ML18066A163

Advises of Planned Insp Effort Resulting from Palisades Plant Performance Review Process.Details of Insp Plan for Next 6 Months Encl

ML18066A163
Person / Time
Site:	Palisades
Issue date:	05/27/1998
From:	Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 9806030252
Download: ML18066A163 (27)

Text

Mr. Thomas J. Palmisano UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 111 801 WARRENVILLE ROAD LISLE, ILLINOIS 60532-4351 May 27, 1998 Site Vice President and General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530

SUBJECT:

PLANT PERFORMANCE REVIEW (PPR)- PALISADES

Dear Mr. Palmisano:

The NRC staff recently completed the semiannual Plant Performance Review (PPR) of the.

Palisades Nuclear Power Plant. The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance. The results are used by NRC management to facilitate planning and allocation of inspection resources. The PPR for the Palisades plant involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period of October 1997 through March 1998. PPRs provide NRC management with a current summary of licensee performance and serve as inputs to the NRC Systematic Assessment of Licensee Performance (SALP) and senior management meeting (SMM) reviews. contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM). that were considered during this PPR process to arrive at an integrated view of licensee performance trends. The PIM includes only items from inspection reports or other docketed

~orrespondence between the NRC and Consumers Power Company. The PPR may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration. This material will be placed in the PDR.as part of the normal issuance of NRC inspection reports and other correspondence.

This letter advises you of our planned inspection effort resulting from the Palisades PPR process.

It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Enclosure 2 details our inspection* plan for the next 6 months. The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas. Resident inspections are not listed due to their ongoing and continuous nature.

9806030252 980527

~DR ADOCK 05000255 PDR r, -~* **t * *I\\~- L. '-~~)I

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We will inform you of any changes to the inspection plan. If you have any questions, please contact me at 630/829-9629.

Sincerely,

~~

Bruce L. Burgess, C~

Reactor Projects Branch 6 Docket No.: 50-255 License No.: DPR-20

Enclosures:

1.

Plant Issues Matrix Inspection Plan ccw/encls:

2.

Robert A. Fenech, Senior Vice President, Nuclear, Fossil and Hydro Operations Nathan L. Haskell, Director Licensing Department Richard Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Department of Attorney General (Ml)

Emergency Management Division, Ml Department of State Police

We will inform you of any changes to the inspection plan. If you have any questions, please contact me at 630/829-9629.

Sincerely,

/s/ Bruce L. Burgess Bruce L. Burgess, Chief Reactor Projects Branch 6 Docket No.: 50-255 License No.: DPR-20

Enclosures:

1.

Plant Issues Matrix Inspection Plan

2.

cc w/encls:

Robert A. Fenech, Senior Vice President, Nuclear, Fossil and Hydro Operations Nathan L. Haskell, Director Licensing Department Richard Whale, Michigan Public Service.Commission Michigan Department of Environmental Quality Department of Attorney General (Ml)

Emergency Management Division, Ml Department of State Police DOCUMENT NAME: G:\\PALl\\INSPPLN6.PAL To receive a OFFICE NAME DATE with att:achmentlenclosure "N"' = No OFFICIAL RECORD COPY

T. Palmisano Distribution:

CAC (E-Maii)

Project Mgr., NRR w/encls C. Paperiello, Riii w/encls J. Caldwell, Riii w/encls B. Clayton, Riii w/encls SRI Palisades w/encls DRP w/encls TSS w/encls DRS (2) w/encls Riii PR_R w/~

PUB~1 w/encls Docket File w/encls GREENS IEO (E-Mail)

DOCDESK (E-Mail)

PLANT ISSUES MATRIX Palisades ENCWSURE 1 5/22/98.

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" lw1 DATE 11 TYPE 11 1

3/31 /1998 VIO/SL-111 SOURCE IR 97014 EA 97-569 II 1D BY II SALP II MM CODE II DESCRIPTION 11 NRC Operations 1A 28 Page 1 of 22 A severity level Ill violation was issued on April 2, 1998, regarding conduct of operation and maintenance activities. Conduct of operations errors were made by a shift operating crew when power was removed from all of the control rod drives during power operation to facilitate the repair of a single control rod drive. These errors reflected significant weaknesses in pre-evolutionary preparations, communications, and A

• supervision that resulted in the breakdown of oversight and control of W' operations activities. Specifically, during the preplanning of this activity, the operating crew failed to implement a plant procedure mandating that a safety assessment be conducted to ensure the system configuration was acceptable for the current plant status. The crew incorrectly removed power from all of the control rod drives without communicating that system configuration to the shift supervisor. Five of the on shift licensed operators did not realize that removing power to all of the control rod drives, during power operation, was a system configuration that the Technical Specifications only permitted for a limited time.

Before removing power from all of the control rods, the operating crew erroneously referenced a previous tag out that had removed power from all of the control rod drives during shutdown conditions. The shift management team failed to exercise its oversight responsibilities by failing to stop the maintenance activity or expand the scope of the post maintenance test after observing a mechanic exceed the scope of the maintenance activity by removing and reinstalling additional relays. As a result, an inadequate post maintenance test was performed because t.

change in scope was not adequately communicated to maintenanee or

• operations personnel. When the expanded maintenance scope was discussed with the operations manager, the post maintenance test was still not revised to include the expanded maintenance scope (EA 97-569 cover letter 4/2198).

PLANT ISSUES MATRIX 5/22/98.

Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *0ate* ; Beginning Date = *10/1 /9r ; Ending Date = "3131198" lw1. DATE II TYPE II SOURCE II 1osv II SALP II MM CODE II DESCRIPTION II 2

3/31/1998 VIO/SL-111 IR 97014, EA 97-NRC Maintenance 1A 28 A severity level Ill violation was issued on April 2, 1998, regarding 567 conduct of operation and maintenance activities. Errors were made by maintenance personnel who failed to follow maintenance-related procedures when power was removed from all of the control rod drives during power operation to facilitate the repair of a single control rod drive. Before starting the repair, maintenance personnel incorrectly e documented that power to only one control rod drive motor was removed; the system configuration required by the maintenance procedure prerequisites. If maintenance personnel had complied with the procedure requirements and correctly verified the prerequisite, the work request could either have been deferred until the specified system configuration was established or changed to accommodate the expanded

(

work scope. During the repair, maintenance personnel inadvertently expanded the scope of the authorized work when they removed and reinstalled relays for three additional control rod drive motors. This was accomplished without documenting the additional work activity. The shift management team failed to exercise its oversight responsibilities by failing to stop the maintenance activity or expand the scope of the post maintenance test after observing a mechanic exceed the scope of the maintenance activity by removing and reinstalling additional relays. As a result, an inadequate post maintenance test was performed because the change in scope was not adequately communicated to maintenance or operations personnel. When the expanded maintenance scope was discussed with the operations manager, the post maintenance test wa-

~

still not revised to include the expanded maintenance scope. Inherent the failure of the staff to recognize the increased main~enance work scope and the need for additional post maintenance testing was the staffs incorrect interpretation that removing and inspecting the relays did not constitute maintenance that could adversely affect system operation (EA 97-567 cover letter 4/2/98).

3 3/13/1998 Positive IR 98002 NRC Operations 1A Conservative decision making was noted by the inspectors during plant startup and subsequent power escalation following emergent equipment problems. Plant response to emergent issues was prompt and appropriate actions were implemented (Section 01.2).

Page 2 of 22

PLANT ISSUES MATRIX Palisades S/22/98.

• Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" lwl DATE 11 TYPE 11 SOURCE 4

3/13/1998 Positive IR 98002 S

3/13/1998 Weakness IR 98002 6

3/13/1998 Negative IR 98002 7

3/13/1998 Positive IR 98002 8

3/13/1998 Negative IR 98002 9

3/13/1998 Positive IR 98002 10 3/13/1998 VIO/SL-IV IR 98002 II 10 BY II SALP II MM CODE II NRC Plant 1C 3A Support NRC Operations 2A 28 NRC Engineering 2A 5C NRC Operations 3A 1A NRC Maintenance 3A 2A NRC Maintenance 3A 28 NRC Operations 3A SB Page 3 of 22 DESCRIPTION Emergency Planning personnel effectively used an emergency drill to accomplish stated objectives and to conduct training. The problems associated with an untimely response of a search and rescue team identified last year was not evident during this drill (Section PS).

11 The inspectors noted that previously identified procedural weaknesses !Iii..

the cold weather checklist still existed. More significantly, the inspecto.

noted a large backlog of outstanding procedure change requests. The inspectors were concerned that the long delay of incorporating procedure changes would have a negative impact in that licensee personnel would be reluctant to submit additional needed procedure change requests.

Licensee management promptly allocated more personnel to the procedures group (Section 03.1).

The redundant capability of the instrument air system was good.

However, reliability of the compressors appeared to be a problem due to service water silting problems, which had not been addressed by the licensee (Section E2.1).

The crew used procedures appropriately and completed the mitigative actions in a timely manner for the inadvertent containment high radiation signal and resultant containment isolation signal. Crew communications, at times, were weak (Section 04.3).

Problems with control rod drive contactors continue. However, the A

problem associated with Control Rod Drive 3S was caused by an error

• reassembly of the contactor after cleaning and inspection. Post maintenance testing for CRD 3S was considered appropriate (Section M4.1).

Overall, good procedure adherence and maintenance work practices were noted. However, examples of weaknesses in post m.aintenance testing continued (Section M1.1 ).

The failure to property secure a watertight door in accordance with procedural requirements was a violation. Also, the inspectors identified several weaknesses in the initial evaluation of watertight door Number S9. The primary concern was a lack of safety focus associated with the engineering department's review of the undogged door. The re-review and proposed corrective actions were more thorough (Section 02.1).

PLANT ISSUES MATRIX Palisades S/22/98.

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "10/1/97" ; Ending Date = "3131198" lw1 DATE 11 TYPE 11 SOURCE 11 3/13/1998 Positive IR 98002 12 3/13/1998 NCV IR 98002 13 3/13/1998 Negative IR 98002 14 3/13/1998 NCV IR 98002 1S 1/27/1998 NCV IR 97018 16 1/27/1998 Positive IR 97018 II 1D BY II SALP II MM CODE II DESCRIPTION 11 NRC Operations SA 3A An independent team completed an audit in the area of operations.

Licensee Operations NRC Plant Support NRC Engineering NRC Engineering NRC.

Operations Overall, the audit team concluded that the operations department at Palisades was functioning effectively. The team reviewed individual procedure weaknesses and concluded they were minor. However, the number of outstanding procedure changes was a concern. The audit team's observations regarding procedures validated the inspectors a

concerns in this area (Section 07.1)

W SA SB SB The licensee identified a condition outside the design basis involving inadequate procedural guidance to ensure that high pressure air is restored during a LOCA concurrent with a loss of power to the high pressure air compressors. Prompt appropriate corrective actions were taken. This was considered a non-cited violation. (Section 03.2).

SA SC The inspectors identified a common misunderstanding among licensee personnel for the posted radiological requirements applicable to 2400 volt electrical Bus 1 C. Prompt and thorough corrective actions were taken (Section R8;1).

SB SC SA The licensee's review and root cause analysis of the circumstances surrounding the inadvertent CHR event were rigorous. This resulted in identification of a condition outside design basis regarding the containment radiation monitoring system. The proposed corrective actions were considered thorough. This was considered a non-cited violation (Section E7).

e 1A 28 48 During a closeout of a licensee event report, the inspectors identified a non-cited violation for failure to meet Technical Specifications testing requirements of the emergency escape air lock (Section E8.3).

18 38 58 The operators responded appropriately to a loss of component cooling water event that occurred on January 1, 1998. The licensee established an incident response team (IRT) to investigate the circumstances surrounding the event, and the inspectors concluded that the IRrs findings and proposed corrective actions were thorough. However, the inspectors identified several IRT weaknesses, most significantly, the team's lack of understanding of Generic Letter 91-18 regarding degraded conditions. The inspectors discussed the weaknesses with licensee management and concluded that the corrective actions taken or planned were adequate (Section 01.2).

Page 4 of 22

PLANT ISSUES MATRIX Palisades 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" 1w1 DATE 11 TYPE 11 SOURCE II 1D BY II SALP II MM CODE II DESCRIPTION 11 17 1/27/1998 VIO/SL-IV IR 97018

, NRC 18 1/27/1998 URI IR 97018 NRC 19 1/27/1998 ED IR 97018 EA 96-NRC 131 IR 97011 LER 97-010 Engineering 2A During follow up to a March 1997 failure of CV-3018 to reposition, the inspectors concluded that the corrective action for air line filter placement for pressure control valves (PCVs) was inadequate in that the licensee failed to correct a previously identified condition adverse to quality. The inspectors further concluded that placement of low point drains in the air lines leading to the PCVs was inadequate. The low po**

drain problem and the lack of corrective action for the air filter placem problem led to failure of CV-3018's air regulator. A violation of NRC requirements was identified (Section E1.1).

Maintenance 2A The inspectors concluded that the spent fuel pool maintenance activity to repair body to bonnet leaks on two valves, MV-SFP131 and MV-SFP132, was well planned and executed. However, the inspectors noted one deficiency in that the nuts and bolts on the valves were heat treated steel instead of stainless steel. An unresolved item was opened pending a review of the licensee's evaluation of the nuts and bolts (Section M1.2).

Engineering 2A 48 4C Three 10 CFR 50, Appendix R, issues were of concern because of the Page 5 of 22 safety significance associated with plant equipment configuring that did not meet 1 O CFR Part 50, Appendix R, safe shutdown requirements for a design basis fire. These issues would normally be designated as a Severity Level Ill problem in accordance with the NRC's NUREG-1600, "General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy). However, enforcement discretion will 9 used in accordance with Section Vll.8.3, "Violations Involving Old Design Issues," of the Enforcement Policy and a Notice of Violation will not be issued. The decision to apply enforcement discretion was based on consideration of the following: 1) significant NRC enforcement action (EA 96-131) was taken against the Consumers Energy Company for

• several examples of a failure to take prompt corrective actions related to Appendix R deficiencies. Palisades identified the issues detailed above and promptly notified the NRC; 2) corrective actions were immediate and encompassed the root causes for these issues; 3) some of the issues were related to activities that were in progress before the enforcement action was issued; 4) the issues would not be classified at a severity level higher than Severity Level Ill; and 5) Consumers Energy Company met with the NRC to explain their efforts to resolve these issues, which w~re outlined in their reply dated September 12,1996.

PLANT ISSUES MATRIX 5/22198.

Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" 1w1 DATE II TYPE II SOURCE II IDBY II SALP II MM CODE II DESCRIPTION II 20 1/27/1998 Positive IR 97018 NRC Operations 26 3A Following the discovery of a mispositioned valve at a nitrogen station, the licensee instituted an equipment status control record to enhance the operations department's control of equipment. To date, no discrepancies have been identified (Section 01.3).

21 1/27/1998 Negative IR 97018 NRC Engineering.

3A The inspectors concluded that the system engineer had adequately prepared to perform leak checks on the radwaste evaporator compone~

cooling water supply and return valves. However, the inspectors noted 1

that the system engineer did not communicate to the control room supervisor all of the activities performed in preparation of valve testing (Section E1.2).

22 1/27/1998 Positive IR 97018 NRC Plant 3A The inspectors concluded that radiological practices observed during the Support maintenance activities and plant daily walkdowns were adequate.

23 1/16/1998 Negative IR 97016 NRC Plant 1C Infrequent evolutions were generally well managed and expended Support reasonable radiation dose. However, the sludge solidification work exceeded the dose estimate partially due to the vendor's incorrect determination, based on cursory analyses, that sludge from the chemistry/laundry tank was compatible with the solidification process.

The posting of the entrances into two large areas in the Auxiliary Building were inconsistent with NRC guidance (Section R4.1).

24 1/16/1998 Weakness IR 97016 NRC Plant 1C 3A C&RS personnel* have experienced communication problems with other Support station departments. The C&RS management was aware of these e communication issues and indicated that there would be continued attention to improve the performance in this area (Sections R1.4, R4.1, R4~3. and R4.4).

25 1/16/1998 Positive IR 97016 NRC Plant 2A The make-up water system was well maintained and well managed, and Support the system effectively met plant needs for ultrapure water. The reliability and materiel condition of the various components were very good, as evidenced by the recent exceptional operating history (Section R2.1).

Page 6 of 22

PLANT ISSUES MATRIX 5/22198 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" IC!JI DATE II TYPE II SOURCE II IDBY II SALP II MM CODE II DESCRIPTION 11 26 1/16/1998 URI IR 97016 NRC Plant 2A The materiel condition and mechanical isolation perfonnance of the Support accident high range monitors was very good, as evidenced by surveillance testing. However, the C&RS staffs failure to change out this filter resulted in greatly exceeding the shelf life of the iodine cartridge and the radiochemistry laboratory did not have a calibrated geometry to analyze this cartridge. Discrepancies in various document-indicated inattention to. detail. As the licensee may not have been able to sufficiently detennine the iodine release in stack effluents under accident conditions, this issue is being considered an Unresolved Item (Section R2.4).

27 1/16/1998 Positive IR 97016 NRC Plant 2A The licensee conducted effective oversight of the control room heating, Support ventilation, and air conditioning system maintenance and operation. The required surveillances were satisfactorily completed and the various system components and equipment were in good working order (Section R2.2).

28 1/16/1998 Negative IR 97016 NRC Plant 2A The training and inventories for the post accident sample monitoring Support (PASM) system were conducted in accordance with procedure.

However, the perfonnance of the PASM has been generally unreliable for the past two years, as evidenced by continued materiel condition, sampling, and analysis problems. In particular, unreliable hydrogen analysis and the lack of verification that PASM samples are representative of the reactor coolant are being considered an Inspection-Followup Item (Section R2.3).

29 1/16/1998 Positive IR 97016 NRC Plant 2A

• Overall, the water quality for the primary and secondary systems was Support effectively controlled below industry guideline levels. Some primary coolant chemistry parameters did exceed recommended levels or listed procedural ranges, but the plant staff had established adequate technical reasons for these instances. Implemented and planned improvements indicated a strong commitment to excellent plant water quality (Section R1.1).

30 1/16/1998 Positive IR 97016 NRC Plant 2A SA Overall, the quality assurance and materiel condition of the laboratory Support and in-line instrumentation were very good, as evidenced by.function checks and laboratory inter/intracomparison data. However, staff experienced communication problems regarding calibration of the gamma spectrometry system and infrequent problems with various chemical analyses (Section R7.1).

Page 7 of 22

PLANT ISSUES MATRIX S/22198 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "1Of1197" ; Ending Date = "3131198" lw1 DATE II TYPE II SOURCE II IDBY II SALP II MM CODE II DESCRIPTION 11 31 1/16/1998 Positive IR 97016 NRC Plant 2B Station staff conducted effective oversight of the respiratory protection Support program, as the surveillances and maintenance were satisfactorily completed as required. The equipment was in good working order and was cleaned and stored appropriately. Personnel using the equipment were proper1y trained, medically qualified, and proper1y fit-tested 32 1/16/1998 VIO/SL-IV IR 97016 NRC Plant 3A (Section R1.3).

e One violation for the failure to post the high radiation area in the waste Support gas surge tank room was identified. Poor communications between the operations and Chemistry and Radiological Services (C&RS) departments was a significant contributing factor for this occurrence. In particular, the control room operators did not communicate sufficiently with C&RS regarding plant evolutions and the C&RS staff exhibited a narrow focus in their communications with operations staff (Section R1.4).

33 1/16/1998 Positive IR 97016 NRC*

Plant SA The Nuclear Performance Audit 'Department audit team was highly Support qualified, and the chemistry audit was extensive. This audit effectively identified areas for improvement and followed-up past issues to ensure proper resolution (Section R7.2).

34 1/16/1998 Positive IR 97016 NRC Plant SA The licensee's fuel integrity group effectively monitored a wide variety of Support chemistry parameters to ascertain the fuel integrity. In particular, the staff concluded that the current data indicated the existence of one fuel defect, which is probably a large pinhole leak. The inspectors conclude that the fuel integrity group utilized appropriate methodology for this determination (Section R1.2).

35 1/16/1998 Positive IR 97016

• NRC Plant SA ALARA post-job reviews were well done and these reviews demonstrated Support that the staff was appropriately critical of licensee performance in a variety of areas. The reviey.'ers identified several significant lessons learned which should enable the plant personnel to improve dose control for future outages (Section R4.2).

Page 8 of 22

PLANT ISSUES MATRIX 5/22198.

Palisades*

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" lw1 DATE II TYPE II SOURCE II 1DBY II SALP II MM CODE II DESCRIPTION II 36 1/13/1998 LER LER 98003 Licensee Operations 3A 1A Watertight door improper1y latched. A maintenance worker found watertight door #59 between the East and West Engineered Safeguards Rooms closed but not latched. Without being closed and latched, and with no personnel in the area to proper1y latch the door, the door could not have performed as designed. The door is part of the wall separating the East and West Engineered Safeguards Rooms and is relied upon t9 prevent a flooding event from affecting both rooms. The door is also required to maintain the fire barrier between the rooms.

37 1/12/1998 LER LER 98002 Licensee Engineering 4A 48 Potential challenge to channel separation. While making preparations for the 1998 refueling outage, it was discovered that channel separation between two nuclear instrumentation channels had been compromised during the 1996 refueling outage.

38 1/1/1998 LER LER 98001 Licensee Maintenance 2A Large leak of component cooling water during power operation. A component cooling water leak on the 'A' Radioactive Waste Evaporator Distillate Cooler increased from about 100 ml/min to about 200 gpm, which was more than the makeup capacity of the Component Cooling Water (CCW) system. The leak emptied the CCW Surge tank and resulted in a reduction in the normal CCW Discharge header pressure of about 120 psi to 98 psi. The operators used Off Normal Procedure 6.2 for Loss of Component Cooling Water and isolated applicable components. The leak was identified and isolated by the operators within about 15 minutes. No abnormal component temperatures were observed and no effect on the Primary Coolant Pump seals was identified. e 39 12/11/1997 Positive IR 97017 NRC Maintenance 28 An inspection follow-up item regarding the acceptability of proposed changes to the reliability criterion for the reactor protection system was closed.

40 12/11/1997 Positive IR 97017 NRC Maintenance 28 An inspection follow-up item regarding an evaluation of the reactor protection system for classification as category (a)(1) was closed.

41 12/11/1997 Positive IR 97017 NRC Maintenance 28 The licensee proper1y addressed all open items that were identified IR 97017 during the Maintenance Rule Baseline Inspection.

42 12/11/1997 Positive IR 97017 NRC Maintenance 28 For the three additional systems reviewed, the maintenance rule program was adequately implemented and the systems were

• appropriately classified.

Page 9 of 22

PLANT ISSUES MATRIX Palisades r;

.1,,.

5/22/98.

Search Sorted by Date (Descending) and SMM Codes (Ascending):* Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" ICiJI DATE II TYPE II SOURCE 43 12/1111997 Positive IR 97017 44 12/5/1997 VIO/SL-IV IR 97013 45 12/5/1997 Negative.

IR 97013 46 12/5/1997 Positive IR 97013 4 7 12/5/1997 Positive IR 97013 II 1D BY II SALP II MM CODE II DESCRIPTION 11 NRC Maintenance 28 NRC Operations 1 C Self-Operations 2A Revealed NRC Maintenance 28 NRC Maintenance 28 3A Page10of 22 An inspection follow-up item involving performance of periodic assessments, reliability-availability balances, and use of industry operating experience was closed.

The inspectors identified a violation in that procedure SOP-1, "Primary Coolant System," Revision 38, was inappropriate for the circumstances6 This procedure allowed the operators to start a primary coolant pump W without verifying that the Technical Specification requirements for starting forced circulation were met. The inspectors were concerned about the similarity of this event to an event identified in Inspection Report No. 50-255/97008 (Section 01.2).

The licensee was required to enter a second forced outage to repair relief valve RV-2013 bellows. An operator workaround for chemical volume and control system (CVCS) pressure control, in conjunction with material condition problems on the turbine stop valve bypass valves and an unusual eves system configuration, resulted in an RV-2013 bellows failure. The inspectors concluded that adequate corrective actions had been planned or taken to prevent recurrence of this problem (Section 01.2).

The inspectors noted that most maintenance was conducted in a professional and thorough manner. All work observed was done with the work package present and in active use. Work packages were comprehensive for the task and post maintenance testing requirement!A were adequate. The inspectors frequently observed supervisors and W' system engineers monitoring work. When applicable, work was done with the appropriate radiation control measures in place (Section M1.1).

The licensee's preparation for and conduct of the work for the main steam bypass valve repair was good. However, the inspectors noted a weakness in management oversight of the job. Once all preparatory work was done, no single individual had overall responsibility for scheduling and completing the repair (Section M1.2).

PLANT ISSUES MATRIX Palisades 5/22/98 Search Sorted by Date (DesCending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" 1w1 DATE 11 TYPE 11 SOURCE 48 1215/1997 Positive IR 97013 49 1215/1997 Positive IR 97013 50 12/5/1997 Positive IR 97013 51 11 /19/1997 Negative IR 97014 II 1D BY II SALP II MM CODE II NRC Engineering 48 NRC Engineering 48 NRC Plant SA Support NRC Operations 1A Page 11 of 22 DESCRIPTION 11 The engineering department's.operability evaluation and assistance for preparations for the repairs to main steam isolation valve (MSIV) M0-0510 were thoroug~. The engineering department's efforts had improved over those associated with previous similar MSIV repairs (Section E1.2).

The inspectors detennined that the licensee's actions were adequate tcA address the atmospheric dump valve hot short Appendix R scenario aP rebaselining of fire dampers and barriers. The inspectors also concluded that the Appendix R review team was adequately staffed and supported. However, the inspectors were concerned with plans to potentially reduce the Appendix R evaluation effort should resources be needed to support the upcoming 1998 refueling outage. The inspectors also stressed the importance of a timely response to the longstanding Appendix R issues (Section E1.1 ).

During an emergency preparedness drill, the licensee identified a deficiency involving a prolonged period of time before a search and rescue team was sent to find a simulated injured individual. The licensee stated that a review will be perfonned to correct the response timeliness concerns (Section P1.1).

Fortuitously, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> action statement requirements of Technical Specification 3.10.4.b was satisfied on October 17, 1997. The inspectors identified a concern regarding the Nuclear Control Operators failure to A question the appropriateness of removing power from all the control ro*

with the plant at power. (Section 04)

lw1 DATE II 52 11/19/1997 PLANT ISSUES MATRIX Palisades 5/22198.

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search. Cotumn = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" TYPE II SOURCE II IDBY II SALP VIO/SL-111 IR 97014 EA 97-NRC Maintenance 567 (see 3/31/98

• entry)

II MM CODE II 1A 26 Page 12 of 22 DESCRIPTION 11 A severity level Ill violation was issued on April 2, 1998, regarding conduct of operation and maintenance activities (see 3/31/98 entry).

Multiple apparent violations regarding maintenance activities occurred which included: (1) the failure to satisfy the control rod drive system conditions required by the maintenance procedure; (2) the failure to a identify that the maintenance activity could not be performed as W'

scheduled; (3) the failure to replan the work order prior to expanding the work scope; (4) the failure to revise the testing requirements after the work scope was changed; and (5) the faill,ire to document the work performed.

The causes of the failures included: (1) the Lead Electrical Repairman's inadequate review of the work order due to the apparent wfalse sense of comfortw regarding control rod #38 repairs; (2) the Lead Electrical Repairman acting as the Assigned Supervisor removed one level of independent review for the work order; (3) the Lead Electrical Repairman's, System Engineer's, and Shift Supervisor's apparent lack of understanding that the removal of control rod drive relay contacts was a maintenance activity that could affect control rod operability; and (4) the Lead Electrical Repairman's apparent lack of understanding that documenting the removal, inspection, and reinstallation of control rod drive relay contacts was required.

The number of failures that occurred indicated a programmatic breakdown regarding maintenance activities during control rod #38 repairs. (Section M1)

PLANT ISSUES MATRIX 5/22198 Palisades.

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column c "Date" ; Beginning Date = "10/1197" ; Ending Date = ?f.31198" lw1 DATE II TYPE II SOURCE II IDBY II SALP II MM CODE II DESCRIPTION 11 53 11/19/1997 EEi IR 97014 EA 97-NRC Operations 1A 28 A severity level Ill violation was issued on April 2, 1998, regarding 569 (see 3/31/98

• conduct of operation and maintenance activities (see 3/31/98 entry).

entry)

Multiple apparent violations regarding conduct of operation activities occurred which included: (1) the breakdown in crew communications; (2) the failure to ensure that equipment could be removed from service bye ensuring that Technical Specification limiting conditions for operations were met prior to removing the equipment from service; (3) the failure to complete the required risk-based assessment prior to maintenance; (4) the failure to perform operability testing following maintenance activities that had the potential to affect equipment operability; and (5) the failure to perform post maintenance testing prior to declaring equipment operable.

The causes of the failures included: (1) the crew's failure to question the appropriateness of removing power from all the control rods with the plant at power; (2) the crew's apparent "false sense of comfort" regarding control rod #38 repairs; (3) the crew's poor knowledge of Technical Specification 3.10.4.b; and (4) the Operations Manager's, Shift Supervisor's, and Shift Engineer's apparent lack of understanding that the removal of control rod drive relay contacts was a maintenance activity that could affect equipment operability.

There were several missed opportunities to identify the inappropriate e tagout and that work was performed outside the work order's scope.

Also, the number of failures that occurred indicated a programmatic breakdown in the conduct of operations activities surrounding the control

.rod #38 repairs. (Section 01) 54 11/19/1997 Negative IR 97014 NRC Operations 38 The October 17, 1997, "A" shift licensed operators' knowledge and understanding of TIS 3.10.4 was poor. (Section 04) 55 11/14/1997 Negative IR 97201 NRR NRC Engineering 2A 3A In several instances, the team observed that maintenance and operations support activities were not performed in accordance with plant procedures. Two scaffolds were erected in the vicinity of safety-related equipment without Engineering review, a storage cabinet was improperly located adjacent to safety-related piping and valves, a chainfall was stored adjacent to the shutdown cooling heat exchangers, and a ladder was improperly stored.

Page 13 of 22

PLANT ISSUES MATRIX Palisades 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "bate" ; Beginning Date = "10/1197" ; Ending Oate = "3131198" lw1 DATE 11 TYPE 11 SOURCE 56 11 /14/1997 Negative IR 97201 NRR 57 11/14/1997 Negative IR 97201 NRR 58 11/14/1997 Negative IR 97201 NRR II 1D BY.II SALP II MM CODE II DESCRIPTION 11 NRC Engineering 3A 28 NRC Erigineering 3A 4A NRC Engineering 4A Page 14 of 22 The team identified several valves that performed a safety function which were not included in the in-service testing (IST) program. Check valves in the high pressure SI (HPSI) pump minimum-flow recirculation lines, which prevented overpressurization of HPSI pump suction lines, were not tested to verify closure. There were requirements for closure of the safety injection tank vent valves and operation of the relief valve A inside containment on the CCW return line in the event of an accident.

• However, these valves had not been evaluated for inclusion in the IST program.

The team identified numerous deficiencies in the control and performance of calculations. Several calculations were not updated when analytical inputs changed, such as SI pump horsepower inputs to the emergency diesel generator loading calculation and load changes, which affected the main electrical load analysis. Errors in calculations included failure to consider specific uncertainty values in instrument.

setpoint calculations and a non-conservative initial air temperature in a room heatup calculation. Also, several instrumentation calculations failed to adequately identify the source of inputs; the calculation evaluating the effects of a high energy line break (HELB) on CCW piping did not contain adequate analysis to support the conclusion; and the 125-V de short-circuit calculation vyas issued without verifying all input parameters or providing any conclusion on the acceptability of the de system. Failure to maintain design-basis calculations current was A

apparently due, in part, to a weakness in the transfer of information W'

between engineering groups.

The team identified a modification that resulted in the capability for an automatic transfer between redundant safety-related electrical busses.

This capability was outside the licensing basis. Additionally, the 125-V de system electrical fault protection design implementation was not in accordance with the licensing basis in that the effects of short-circuit fault currents were not evaluated at the correct locations.

PLANT ISSUES MATRIX 5/22/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" lw1 DATE II TYPE II SOURCE II IDBY II SALP II MM CODE II DESCRIPTION 11 59 11/14/1997 Negative IR 97201 NRR NRC Engineering 4A The team identified many inconsistencies between the installed configurations of instrument tubing and the design basis in the CCW and SI systems. For example, the high-and low.., head SI flow transmitters were installed about 8 feet above the flow elements and the team believed that potential air entrapment in the sensing lines could cause significant and unquantifiable errors in the instruments. Information fro-these flow elements was used in postaccident monitoring and control activities.

60 11/14/1997 Negative IR 97201 NRR NRC Engineering 4A The licensee had no evidence that the CCW pumps met the vendor-recommended minimum flow requirement under all operating conditions. A preliminary analysis showed that the flow was adequate to meet a revised vendor recommendation. The team identified other instances in which the design basis was not adequately documented. No analysis was available to show that the de loads would operate at the minimum battery voltage stated in the FSAR; there was no analysis to show adequate ac voltage at the 120-V safety-related loads; there was no analysis to show that the battery could carry all required de loads during a design-basis accident with the battery chargers cross-connected.

61 11/14/1997 Negative IR 97201 NRR NRC Engineering 4A 48 Other discrepancies included a potential path for debris to bypass the containment sump screens, installation of incorrectly rated solenoid coils, incorrect implementation of the design-basis lifetime of Agastat time delay relays, incomplete evaluation of a 1 O CFR Part 21 notification concerning Agastat relays, and a missed surveillance for safety-related overcurrent relays. The team also identified a number of discrepancies in the FSAR, DBDs, and other plant documents.

62 11/14/1997 Negative IR 97201 NRR NRC Engineering 4A 48 Analyses had been performed, which identified that the CCW system could operate at temperatures in excess of the design-basis temperature, yet a complete evaluation of CCW system performance at these higher temperatures had not been done and the maximum postaccident CCW temperature had not been determined.

Page 15 of 22

PLANT ISSUES MATRIX Palisades

/r 5/22/98.

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" IGJI DATE II TYPE II SOURCE 63 11 /14/1997 Positive IR 97201 NRR 64 11/14/Hl97 Negative IR97201 NRR 65 11 /14/1997 Positive IR 97201 NRR 66 11110/1997 LER LER 97013 67 11n/1997 VIO/SL-IV IR 97015 II 1D BY II SALP II MM CODE II NRC Engineering 4A 4C NRC Engineering 4C NRC Engineering SC Licensee Maintenance 28 NRC Plant Support 3A Page 16 of 22 DESCRIPTION 11 Overall, the team found that the selected systems were capable of performing their design-basis safety functions, although some discrepancies were identified regarding adherence of the systems to their design and licensing bases. The DBDs reviewed provided comprehensive information for personnel involved in plant modifications and evaluations. Operability assessments performed during the course A of the inspection were comprehensive.

W The TS required one battery charger on each bus during normal operation; however, both chargers were disconnected during a monthly evolution of switching battery chargers, and a limiting condition for operation (LCO) was not entered. The team determined that the licensee's failure to enter an LCO during the battery switching evolution had minimal safety impact on the plant. Another TS concern identified was that the 2-hour battery test duration required by the TS appeared non-conservative compared to the 4-hour battery duration required by the design basis.

The licensee took appropriate actions to resolve the immediate concerns identified by the team. For other issues, the licensee initiated appropriate reviews and evaluations using *the corrective action process or initiated changes to documents.

Failure to closure test two check valves result in a violation of technical A specification 6.5.7. Check valves in the minimum flow recirculation 9

piping from the discharge of each High Pressure Safety Injection (HPSI) pump were not periodically tested to confirm their closure capability.

This is contrary to the requirements of ASME XI and Technical Specification 6.5.7.

Overall, postings in the plant were consistent with the radiological conditions documented on the radiological area status sheets. However, one violation for the failure to post a high radiation area was identified.

Other postings that were inconsistent or lacked the proper material to maintain the postings in place were also identified. The current contaminated area posting practice appeared to cause confusion for plant personnel and may have contributed to instances where rope barricades were found down at contamination areas throughout the plant (Section R1.1).

PLANT ISSUES MATRIX Palisades J/,,.

5/22/98.

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197' ; Ending Date = "3131198" 1w1 DATE 11 TYPE 11 SOURCE 68 1117/1997 VIO/SL-IV.

IR 97015 69 1117/1997 VIO/SL-IV IR 97015 70 1117/1997 Positive IR 97015 71 1117/1997 Positive IR 97015 72 10/25/1997 Positive IR 97012 II 1D BY II SALP II MM CODE II NRC NRC NRC NRC NRC Plant Support Plant Support Plant Support Plant Support Plant Support 3A 3A 38 58 1C Page 17 of 22 DESCRIPTION 11 Routine radiological surveys were generally done in accordance with station procedures, and the surveys were adequate to inform wor1cers of radiological conditions. However, three examples of a violation of Technical Specifications were identified as C&RS staff did not perform surveys to verify a high radiation area boundary or the extent and magnitude of contamination in the clean waste filter transfer room and*.

failed to forward survey data to the duty health physicist for review and*

signature (Section R1.2).

One violation for the failure of a health physics technician to be aware of dose rate levels or have a radiation dose rate meter prior to entry into a high radiation area was identified. The lack of a questioning attitude by experienced C&RS staff regarding the downed high radiation area posting, the failure to utilize available information to determine whether the downed high radiation area posting was correct, and the lack of a clear communication of management expectations were identified as weaknesses (Section R4.1).

Radiation protection training for plant personnel adequately addressed radiological and radiation protection issues. Several minor inconsistencies between training materials and plant procedures regarding contamination areas and radiological surveys were identified (Section R5.1).

The corrective action program was effectively implemented in e

accordance with station procedure. The root cause evaluation conducted in response to the high radiation area posting incident identified two violations and other significant problems. The recommended corrective actions appeared appropriate. However, some C&RS staff expressed a reluctance for initiating condition reports due to unclear management expectations (Section R7.1).

The radiological effluents program was well managed and implemented in accordance with the Technical Specifications (TS) and ODCM. Staff utilized appropriate sample collection and analysis methodology, and the licensee's dose assessment calculations demonstrated that offsite radiation dose to the public was well below regulatory limits. However, several procedures referenced an outdated TS amendment which indicated a lack of attention to detail by C&RS staff (Section R1.2).

PLANT ISSUES MATRIX Palisades r.-

S/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "10/1197" ; Ending Date = "3131198" lw1 DATE 11 TYPE 11 SOURCE 73 10/2S/1997 Positive IR 97012 74 10/25/1997 Positive IR 97012 7S 10/25/1997 Misc IR 97012 76 10/25/1997 Positive IR 97012 77 10/17 /1997 Positive IR 97011 11 ID BY II SALP II MM CODE II NRC Plant 1C Support NRC Plant 3A Support NRC Plant SA SC Support NRC Operations SC SA NRC Operations 1A Page 18 of 22 DESCRIPTION The radiological environmental monitoring programs (REMP) was well implemented in accordance with the Offsite Dose Calculation Manual (ODCM), and data showed that plant operations did not have a discernible radiological impact on the environment. Recent maintenance initiatives, coupled with a new type of charcoal cartridge, improved air sampling pump operability. Minor errors in REMP A

procedures indicated a lack of attention to detail by Chemical and W

Radiological Services (C&RS) staff (Section R 1.1).

The C&RS staff response to the abnormal gaseous release from the waste gas surge tank was appropriate, and the effluent dose calculations were accurate. In addition, the assessment of the total effective dose equivalent of the workers in the area of the release was thorough and comprehensive (Section R4.1).

Engineering staff effectively identified and adaressed a variety of problems regarding the waste gas system (WGS) operation and materiel condition which had caused operator work arounds and personnel contaminations. However, numerous problems remain with WGS material condition and due to concerns in this area Region Ill staff will continue to review licensee actions to minimize operator work arounds and radiological incidents (Sections R2.1 and R4.1).

The corrective actions for an inadequate procedure violation pertaining to handling solid radwaste were completed and plant personnel A

effectively implemented these actions during a recent spent resin sluiOO.

Additionally, the licensee's solid radwaste system design review and improvement plan identified significant component and process issues which were being addressed by plant staff (Section R3.1).

The licensee conservatively decided to shut down the plant due to a relatively minor increase in containment unidentified leakage. The inspectors noted that control room operators performed well in bringing the plant to hot shutdown.

PLANT ISSUES MATRIX 5/22198 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131/98" l~I DATE II TYPE II SOURCE II IDBY II SALP II MM CODE II DESCRIPTION II 78 10/17/1997 Positive IR 97011 NRC Operations 1A The inspectors concluded that the licensee provided good management oversight during the reactor startup, including the approach to critical with a reactivity manager and reactor engineering stationed onshift to augment shift coverage. Good conservative decision making took place on several occasions, specifically: to return the plant to a hot shutdown condition by inserting regulating rods during troubleshooting and repai~

to CROM 39, to insert all regulating rods when the ECP was not achieved with all control rods out, and to conduct a PRC meeting prior to continuation of a plant startup following the ECP discrepancy (Section 01.5).

79 10/17/1997 "NCV IR 97011 NRC Operations 1A 38 Operators failed to ensure that service water system valves were closed, which could have resulted in the potential draining of the component cooling water system in an Appendix R design bases fire. This resulted in the plant operating the facility outside the design bases for 10 days following discovery of the condition (Section 01.3). However, the inspectors reviewed this licensee's actions for this self-identified Item and determined this was a Non-Cited Violation consistent with Section Vll.8.1 of the Enforcement Polley (NCV No. 50-255/97011-02).

80 10/17/1997 Positive IR97011 NRC Operations 1A 48 The inspectors noted that operators were thoroughly prepared for a plant downpower and main turbine valve testing evolutions. Reactor engineering, system engineering and the procedure sponsor provided good support for these evolutions (Section 01.2).

e 81 10/17/1997 Negative IR 97011 NRC Maintenance 2A 1A The inspectors noted the operators were challenged by a number of emergent equipment problems during the plant shutdown. This was indicative that the licensee continues to struggle with plant material condition issues (Section M1.1).

Page 19 of 22

PLANT ISSUES MATRIX Palisad*es 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1197" ; Ending Date = "3131198" lw1 DATE 11 TYPE 11 SOURCE 82 10/17/1997 VIO/SL-IV IR 97011 83 10/1711997 Positive IR 97011 84 10/17 /1997 Positive IR 97011 85 10/1411997 Misc IR 97009 86 10/14/1997 Negative IR 97009 87 10/14/1997 Positive IR 97009 88 10/14/1997 Negative IR 97009 II ID BY II SALP II MM CODE II DESCRIPTION 11 NRC Maintenance 2B NRC Plant 2B Support NRC Engineering 4B NRC Operations 1A Licensee Operations 1A 3A Licensee Engineering 1 B 2A NRC Engineering 2B Page 20 of 22 The inspectors concluded that the maintenance procedure for repair of the waste gas surge tank was inadequate for the circumstances. The procedure allowed the waste gas surge tank to be vented to the auxiliary building atmosphere by allowing the gagging of relief valve, RV-1114, resulting in the contamination of five individuals during a routine VCT gas sample. The use of the procedure should have caused operators.

question the potential for a breach of the waste gas surge tank discha piping. Also, adequate equipment controls were not provided to prevent personnel contamination. The inspectors concluded that the use ofa fluted tap by maintenance personnel when a 2 inch threaded bolt was specified in the work procedure was inappropriate and contributed to the contamination of personnel (Section M1.2).

The licensee's actions to improve the resin transfer proce~ resulted in an error-free evolution for the spent fuel pool job (Section R1.1).

The inspectors found the compensatory measures taken for the identified Appendix R issues to be adequate. The Appendix R enhancement review was found to be progressing slowly. However, the review appeared to be thorough (Section E 1.1).

. The inspectors concluded that although the Consumers Energy load distribution center and the Michigan Electric Power Coordination Center are an integral part otthe Consumers Energy system, these organizations exert minimal influence on the Palisades facility. The A

Palisades facility is unique in that personnel maintain control of the W

Palisades switchyard to ensure additional reliability (Section 01.3).

Operators missed several opportunities to notify plant management of a step change in main turbine vibration (Section 01.2).

Licensee response was prompt and thorough to the step change increase in main turbine vibration (Section E1.3).

The* inspectors identified the potential for a shortage of available lubricating oil to supply the emergency diesel generator in the event of a design basis accident. In response, the licensee took prompt action and procured a sufficient amount of oil. Administrative controls were implemented to ensure a sufficient quantity of lubricating oil would be maintained (Section E1.2).

PLANT ISSUES MATRIX Palisades I

..~*

S/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Coiumn = "Date* ; Beginning Date = ~10/1197" ; Ending Date = "3131198" lriJI DATE II TYPE II SOURCE 89 10/14/1997 Misc IR 97009 90 10/14/1997 Positive IR 91009 91 10/14/1997 Negative IR 97009 92 10/12/1997 LER LER 97011 II ID BY II SALP II MM CODE II DESCRIPTION NRC Maintenance 28

• The licensee initially treated the turbine vibration sensitivity testing as a routine maintenance activity. Based on unexpected test results, the licensee.detennined that a more thorough procedure and pre-job briefing was needed. The second testing evolution was perfonned in an orderly manner with appropriate controls in place (Section M1.1).

11 NRC Engineering SA The inspectors concluded that the new perspective used by system e engineers to perfonn system health assessments resulted in identification of system perfonnance problems that would not have* been identified by using only the maintenance preventable functional failure criteria specified in the maintenance rule. Looking beyond the required maintenance rule indicators to detennine system perfonnance and incorporating support system perfonnance, showed a willingness of system engineers to be critical of their respective systems. (Section E1.4).

NRC Engineering SA SB SC The specific root cause for the "C" channel thennal margin monitor Licensee Operations 3A 1A Page 21 of 22 failures could not be conclusively identified. However, the licensee's final evaluation appeared adequate. The licensee missed several opportunities to address "C" channel failures in ear1y 1997 and was slow to focus adequate resources to solve the problem (Section E 1.1).

Starting of primary coolant pump with steam generator temperatures greater than cold leg temperatures.

5/22198 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC internal editing.

DATE The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. For issues that do not have an actual date or a date of identification, use the LER or inspection TYPE r-mort ~ate.

e ca egorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue inforrnation: IR for NRC Inspection Report or LER for Licensee Event Report IDBY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and AIUMultiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

DESCRIPTION Details of the issue from the LER text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Reauirements EEis are apparent violations of NRC 1

Operational Performance:

ED Escalated Discretion - No Civil Penaltv requirements that are being considered for A-Normal EEi*

Escalated Enforcement Issue - Waitinq Final NRC Action escalated enforcement action in accordance B - During Transients LER License Event Report to the NRC with the *General statement of Policy and C - Programs and Processes Licensinq Licensinq Issue from NRR Procedure for NRC Enforcement Action" Material Condition:

(Enforcement Policy), NUREG-1600.

2 Misc Miscellaneous (Emerqencv Preparedness Finding etc.}

However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes Neaative Individual Poor Licensee Perforrnance identified by the EEis and the PIM entries 3

Human Perforrnance:

Positive Individual Good Licensee Perforrnance may be modified when the final decisions A - Work Performance Strenqth Overall Strong Licensee Performance are made. Before the NRC makes its B - Knowledge, Skills, and Abilities URI**

Unresolved Inspection Item enforcement decision, the licensee will be C - Work Environment VIO/SL-1 Notice of Violation - Severity Level I provided with an opportunity to. either 4

Engineering/Design:

( 1 ) respond to the apparent violation or VIO/SL-11 Notice of Violation - Severity Level II (2) requeSt a predecisional enforcement A-Design VIO/SL-111 Notice of Violation - Severity Level Ill conference.

B - Engineering Support VIO/SL-IV Notice of Violation - Severity Level IV URls are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Performance more information is required to determine 5

Problem Identification and Resolution:

. whether the issue in question is an A - Identification IDBY acceptable item, a deviation, a

. B - Analysis nonconformance, or a violation. However, C - Resolution Licensee The licensed utility the NRC has not reached its final NRC

'The Nuclear Reaulatory Commission conclusions on the issues, and the PIM Self-Revealed Identification by an event( e.g., equipment breakdown) entries may be modified when the final conclusions are made.

Other Identification unknown Page 22 of 22

IP - Inspection Procedure Tl - Temporary Instruction PALISADES INSPECTION/ACTIVITY PLAN Core Inspection - Minimum NRC Inspection Program (mandatory all plants)

INSPECTION/

TITLE/

NUMBER OF NRC PLANNED ACTIVITY PROGRAM AREA INSPECTORS/

DATES INDIVIDUALS Various Outstanding Eng Item 1

5/25-6/8/98 Closure 92301/82302 Emergency Exercise 4

11/30-12/4/98 IP 37550 and Engineering Technical 4

7/6-20/98 40500 Support and Self Onsite Weeks 7/6 and Assessment/ Corrective 7120 Action Effectiveness IP 84750 Radiation Protection 1

7/13-20/98 IP 83750 Radiation Protection 1

9/28-10/5/98 EOP Inspection 1

11/16-11/23 IP 82701 Emergency Response 1

8/3-7/98 ENCLOSURE 2 TYPE OF INSPECTION/ACTIVITY-COMMENTS Regional Initiative Core Core Core Core Regional Initiative Core*