605,
11Feedwater Heater 6-B Drain
11
failed in the closed position (discussed in paragraph 4.b,
11Maintenance
11 ).
b.
CROM 17 Inoperable
The inspector reviewed the licensee's response to an elevated seal
leak-off temperature for Control Rod Drive Mechanism (CROM) 17.
The elevated leak-off temperature was identified during biweekly
exercising of CRDMs.
The design of the CRDMs utilizes a direct
drive with a rotating seal which forms part of the primary coolant
pressure boundary.
Each CROM has a seal leak-off line with a
locally mounted thermocouple to monitor seal performance.
Leak-off
water is collectively drained to the containment sump.
The elevated
temperature can indicate seal integrity problems.
Because of a
common drain line, the licensee cannot measure the individual CROM
leak-off rate.
The licensee has implemented the following actions.
(1)
The temperature alarm setpoint of CROM 17 has been increased to
eliminate a standing common control room alarm.
This will
ensure that an elevated temperature for CROM 17 does not mask
potential problems with other CRDMs.
(2) A review of the planned preventative maintenance activities for
CROM 17 confirmed that a changeout of the seal package was
scheduled for the next refueling outage.
(3)
An evaluation of the elevated temperature de.termined
operability was not a problem. However, there was a need to
minimize movement of the seals .
4
(4)
To m1n1m1ze movement of the seals, CROM 17 was removed from the
biweekly testing schedule and declared inoperable. Technical
Specifications do not require compensatory measures if one CROM
is inoperable.
(5)
The rod was confirmed not to be misaligned and was still
considered capable of being tripped as evidenced by the
refueling frequency test that verified tripping times.
The inspector reviewed the Technical Specifications and FSAR,
discussed this issue with the system engineer, and concluded that
the licensee remains in compliance with the reviewed documents.
c.
Diesel Generator Operability
During this inspection period, the Configuration Control Project
identified a number of potential diesel generator operability
problems.
Each was evaluated and determined not to render the
diesel generators inoperable.
These items are listed below and
were provided to the NRC Electrical Distribution System Functional
Inspection (EDSFI) team leader for consideration during the upcoming
EDSFI inspection.
(1)
The licensee found that no diesel generator trips were bypassed
during emergency phases of operation. This was contrary to NRC
Branch Technical Position 17 which required bypassing of
certain trips during emergency operations.
This item was the. subject of Systematic Ev_aluation Program (SEP)
Topic VIII-2,
11Diesel Generators
11
The closeout letter dated
February 27, 1981, for SEP Topic VIII-2, stated the licensee
was in compliance with Branch Technical Position 17 with one
exception which was listed and approved.
The February 27
letter also referenced applicable licensee correspondence.
One
licensee letter dated May 16, 1977, stated that the trips were
active and not bypassed during an emergency start. The
licensee has been in telephone contact with NRR to discuss -the
issue and plans to make the appropriate modifications during
the next outage.
(2)
The licensee determined that the
11A
11 control circuit may be
inoperable because of a modification made to the local
annunciator panel.
During the modification, a non-seismically
qualified annunciator panel was installed to provide reflash
capability in the control room.
The annunciator panel has a
locally installed fuse that may short circuit during a seismic
event and cause a loss of power to the
11A
11 control circuit.
The licensee evaluation determined that the.
11B
11 control circuit
was seismically qualified, operated independently of the
11A
11
control circuit and was capable of starting the diesel
generator.
The licensee determined that the diesel generators
were operable but will require modifications during the 1992
refueling outage to establish the proper configuration.
5
(3) A review of diesel generator room cooling determined that the
cooling capacity was marginal.
The room was cooled by a forced
air ventilation system.
The heat rating of the generator may
be exceeded during prolonged usage at fully loaded conditions
during certain times of the year.
The licensee evaluation
continues.
d.
Medical Response Drill
The inspector observed the medical response drill conducted on
September 27, 1991.
The drill was well planned and executed.
The
drill exercised emergency first aid skills, crowd control and
access/egress within a radiologically*controlled area. The response
by both onsite and offsite personnel demonstrated appropriate skills
to deal with actual incidents.
e.
50.72 Notification
On November 1, 1991, the licensee determined that a potential
exists to exceed 10 CFR, Part 50, Appendix A, Criterion 19 limits
for radiological exposure of control room personnel.
The potential
exists because post accident management of containment iodine (as
approved by a previous revision of the NRC Standard Review Plan)
assumed that hydrazine added to the injection water provided iodine
retention and sodium hydroxide added to recirculation water
established a neutral pH and maintained iodine in retention.
The current revision of the Standard Review Plan does not credit
hydrazine for iodine retention. Based on current operating
practices, the licensee determined that the sump pH required to
keep iodine in solution would not be established within one hour (as
assumed in the accident analysis) following a Design Basis Accident
(DBA), the large break loss-of-coolant-accident (LOCA).
Based on
preliminary calculations, unacceptable control room doses are
expected if iodine does not stay in solution during the first four
hours of an event. Presently, the licensee is pursuing proposals on
the application of trisodium phosphate (TSP) for passive sump pH
control. Additionally, control room atmosphere is continuously .
monitored for iodine with procedural requirements for operators to
don self-contained breathing apparatus (SCBA) should an alarm occur.
The inspector had no additional questions. However, this issue will
be followed as the licensee c*ompletes their Maximum Hypothetical
Accident (MHA) analysis.
No violations, deviations, unresolved or open items were identified.
4.
Maintenance (62703, 42700)
Maintenance activities in the plant were routinely inspected, including
both corrective maintenance (repairs) and preventive maintenance.
Mechanical, electrical, and instrument and control group maintenance
activities were included as available *
The focus of the inspection was to ensure the maintenance activities
reviewed were conducted in accordance with approved procedures,
6
regulatory guides and industry codes or standards, and in conformance
with Technical Specifications.
The following items were considered
during this review: the Limiting Conditions for Operation were met while
components or systems were removed from service, approvals were obtained
prior to initiating the work, activities were accomplished using approved
procedures, and post maintenance testing was performed as applicable.
The following activities were inspected:
a.
Work Order (WO) 24906479:
Preplanned Emergence Work On Station
Power Inverters.
The inspector reviewed WO 24906479, which was used to troubleshoot
the Preferred AC Bus No. 1 Trouble alarm on August 27, 1991.
During
trouble shooting, the licensee found a ground associated with
PS-0918 had caused the trouble alarm.
When PS-0918 was removed from
the circuit, the trouble alarm was cleared.
PS-0918 is not directly
associated with the station power inverters and appears to be
outside the boundary of the inverters.
The inspector reviewed Palisades Administrative Procedure (AP) 5.01,,
"Processing Work Requests/Work Orders,
11 as it pertains to job scope
(section 5.20) and performance of work (section 6.2.17). It was the
inspector
1 s assessment that the use of WO 24906479 was not in
compliance with the guidance and direction established in AP 5.01.
The noncompliance in this instance is twofold.
(1)
Job scope, as defined section 5.20, is: "That work required to
eliminate the deficiency identified in the original WO,
provided all the required work is principally associated with
the equipment **. identified in the Work Order Equipment
Description section . . .
and no additional system boundaries
will be violated." The defined job scope of WO 24906479
pertained to the station
1s inverters and did not include the
Main Control Room Panel C13L, the panel in which the links for
PS-0918 are located.
Palisades Plant Drawing 950 E-8 Sheet 2,
diagrams the 120V Instrument and Preferred AC System.
The.
Station Power Inverters are shown as dotted lines which is
indicative of a system interface or boundary and doesn
1t
include Panel C13L within the system boundary.
(2)
The performance of work orders, as detailed in section 6.2.17,
requires if a WO cannot be performed or completed in accordance
with the job plan (i.e., there is work required in addition to
the job plan description) the Assigned Supervisor shall proceed
in accordance with section 6.2.9.b of AP 5.01. Section 6.2.9,
11Returned Work Order Processing," requires the Assigned
Supervisor to return the WO to the Work Gro~p Coordinator or
Job Planner if the work required to complete the job was
outside the scope of the WO.
Once returned, the Work Group
Coordinator or Job Planner will revise and reissue the WO to
the Work Group Supervisor for completion.
WO 24906479 was not
revised in accordance with the requirements of section 6.2.9.
7
The manner in which WO 24906479 was used, in the aforementioned
situation, is incompatible with the guidance provided in
Administrative Procedure 5.01.
The inspector did not pursue enforcement action for maintenance
aspects of this issue because electrical maintenance did maintain
positive control by use of a "lead/link control sheet" to document
and control the opened links for PS-0918 in accordance with
Administrative Procedure 5.16, "Controls of jumpers, leads and links
during maintenance, modifications and testing." Enforcement action
is being taken relating to operability of PS-0918 (reference
paragraph 2.b). Through discussions with the licensee, the
inspector has concluded that this apparent misuse of WO 24906479 was
an isolated case and actions taken appeared reasonable to preclude
recurrence.
b.
WO 24105095: Repair CV-0605 "Feedwater Heater E-68 Drain."
The inspector observed two portions of the attempted repair
activities. The first pertained to the investigation confirming
that the valve was separated from the disc and the second pertained
to planning and attempted repair of the valve. During the initial
investigation, the inspector observed the cooperative effort of
system engineers, operations personnel (auxiliary and shift
supervisor) and maintenance personnel performing the investigation.
During the attempted repair, the inspector attended the planning
meeting and noted that representatives from various plant disciplines
were present, conversation was uninhibited and covered a range of
topics from contingency options to effect on the plant.
The repair
was aborted because a boundary isolation valve would not isolate due
to malfunction.
The licensee continued to evaluate repair options,
because the failure of CV-0605 resulted in an efficiency loss of
approximately 10 MWe.
c.
WO 24105214: Repair Manual Operator BTV-0606, "High Pressure
Feedwater Heater E-68 Extraction Steam."
d.
e.
f.
g .
h.
The manual operator malfunctioned when this valve was used as a
boundary isolation valve for another repair activity.
The
malfunction occurred when the fasteners broke.
Initial
investigation indicated that the fasteners were the wrong material.
The licensee evaluation continues.
WO 24102911:
WO 24102031:
WO 24103543:
WO 24103601:
WO 24100035:
M-20 Asphalt Recirculation Pump Installation.
Refurbish Spare Condensate Pump.
Cleaning Main Transformer Cooling C.oil Fins.
Thermal Scan of Station Power System.
Erect Scaffolding for CV-0605.
8
i.
WO 24103594:
Remove Mechanical Block From Emergency Diesel
Generator 1-2 Dampers.
j.
WO 24103474:
Remove Mechanical Block From Emergency Diesel
Generator 1-1 Dampers.
k.
WO 24101661:
Air Compressor C-2C.
l.
WO 24104989:
Repair of Leaking Fitting Associated With Heater Drain
Pump lOA.
No violations, deviations, unresolved or open items were identified.
5.
Surveillance (61726, 42700)
The inspector reviewed Technical Specifications required surveillance
testing as described below and verified that testing was performed in
accordance with adequate procedures.
Additionally, test instrumentation
was calibrated, Limiting Conditions for Operation were met, removal and
restoration of the affected components were properly accomplished, and
test results conformed with Technical Specifications and procedure
requirements.
The results were reviewed by personnel other than the
individual directing the test and deficiencies identified during the
testing were properly reviewed and resolved by appropriate management
personnel.
The following activities were inspected:
a.
ME-12
Monthly Battery Checks
b.
The inspector verified that the crew was in compliance with the
requirements of ME-12 during the setup and performance of the test.
During the setup, the crew placed an electrical extension cord
through the fire doors to battery rooms 1 and 2.
The fire doors
were declared inoperable and the applicable compensatory measures
implemented.
Once the equipment was setup, the crew left the area.
The inspector questioned the need to degrade a fire barrier (fire
door) in preparation for test performance since no one was in the
area, no surveillance activities were being performed and removal
of the extension cord and restoration of the fire barrier to operable
status was not a difficult or time consuming task.
Q0-10
(1)
Containment Spray and Low Pressure Safety Injection
Check Valve Test
During the Enforcement Conference for Inspection Report No.
50-255/91017(DRP), the licensee stated that the performance of
Q0-10 interrupted shutdown cooling because the Containment
Spray System and Shutdown Cooling System share components.
As
a result of that statement, the inspector reviewed Q0-10 to
ensure that sufficient controls were in place to prevent an
inadvertent loss of shutdown cooling.
Q0-10 required approval
of a shift supervisor, the Operations Department Scheduler and
the Operations Superintendent prior to performance of sections
9
that bypassed the shutdown cooling heat exchanger.
Additionally, the test was not permitted during mid-loop or
reduced inventory conditions. Q0-10 maintained shutdown
cooling flow but bypassed the shutdown heat exchanger during
performance of the test and appeared to have sufficient
administrative controls in effect to prevent an inadvertent
loss of shutdown cooling.
The inspector discussed this item with the Operations
Superintendent and the Inservice Inspection Supervisor.
The
inspector asked if the licensee considered that the information
obtained from the test justified the risk to shutdown cooling
ability.
The response was affirmative.
In addition, the
inspector was informed that a proposed modification to the
recirculation flow path, to resolve an unrelated problem,
should minimize the risk.
(2)
While reviewing Q0-10, the inspector noted that paragraphs
5.2.2.a. and 5.2.3.a. required verification that the RHR pump
discharge valve was open prior to starting the pump.
The valve
referenced was not for the pump started. This was identified
to the System Engineer, who stated that the procedure would be
revised. This error did not affect operability of the pumps.
c.
M0-78
Fire Water Pumps
d.
M0-7C
Fuel Oil Transfer Pumps
e.
DW0-13
LLRT Inner/Outer Personnel Air Lock Seal
No violations, deviations, unresolved or open items were identified.
6.
Security. (71707)
Routine facility security measures, including control of access for
vehicles, packages and personnel, were observed.
Performance of
dedicated physical security equipment was verified during inspections in
various plant areas.
The activities of the professional security force
in maintaining facility security protection were occasionally examined or
reviewed, and interviews were occasionally conducted with security force
members.
During the evening of October 1, 1991, the inspector observed various
drills designed to exercise the response capabilities of the licensee's
security force against terrorist infiltration of the facility.
The
professionalism and enthusiasm of the security personnel were noteworthy.
The drill scenarios appeared to be well planned, well executed, and a
valuable training tool.
No violations, deviations, unresolved or open items were identified.
10
7.
Reportable Events (92700, 92720)
The inspector reviewed the following Licensee Event Reports (LERs) by
means of direct observation, discussions with licensee personnel, and
review of records.
The review addressed compliance to reporting
requirements and, as applicable, that immediate corrective action and
appropriate action to prevent recurrence had been accomplished.
a.
(Closed) LER 90012:
Service Water to Control Room HVAC
(CRHVAC) Inadequate to Support CRHVAC Design Temperature Due to
Incorrect Heat Load Assumption.
b.
(Closed) LER 90016:
Primary Coolant System Vent Valve Sizing Error.
This event involved a violation of Technical Specification 3.1.8.
The inspector concluded that the licensee had performed a prompt
evaluation for this event with appropriate management attention.
The corrective actions taken appeared adequate to prevent recurrence.
In accordance with 10 CFR 2 Appendix C, Section V.G., a Notice of
Violation was not issued for failure to meet the requirements of
Technical Specification 3.1.8 since it was licensee identified,
classified as Severity Level IV or V, reported, not a willful
violation, and was corrected, including measures to prevent
recurrence, in a reasonable period of time (Closed - Violation
(NV6) 255/91018-02(DRP)).
c.
(Closed) LER 90017:
LTOP Inoperable as PORV Circuitry
Inappropriately Disabled.
This event also involved a violation of Technical Specification 3.1.8.
The inspector concluded that the licensee had performed a prompt
evaluation for this event with appropriate management attention.
The corrective actions taken appeared adequate to prevent recurrence.
In accordance with 10 CFR 2 Appendix C, Section V.G., a Notice of
Violation was not issued for failure to meet the requirements of
Technical Specification 3.1.8 since it was licensee identified,
classified as Severity Level IV or V, reported, not a willful
violation, and was corrected, including measures to prevent
recurrence, in a reasonable period of time (Closed - Violation (NV6}
255/91018-03(DRP)).
d.
(Closed) LER 91001:
Plant Operation in Literal Non-compliance with
Technical Specification Table 3.17.1.
The inspector determined this event did not constitute a violation.
e.
(Closed) LER 91003:
Failure to Test Diesel Auto Start Circuits.
This event involved a violation of testing requirements of Technical
Specification 4.1.
The inspector concluded that the licensee had
performed a prompt evaluation for this event with appropriate
management attention.
The corrective actions taken appeared adequate
to prevent recurrence.
In accordance with 10 CFR 2, Appendix C,
Section V.G., a Notice of Violation was not issued for failure to
11
meet the surveillance requirements listed in Technical
Specification 4.1, Table 4.1.2 since it was licensee identified,
classified as Severity Level IV or V, reported, not a willful
violation, and was corrected, including measures to prevent
recurrence, in a reasonable period of time (Closed - Violation
(NV6) 255/91018-04(DRP)).
f.
(Closed) LER 91005:
Inadvertent Left Channel Containment Isolation
Caused by Inappropriate Work Instructions.
g.
(Closed) LER 91006:
Failure to Compensate for Open Fire Barrier
Seal.
Three violations were identified.
No deviations, unresolved or open
items were identified.
8.
Management Interview
The inspectors met with licensee representatives - denoted in Paragraph 1
- on November 7, 1991, to discuss the scope and findings of the
inspection.
In addition, the likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspectors during the inspection was also discussed.
The licensee did
not identify any such documents/processes as proprietary.
Highlights of the exit interview are discussed below:
a.
Strengths noted:
(1)
The licensee evaluation of an elevated CROM leak-off
temperature (paragraph 3.b, "Operations - CROM 17 Inoperable").
(2)
Response to a medical drill (paragraph 3.d, "Operations -
Medical Response Drill").
(3)
(4)
(5)
Initial troubleshooting and preplanning of repair for CV-0605
(paragraph 4.b, "Maintenance - WO 24105095
11 ).
.
-
Administrative program implemented to assure shutdown cooling
was not lost during performance of a required surveillance test
(paragraph 5.b, "Surveillance - Q0-10
11 ).
Professionalism and enthusiasm during a security drill
(paragraph 6, "Security").
b.
Weaknesses noted:
(1)
Control of vendor manuals (paragraph 2.a, "Action on Previously
Identified Items").
(2)
The. scope of a work order appeared to be exceeded (paragraph
4.a, "Maintenance - WO 24906479
11 ).
12
c.
d.
e.
f.
g.
(3)
The staging of equipment to perform a surveillance test
resulted in unnecessary compensatory measures (paragraph 5.a,
"Surveillance - ME-12").
The cited violation was discussed. The licensee stated in a previous
meeting and at the exit interview that it did not agree with the
violation.
The licensee was encouraged to discuss its views on the
matter with the NRC Region III section chief assigned to Palisades
(paragraph 2. b, "Ac~ion on Previously Identified Items").
The findings of the Configuration Control Project pertaining to the
Diesel Generators were discussed. The NRC EDSFI will review these
items during a future inspection (paragraph 3.c, "Operations - Diesel
Generator Operabi 1 ity").
The 10 CFR 50.72 notification was discussed. The inspector will
perform additional reviews when the LER is issued (paragraph 3.e,
"Operations - 50.72 Notifications").
The maintenance problem potentially involving wrong material
fasteners was discussed.
The results of the licensee investigation
will determine if the inspector will inform the NRC vendor inspection
branch (paragraph 4.c, "Maintenance - WO 24105214").
The three non-cited violations were discussed (paragraph 7,
"Reportable Events").
13