ML18066A346

Advises of Planned Insp Effort for Next 6 Months at Plant. Info Provided to Minimize Resource Impact on Staff & to Allow for Scheduling Conflicts & Personnel Availability to Be Resolved in Advance of Inspector Arrival Onsite

ML18066A346
Person / Time
Site:	Palisades
Issue date:	12/02/1998
From:	Anton Vegel NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 9812180114
Download: ML18066A346 (43)

Text

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rJ December 2, 1998 Mr. Thomas J. Palmisano Site Vice President and General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530

SUBJECT:

MID-YEAR INSPECTION RESOURCE PLANNING MEETING - PALISADES

Dear Mr. Palmisano:

On November 4, 1998, the NRC staff held an inspection resource planning meeting (IRPM).

The IRPM provided a coordinated.mechanism for Region Ill to adjust inspection schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in April 1999. to this letter advises you of our planned inspection effort for the next 6 months at Palisades.

This attached information 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. 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. contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM}, that was considered during the IRPM. The PIM includes only items from inspection

• reports or other docketed correspondence between the NRC and Consumers Power Company.

We will inform you of any changes to the inspection plan. If you have any questions, please contact me at 630-829-9620.

Docket No.: 50-255 License No.: DPR-20 Sincerely,

/s/ C. Phillips for Anton Vegel, Chief Reactor Projects Branch 6

Enclosures:

1.

2.

Inspection Plan Plant Issues Matrix See Attached Distribution DOCUMENT NAME: :G:\\pali\\insppln7.pal To receive a copy of this document. Indicate In the box *c* m Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No co y OFFICE Rill NAME DATE 1"

9812180114 981202 PDR ADOCK 05000255 G

PDR OFFICIAL RECORD COPY

CG w/encls:

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

Emergency Management Division, Ml Department of State Police

T. Palmisano Distribution:

CAC (E-Mail}

RPC (E-Mail}

Project Mgr., NRR w/encls J. Caldwell, Riii w/encls C. Pederson, Riii w/encls B. Clayton, Riii w/encls SRI Palisades w/encls DRPw/encls TSS w/encls DRS (2) w/encls Riii PRR w/encls

'. "PUBLIC IE-01 w/encls ~*

• Docket File w/encls GREENS IEO (E-Mail)

DOCDESK (E-Mail)

• 4, r I

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I

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

Regional Initiative - Discretionary Inspections NUMBER OF INSPECTION NRC I

TITLE I PROGRAM INSPECTORS/

PLANNED ACTIVITY AREA INDIVIDUALS DATES IP82301 EP Exercise 4

November 30 -

December4, 1998 IP81700 Security 1

January 11 - 15, 1999 Ti2515/140 Periodic* Verification 2

March 8-12, of MOV Capability 1999 IP82701 EP Program 1

April 26 - May 3, 1999 IP86750 Solid Radwaste 2

May 10-14, Management and 1999 Ti-.

• Regional Initiative to followup on Generic Letter 96-05 for non-JOG plant.

TYPE OF INSPECTION/

ACTIVITY-COMMENTS Core Core Regional Initiative*

Core

• Core

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date = '10/1/97' ; Ending Date = '9130/98' IC!Jl DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION If 9/2/1998 EEi IA 98018 Self-Plant 1C An apparent violation was identified concerning the failure to transport a Revealed Support package of radioactive material In accordance with 49 CFR 173.441, I.e.,

radiation levels on the external surface of the package exceeded the stated regulatory limits. However, due to indications that inherent problems with the cask may have been the cause for the violation, the e actual root cause of the violation could not be determined at the time of the inspection. (Section R1.1) 2 9/211998 Negative IA 980.18 NRC Plant 3A The shipping papers for the radioactive material shipment were prepared Support In accordance with regulations, plant procedures and expectations.

However, several aspects regarding both survey and documentation practices for the shipment did not meet either procedural requirements or management expectations, and the lack of normally available personnel resources contributed to these deficiencies. (Section R4.1 ).

3 8/24/1998 Positive IA 98015 NRC Operations 1A A "mixed" crew of oncoming and offgoing senior reactor operators and reactor operators demonstrated good teamwork and appropriately responded to an Inadvertent trip of 1 A main feedwater pump. The Control Room Supervisor demonstrated positive command and control during Implementation of the emergency operating procedures. (Section 04) 4 8/24/1998 Positive IA 98015 NRC Plant 1A The Inspectors concluded that the fire brigade responded to a minor Support electrical fire wearing the approJ.riate safety gear in a timely manner and that the post-fire critique was e active. A plant wide generic e

communication and a procedure change request appropriately addressed the licensee Identified deficiency regarding individual responsibilities for plant personnel during a fire. (Section F4) 5 8/24/1998 Positive IA 98015 NRC Maintenance 2A SA The Inspectors concluded that the troubleshooting plan for the 1 A main feedwater pump trip was timely and thorough and that the main feedwater system was being monitored against established performance criteria within the scope of the maintenanqe rule. The licensee determined that the Main Feedwater Pump 1 A main lube oil coupling failure was considered a maintenance preventable functional failure. (Section M2)

Page 1.of 39

PLANT ISSUES MATRIX 11/23198 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "10/1/97" ; Ending Date = "9/30198" 1w1 DATE II TYPE II SOURCE II IDBY II SALP 11 SMM CODES II DESCRIPTION II 6

8/24/1998 Positive IA 9801S NAC Maintenance 2B The inspectors concluded that the observed maintenance and surveillance activities were accomplished in accordance with plant procedures, and appropriately documented. However, the work control process did not adjust to account for a change In work scope during the installation of a new relief valve on the equipment drain tank. Immediate e corrective actions implemented by licensee personnel were considered appropriate. (Section M1).

7 8124/1998 Negative IA 980JS.

NAC Operations 2B 3A The Inspectors concluded that poor job planning by operations per5onnel led to the performance of a surveillance on the auxiliary feedwater system In conjunction with maintenance on a hotwell reject valve and caused.an unnecessary main feedwater system upset. (Section 01) 8 8/24/1998 Positive IA9801S NAC Engineering 48 SB Engineering support for the main feedwater pump trip troubleshooting plan and maintenance activities was timely and effective. The licensee's root cause analysis for the Main Feedwater Pump 1A trip was thorough.

(Section E2) 9 8/14/1998 Negative IA 98016 NAC Plant 1C With one exception, reviewed sections of the emergency plan and Support Implementing procedures were consistent with regulatory guidance.

Approved staffing commitments were not consistent with regulatory guidance. The EP staff is evaluating this issue. The emergency implementing procedures were yery detailed and thorough. (Section P3) e 10 8/14/1998 Positive IA 98016 NAC Plant 1C 3B Overall, the EP program had been maintained in an effective state of Support operational readiness. Management support to the program was apparent and interviewed key emergency response personnel demonstrated competent knowledge of responsibilities and emergency procedures. (General) 11 8/14/1998 Positive IA 98016 NAC Plant.

2A 1C The inspected emergency response facilities, equipment, supplies, and Support prompt alert and notification system sirens were well-maintained.

Semiannual augmentation tests have been acceptably conducted by the*

licensee. (Section P2.1)

12. 8/14/1998 Positive IA98016 NRC Plant 38 1C The EP training program was effective. Training was maintained current, Support and selected key emergency response organization personnel

• demonstrated competent knowledge of emergency responsibilities and procedures. All personnel reviewed were qualified for their emergency response positions. (Section PS)

Page 2 of 39

. PLANT ISSUES MATRIX 11/23198 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "10/1/97" ; Ending Date = '9/30198"

\\01 DATE II TYPE II SOURCE II IDBY II SALP II SMM CODES II DESCRIPTION 13 8/1411998 Positive*

IA 98016 NRC Plant SA The licensee's 1997 and 1998 EP program audits were effective and Support satisfied the requirements of 10 CFR SO.S4(t). (Section P7) 14 7/29/1998 Positive IA 98013 NRC Plant 1C During this Inspection period, minimal amounts of combustible material Support were noted In the*plant. The material condition of most fire protection e equipment appeared to be good. The fire brigade turnout gear lockers appeared to be well controlled and, with minor exceptions, contained the proper equipment. (Section F2.1) 1S 7/29/1998 Negative IA 9BOfa NRC Plant 1C A potential weakness was noted in the control of combustible materi.als in Support the plant. Individual work groups may bring in amounts of combustible material that are below the procedural limits. However, the accumulated effect of multiple introductions of combustible materials into a plant area are not monitored and may exceed established limits. In addition, the monthly fire protection inspections lacked rigor In that personnel had not toured all areas in the auxiliary building for five out of the last six months.

(Section F3.1) 16 7/29/1998 Positive IA 98013 NRC Plant 1C The performance of the observed fire drill was good. The training Support provided to the fire brigade appeared to be adequate. The annual physical examinations were kept up-to-date. (Sections F4 and FS) 17 7/29/1998 URI IA 98013 NRC Plant 4A The corrective actions modifying 16 MOV circuits for the conditions Support identified In Information Notice 9~-18 did not address the consequences of multiple hot shorts. The new cables/conductors, installed during the e modifications, remained susceptible to shorts to grounds and shorts between cable conductors. The current circuit design appeared to be contrary to the requirements of 10 CFR SO, Appendix R, Section 111.G.2.

This is an un*resolved item pending generic resolution of multiple hot short circuit analysis requirements. (Section F2.2) 18 7/29/1998 URI IA 98013 NRC Plant 4A The hydraulic calculation for the sprinkler system in the electrical Support equipment room contained an unverified assumption concerning the friction loss factor (C-factor). In addition, the licensee did not analyze the sprinkler system flow test data to ensure capability of the water supply.

This is an unresolved item. (Sections F3.2 and F3.3).

19 7/29/1998 Negative IA 98013 NRC Plant SA A weakness was noted with the audits performed by the Nuclear Support Performance Assessment Department (NPAD). The audit reports and checklists did not reveal substantive inspection in the area of penetration seals for the last three years. (Section F7)

Page 3 of 39

PLANT ISSUES MATRIX*

11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "10/1/97' ; Ending Date = '9/30/98' l~I DATE II TYPE II SOURCE II IDBY II SALP II SMM CODES 11 DESCRIPTION 20 7/24/1998 Positive IR 98012 NRC Engineering 4A 48 The team reviewed 24 modifications and nine temporary modifications and concluded that they were of good quality, properly installed and tested (Section E3.2).

21 7/24/1998 Positive IR98012 NRC Engineering 48 1A Surveillance Test Procedure M0-7A-1 for the diesel generator went e

beyond the specific warning contained in IN 97-16 to assure that any adverse condition found concerning liquid in the cylinders would be formally documented and evaluated (Section E2.1 ).

22 7/2411998 Positive IR 980°12 NRC Engineering 48 4C Overall, the 10 CFR SO.S9 screenings and safety evaluations reviewed for the past two years were of good quality and a good program had been established for ensuring that trained and qualified personnel prepared and reviewed SO.S9 screenings and safety evaluations (Section E3.1 ).

23 7/24/1998 Positive IR 98012 NRC Engineering 4C SA Overall, for the S1 CRs reviewed, the corrective actions taken were good and root cause determinatioris were effective. The team also noted that a low threshold existed for identifying problems and issuance of condition reports. However, two minor examples were noted where corrective actions could have been Improved (Section E 1.1 ).

24 7/24/1998 Positive IR 98012 NRC Engineering 4C SA The program for screening, analyzing and dispositioning industry experience Issues appeared to be effective; however, the team noted two examples where Engineering concluded that concerns were not applicable to Palisades becaus~ the conditions were not precisely the same as those at Palisades, rather than taking the broader view of how e and where there were similarities (Section E2.1 and E7.3).

2S 7/24/1998 VIO/SL-IV IR 98012 NRC Engineering 4C SC SA Although the need for testing of molded case circuit breakers had been licensee Identified In 1993, from review of industry operating experience Information, a testing program was not developed until 1997, after 44 of 72 molded case circuit breakers failed to trip during testing. The failure to assure that this condition adverse to quality was promptly identified and corrected was considered a violation (Section E2.1 ).

26 7/24/1998 Positive IR 98012 NRC Engineering SA The corrective action program at Palisades had shown improvements.in identification, resolution, and prevention of problems in the past two years. Personnel interviewed indicated a willingness to identify problems, considered the process to be owned equally by all plant staff, and did not consider CRs written against themselves to be negative. Overall, the licensee has been effective in the identification and resolution of problems (Section E7.2).

Page 4 of 39

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending):_ Search Column = "Date* ; Beginning Date = "10/1/97" ; Ending Date = "9/30/98" lC!JI DATE II TYPE II SOURCE II IDBY II SALP II SMM CODES 11 DESCRIPTION 11 27 7/24/1998 Positive IR 98012 NRC Engineering SA The team concluded that the Self-Assessment Program was effective and capable of providing valuable performance insights. The team also found that the audit program covered the required areas and was identifying problems and concerns. Audit findings were documented on condition reports, which were used for tracking and to obtain corrective actions. e

• Areas of concern Identified by audit findings were promptly and effectively corrected (Section E7.4).

28 7/24/1998 Positive IR980.12 NRC Engineering SC SB Based on interviews with station personnel and review of corrective action documents, the team concluded the licensee's corrective action, audit, and self-assessment programs were effective. The team concluded that quality assurance activities were of appropriate depth and scope (Section E7.1).

29 7/10/1998 Positive IR 98014 NRC Plant 1C The C&RS staff conducted the daily, monthly, and quarterly channel Support function checks of area and process radiation monitors in accordance with station requirements, and the results indicated that the monitors continued to perform as intended. The compensatory actions for inoperable process radiation monitors were properly performed, but issues regarding the challenge to and the guidance for chemistry personnel were identified (Section R2.2).

30 7/10/1998 Positive.

IR 98014 NRC Plant 1C The calibration program for the,area and process radiation monitors was Support well implemented, and the data indicated that the system electronics and e detectors functioned properly. No materiel condition issues were Identified, and the replacement of problem components improved system performance. However, a number of the process radiation monitor calibrations were performed into the Technical Specification extension period, and the plant management stated that this scheduling issue would be resolved (Section R2.1 ).

31 7/10/1998.

Positive IR 98014 NRC Plant 1C The Chemical and Radiological S~rvices (C&RS) and operations staffs Support effectively coordinated and controlled the activities associated with the fuel pool resin sluice. During the evolution, communication, surveys,

• ALARA measures, and system monitoring were thorough, and the task was successfully completed with a reasonable dose (Section R 1.1 ).

Page S of 39

PLANT ISSUES MATRIX 11/23198 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column.. 'Date' : Beginning Date = '10/1/97' : Ending Date = '9/30/98' 101 DATE II TYPE II S9URCE II IDBY II SALP II SMM CODES II DESCRIPTION 11 32 7/10/1998 Negative IA 98014 NRC Plant 1C 3A The management of the personal contamination monitors was effective, Support as evidenced by the successful completion of calibrations and operational checks at the required frequency.. However, an issue was identified regarding a security gate house PM-7 monitor which alarmed in an incorrect zone when the source was not located near that zone. In e

addition, the low limit fall setpoints for the PCM-18s were not set conservatively (Section R2.3).

33 7/1/1998 Positive IA 980.10 NRC Operations 1C The control room environment was professional and operator performance was generally good during plant startup activities. The procedure deficiency that was identified by a reactor operator during performance of a surveillance test, which prevented starting a charging pump with no suction source, was a positive. However, the operators apparently did not trend the appropriate parameters on the plant computer during performance of a different surveillance test which resulted in the failure to Identify that the refueling cavity level was slowly decreasing. This contributed to dumping 1200 gallons of water from the reactor cavity to the containment sump while the plant was In the refueling condition with shutdown cooling in operation (Section 04).

34 7/1/1998 Positive IA 98010 NRC Plant 1C Radiological practices observed during the maintenance activities and Support plant walkdowns were adequate (Section R8.1 ).

35 7/1/1998 Positive IA 98010 NRC Operations 2A 58 Sufficient progress was being made to decrease the number of "control room deficiencies" and "operations concerns.* None of the remaining e deficiencies would significantly challenge the operators (Section 02.1).

36 7/1/1998 Misc IA 98010 NRC Engineering 28 The licensee struggled with planning and execution of the primary coolant pump lube oil system modifications. The licensee is aware that planning and completing modifications is an area for improvement, but as yet has been unsuccessful In resolving the problems (Section E2.1 ).

37 7/1/1998 Positive IA 98010 NRC Maintenance 28 Overall, the inspectors observed during maintenance and surveillance activities, good procedure adherence and maintenance and radiation work practices (Section M1).

Page 6 of 39

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date = '10/1197' ; Ending Date = '9/30/98'

\\~I DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES 11 DESCRIPTION 11 38 7/1/1998 VIO/Sl-IV IR 98010 NRC Operations 3A 1A Proper plant configuration was not maintained during performance of surveillance refueling test (RT)-BC and while filling the safety injection tank bottles per SOP-4, Section 7.1.2. The improper plant configuration was self-revealing, indicated a weakness in equipment control, and was a violation of -

regulatory requirements. The self-revealing incident during performance of RT-BC resulted in pumping approximately 1200 gallons of water from the refueling cavity to the containment sump while the plant was in the

• refueling condition with the shutdown cooling system in operation. The licensee's audit of equipment control processes in response to the incidents was thorough and effective (Section 01.3).

39*

7/1/1998 NCV IR 98010 Licensee Operations 3A 1C The consequences of the momentarily misaligned rod during low power physics testing were minor; however, the incident was significant from a reactivity management standpoint and resulted in a non-cited violation of station operating procedures (SOP). In addition, the nuclear control operators did not implement self-checking techniques while performing reactivity manipulations. Equipment reliability problems, specifically the primary indicating position associated with the plant computer, contributed to the rod being misaligned. The licensee's review of this event in the followup to the condition report was viewed as adequate. Operations management instituted appropriate corrective actions to prevent recurrence in a timely manner. ftowever, the initial actions taken by the on-shift crew to determine the cause were considered weak (Section e 01.2).

40 7/1/1998 NCV IR 98010 Licensee Engineering 30 Licensee personnel continue to struggle with basic Technical Specification requirements and their applicability to plant equipment as evidenced by engineering personnel's lack of understanding of what constituted a Technical Specification functionaltest. This lack of understanding contributed to the failure of surveillance procedure P0-1 to test the high startup rate trip and is* considered a non-cited violation. The licensee's review of the event was found to be adequate. However, this event underscored the necessity that all plant personnel need to fully understand Technical Specification. requirements (Section E2.2).

41 7/1/1998 NCV IR 98010 Licensee Engineering SA Inadequate auxiliary feedwater pump low suction pressure trip setpoints (Section EB.4).

'Page 7 of 39

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date ;. *1011197* ; Ending Date = "9130/98" 1w1 DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES 11 DESCRIPTION 42 7/1/1998 Positive IA 98010 NRC Operations SA SB SC There were no unplanned losses of shutdown cooling and the shutdown operations plan was complied with during the outage. Plant management's decision to restart the plant with one stage of a primary coolant pump seal In apparent failure was based on several factors Including the associated risk (Section 01.1 ).

e 43 7/1/1998 Positive IR 98010 NRC Maintenance SB SC The Inspectors have documented past performance Issues with the main turbines and generator. However, the licensee's plans addressed the Inspectors' reliability concerns with the main turbine and were adequate (Section M2.1 )..

44 6/4/1998 NCV IR 98011 Licensee Engineering 4A Class 1 E and non-Class 1 E circuits were not isolated or separated as required by the FSAR (Section E8.8) 45 6/4/1998 NCV IR 98011 Licensee Engineering 4A The EOG fuel oil supply and associated piping did not meet licensing basis (Section E8.7).

46 6/4/1998 URI IR 98011 NRC Engineering 48 The engineering staff was effective in the identification and resolution of technical Issues. However, concerns were identified regarding the licensee's review of a non-environmentally qualified cable and the lack of a qualified three-hour fire barrier where redundant safe shutdown circuits were routed In close proximity (Sections E8.15 and E8.16; unresolved Item (URI) S0-25S/98011-03 and URI S0-255/98011-04, respectively).

47 6/4/1998 Positive IR 98011 NRC Engineering SB SC Corrective actions and root cause analyses were acceptable (all sections).

48 6/4/1998 Positive IR 98011 NRC Engineering SC 4B System engineering Involvement in the corrective action process was good (all sections).

49 6/1/1998 Positive IR98009 NRC Plant 1C The ALARA/work planning and implementation for the hot spot retrieval Support from the reactor floor vacuum was well done. The pre-job brief was thorough, the work control was eff~ctive, and the task was accomplished.

for 55% of the dose estimate (Section R4.3).

Page 8 of 39

IGJI DATE II 50 6/1/1998 51 6/1/1998 52 6/1/1998 53 6/1/1998 PLANT ISSUES MATRIX Palisades 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column_= "Date" ; Beginning Date = "10/1/97" ; Ending Date = "9/30/98" TYPE II. SOURCE NCV IA 98009 Strength IA 98009 Negative IA 98009 VIO/SL-IV IA 98009 II 1D BY II Licensee NRC

_NRC SALP Plant Support Plant Support Plant Support Plant Support II SMM CODES II DESCRIPTION 1 C

• The Chemical and Radiological Services (C&RS) staff effectively controlled and monitored airborne, discreet particle, and general contamination resulting In minimal skin dose. Improved housekeeping reduced the generation of radwaste. Controls for water clarity and tilt pit 1C 1C 3A drain line contamination were greatly improved. Although ventilation use ~

- was effective, one Non-Cited Violation (NCV) was identified for the failure -

to label the power cords to prevent inadvertant unplugging (Section R1.1).

The development of ALARA plans and RWPs was greatly improved over past outages. ALARA initiatives for REFOUT98 saved approximately 6.1 rem and staff conducted In-Progress ALARA reviews well before the threshold dose to better determine the source of the unexpected dose.

Although 8% higher than estimated, the REFOUT98 dose was 20% below the previous outage and included minimal rework dose (Section R1.2).

Since documentation of past industry events in NRC Information Notices refer to previous problems raised about communication problems between operations and radiation protection, the failure of the operations and contractor staff to*effectively coordinate or communicate the movement of Irradiated in-core instruments with C&RS was evidence of

• continuing communication problems, and indicated a weakness in the work planning process (Sectio~R4.5).

• 1C 3A SC A review of REFOUT98 radiological incidents and condition reports, and &_

• Interviews with health physics technicians, indicated that there was Inadequate oversight of outage activities - particularly for work conducted Page 9 of 39 by contract personnel. THREE violations (with multiple examples) of basic radiation protection requirements were identified. Although the immediate corrective actions were adequate, the number of incidents indicated that the C&RS needs to be more proactive in communicating and implementing the radiation pretection program at the station (Section R4.2).

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column.. "Date" ; Beginning Date = '10/1197" Ending Date = "9/30/98' lC!JI DATE II TYPE II. SOURCE II IDBY II SALP 11 SMM CODES II DESCRIPTION II 54 6/1/1998 Positive IA 98009 NAC Plant 2A The licensee successfully completed crud bursts during an earlier cold Support shutdown In 1998 and in AEFOUT98, which reduced the primary coolant system (PCS) source term by approximately 500 curies. However, the reduction of steam generator dose rates was less than expected. The use of new resins improved PCS lithium removal and Installation of 0.1 a micron PCS filters should further reduce the source term (Section A1.3).

55 6/1/1998 Negative IA 98009 NAC Plant 3A Although there was not a substantial potential for excessive radiation Support exposures, the staff failed to effectively communicate important radiological Information, failed to establish a radiological hold point, and failed to ensure a common understanding of the radiological conditions for a filter basket transfer cask. Although radiological controls prevented any regulatory dose limits from being exceeded, the staff missed several opportunities to improve the process (Section A4.4).

56 6/1/1998 NCV IA 98009 Licensee Plant 3A 1C Overall, radworker practices were acceptable. However, there were Support several instances of Inappropriate radworker practice during both normal operations and AEFOUT98 which Indicated a poor understanding of radiation protection requirements and expectations. The C&AS staff was proactive in Identifying and correcting problems in the field. Two NCVs were identified for a downed high radiation area barricade and unauthorized high radiation area work on an incorrect AWP (Section A4.1).

57 5/14/1998 Negative IA 98006 NAC Maintenance 2A The Inspector considered the material condition of safety-related systems near the 607 foot elevation of containment generally good. However, the inspector Identified a severely corroded component cooling water flange to the reactor coolant pump P-50A, which the licensee had not previously Identified. (Section M2.1) 58 5/14/1998 Positive IA 98006 NAC Maintenance 28 Overall, the Inspector concluded tbat the licensee's implementation of the lnservice Inspection Program was consistent with Code requirements and NAQ relief request commitments. The inspector considered the use of a

~mera mounted on a robot to perforlT! under-vessel VT-2 examinations to demonstrate an innovative alternative to sending personnel into this radiation dose intensive confined space. The inspector considered the licensee's use of Performance Demonstration Initiative qualified ultrasonic examination techniques to demonstrate a commitment to a quality lnservice Inspection Program. (Section M7.1)

Page 10 of 39

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' : Beginning Date = '10/1/97' ; Ending Date = '9130198'

\\C!JI DATE II TYPE II SOURCE II IDBY II SALP II SMM CODES II DESCRIPTION 11 59 5/14/1998 Positive IA 98006 NRC Maintenance 28

. The inspector considered the use of automated ultrasonic examination equipment and refracted longitudinal wave transducers to be a proactive effort that demonstrated the licensee's commitment to a quality lnservice Inspection Program. Ultrasonic examination of welds potentially susceptible to thermal fatigue cracking (beyond the minimum welds e*

required by Code), demonstrated the licensee's commitment to safety.

(Section M1.2) 60 5/14/1998 Positive IA 98006 NRC Maintenance 28 The eddy current examination scope and methods met or exceeded the Technical Specification requirements and were consistent with licensee responses to GL 95-03 and GL 97-05. Contractor personnel acquiring eddy current data used state-of-the-art industry qualified techniques, were

. knowledgeable and performed eddy current examinations. In accordance with the approved procedures. (Section M1.1) 61 5/14/1998 Negative IA 98006 NRC Maintenance 28 The inspector Identified an inspection followup item pertaining to the licensee's practice of crediting full Code volumetric coverage for single sided ultrasonic examination of welds, which does not appear appropriate for austenitic materials. Additionally, the lnservice Inspection Program documents lacked requirements to control implementation of alternatives to Code nondestructive examination methods, which the inspector considered an opportunity for lnservice Inspection Program improvement. (Section M7.1)

• 62 5/14/1998 Negative IA 98006 NRC Maintenance 28 The inspector identified a lack of independent field observation with e*

qualified personnel during audits of past and present lnservice inspection

~ctivities, which demonstrated a substantial weakness in the Nuclear Performance Assessment Department Program for the conduct of performance based audits of the lnservice Inspection Program. (Section M7.2) 63 5/14/1998 Negative IA 98006 NAC Maintenance 28 The inspector found that the inserv.ice inspection procedures and data recorded for examinations witnessed in Section M1 were in accordance with Code requirements. However, the inspector identified that EM-09-05 "Steam Generator lnservice Inspection,* Revision 7, contained an unused option to leave steam generator tube eddy current indications in-service, that was not consistent with plant operation focused on safety.

(Section M3.1)

Page 11 of 39

PLANT ISSUES MATRIX 11/23198 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column*= "Date* ; Beginning Date = "10/1/97" ; Ending Date = '9/30/98' lw1 DATE II TYPE II SOURCE II ID BY II SALP llsMM coDEsll DESCRIPTION II 64 5/14/1998 Positive IA 98006 NAC Maintenance 20 30 The licensee inservice inspection personnel performing nondestructive examination of Code Clas*s 1 and 2 pipe welds and component supports were well prepared, well trained and conducted a thorough examination in accordance with the approved procedures. (Section M1.2) 65 5/14/1998 IA 98006 NAC

_Engineering 4C The inspector concluded that the scope of the licensee's steam generator -

tube repairs were conservative with respect to Technical Specification requirements. However, the limited scope of the foreign object search and retrieval inspection of the secondary side of the steam generators demonstrated a less than comprehensive effort. (Section E2.1) 66 518/1998 Negative IA 98008 NAC Plant 3A 1C The inspector identified that the effectiveness of the package search Support program was reduced because physical searches of certain packages were generally conducted in a superficial or cursory manner. (Section S1.1)

67.

5/8/1998 Negative IA 98008 NAC Plant 3A 5A **

The inspector identified that required reviews of some security and Support contingency procedures were not documented. The licen_see initiated corrective measures to ensure that completed procedure reviews are

. properly documented. (Section S3.1) 68 5/8/1998 Positive IA 98008 NAC Plant

. 3A 50 5C Security personnel generally demonstrated an appropriate level of Support awareness and knowledge of security requirements to effectively implement security plan requirertients and to respond to routine security issues and reactive problems. Security management was properly 9*

focused to address security issues. (Section S4) 69 5/8/1998 Negative IA 98008 Licensee Plant 3A 5C The licensee Identified a failure to properly implement compensatory Support measures in a timely manner. The event appeared to be an individual security supervisor personal error caused by weak attention-to-detail and a failure to use procedure guidance~ Corrective action was comprehensive and implemented in a timely manner. (Section S8.5) 70 5/6/1998 Positive IA 98005

• NAC Operations 1A The control room access was well controlled which eliminated unnecessary distractions to the operators. Control room manning exceeded Technical Specification requirements. The plant was operated in a c_onservative manner while the turbine control system was in an off-normal configuration. The inspectors identified weaknesses in control room log keeping and noted that licensee management had targeted *this as an area which needed improvement. (Section 01.2)

Page 12 of 39

PLANT ISSUES MATRIX Palisades 11/23198 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = ~10/1/97" ; Ending Date =

0 9130/98° 101 DATE II TYPE II 71 5/6/1998 Positive 72 5/6/1998 Positive 73 5/6/1998 Positive 74 5/6/1998 Negative 75 5/6/1998 Negative SOURCE IA 98005 IA 98005 IA 9~005 IA 98005 IA 98005 IR 98005 II ID BY II SALP II SMM CODES II NAC Operations 1 A NAC

. Operations 1 B

• NAC Plant 1C Support NAC Maintenance 2A NAC Operations 2A 1 A Page 13 of 39 DESCRIPTION The control room operators successfully operated the plant while the*

turbine control system was restricted to an off-normal, manual mode of operation. (;oordination among crew members was good during those activities performed to shut down the plant for the scheduled refueling outage. The crew transferred feed to the steam generators from the main A feedwater system to the auxiliary feedwater system during the plant 9

shutdown without causing an unnecessary transient which reflected Improved performance from past evolutions. (Section 04)

The actions taken In response to the unknown status of main turbine stop Valve #1 were appropriate and ensured positive control of the valve.

Closing and Isolating hydraulic fluid to main turbine stop Valve #1 and governor Valve #1 was considered prudent In preventing a potential turbine overspeed condition that could result from a failure of governor Valve #1 to close following a turbine trip. (Section 02)

The Inspectors concluded that radiological practices observed during maintenance activities and plant daily walkdowns were adequate.

(Section A8.1 )

Several examples of maintenance cleanliness and foreign material exclusion Issues were Identified by licensee personnel during the early stages of the outage. lndlviduavy. the identified cleanliness and foreign material exclusion issues were considered minor; however, collectively they indicated that additional management attention in this area was A

warranted. (Section M1.1)

W Plant operations was challenged with continued equipment reliability issues. Specifically, main turbine stop Valve #1 and governor Valve #1 were closed and hydraulically isolated due to inadvertent partial closure and subsequent opening of turbine stop Valve #1. This resulted in placing the turbine control system Jn an off-normal, manual mode of operation. In addition, the licensee had previously taken a turbine generator electrohydraulic control system pump out-of-service (February 16, 1998) due to a leak in the discharge flow instrument. (Section 01.1)

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending):

~earch Column.. "Date" ; Beginning Date = "10/1/97" ; Ending Date = "9/30198' lw1 DATE II TYPE II SOURCE II ID BY II SALP llsMM coDEsll DESCRIPTION 76 5/6/1998 VIO/Sl-IV IA 98005 NAC Maintenance

• 2A 28 The Inspectors Identified that no foreign material exclusion covers were Installed on the emergency diesel's generator access covers and no maintenance personnel were present to maintain positive foreign material exclusion controls. Also, the inspectors identified that inadequate procedural requirements existed for foreigri material exclusion controls e pertaining to electrical components which was a violation of regulatory requirements. (Section M3) 77 5/6/1998 Positive IA 98005 NAC Maintenance 28 The planned work scope for the 1998 refueling outage should not be challenging for the licensee to safely accomplish. The level of planning and preparation was thorough and complete. However, the inspectors noted that some longstanding equipment problems were deferred.

(Section M1.3) 78 5/6/1998 Positive IA 98005 NAC Maintenance 28 3A Overall, the Inspectors observed, during maintenance and surveillance activities, good procedure adherence, and maintenance and radiation work practices. (Section M1.2) 79 5/6/1998 Negative IR 98005 NRC Engineering 38 48 The licensee relied on vendor representatives rather than in-house knowledge of the turbine control systems. Also, some licensee engineering personnel did not understand the operational design for the auxiliary feedwater Yokagowa flow controllers. This Indicated an apparent knowledge weakness on behalf of engineering personnel regarding auxiliary feedwater flow controllers and the turbine generator 9..

control systems. (Section E4) 80 5/6/1998 Positive IA 98005 NAC Engineering 48 Engineering personnel were frequently challenged with emergent equipment reliability issues. Specifically, engineering personnel had to respond to and support emergent work pertaining to containment air locks,-turbine control systems, and auxiliary feedwater flow controller operational issues. Engineering personnel responded to and su1worted these activities In a timely manner.. (Section E1.1) 81 5/6/1998 Positive IA 98005 NAC Engineering 48 4C The inspectors noted that the follow-up to correct identified deficiencies.

with inservlce testing requirements was thorough. However, system engineering supervision relied on engineering personnel to identify errors In the IST program data base. (Section E2)

Page 14 of 39

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" : Beginning Date ;. "10/1/97" ; Ending Date = "9130198" 1w1 DATE II TYPE II SOURCE II ID BY II SALP 11 SMM CODES II DESCRIPTION 82 5/6/1998 Positive IA 98005 NRC Maintenance 5A The personnel air lock Technical Specification amendment should benefit the licensee if personnel air lock operability problems arise in the future.

However, the inspectors discussed with the licensee the need for maintenance and system engineering personnel to ensure corrective actions adequately address reliability of the personnel and emergency air e locks due to the safety significance of these components regarding containment integrity as well as personnel safety. (Section M2.1) 83 4/10/1998 DEV IA 98003 NRC Engineering 4A 5A A deviation from a commitment to Regulatory Guide (RG) 1.97 was Identified when CCW flow could not be measured from 0-11 O percent of flow using the listed temperature instruments because their Indication range was 0-180 F and recent sensitivity studies indicated that the outlet temperature of CCW from the shutdown cooling heat exchanger would be

• 184 F.

84 4/10/1998 VIC/SL-IV IA 98003 NRC Engineering 4A SA A violation was identified for problems with the original plant design: Two vent pipes, which connected the containment sump to the 590 ft elevation of the containment, did not have screens installed which were specified by the original design drawings. This piping configuration resulted In a pathway for debris to enter the recirculation system without being filtered by the containment sump screens with a potential to clog the containment spray nozzles. A second example of this violation involved instrument tubing to the HPSI and LPS flow.transmitters that did not have the one Inch per foot slope specified by the original design drawings.

e 85 4/10/1998 VIC/SL-IV IR 98003 NRC Engineering

48. 3A Failure to follow procedures resulted in a violation. An unsecured operations storage cabinet was found within nine feet of safety related valves CV-737 and CV-0747A in the west engineering safeguards room which was less than the procedure required 11.5 feet (cabinet height +5 feet).

86 4/10/1998 VIC/SL-IV IR 98003 NRC Engineering 48 3A Failure to follow procedures result~d in a violation. Test results could not be located to verify that testing had been completed during the 1995 refueling outage for overcurrent relays for supply breakers 152-105 and 152-106 to Bus 1C as required by the procedure.

Page 15 of 39

i*

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "10/1/97' ; Ending Date = '9/30198'

\\CiJI DATE II TYPE II SOURCE II ID BY II SALP llsMM CODEsll DESCRIPTION 11 87 4/10/1998 VIO/SL-IV IA 98003 NAC Engineering 48 3A Failure to follow procedures resulted in a violation. Engineers failed to document justification of the acceptability of scaffolding installed adjacent to the safety related safety injection and refueling water tank and in the east engineering safeguards (ESG) room adjacent to safety related piping as required by the procedure.

e 88 4/10/1998 VIO/Sl-IV IA 98003 NAC Engineering 48 3A SA Failure to follow procedures resulted in a violation. Five examples were identified where recent safety related calculations were not revised when analytical inputs changed or were found to be in error as required by procedures.

89 4/10/1998 VIO/Sl-IV IA 98003 NAC Engineering 48 4C A violation was identified for a recent failure to scope and include in the inservice testing program, eight valves with specific functions in shutting down the reactor to a cold shutdown condition, in maintaining the cold shutdown condition, or in mitigating the consequences of an accident.

90 4/10/1998 DEV IA 98003 NAC Engineering 48 SC A deviation from a commitment to AG 1.6 was identified when a design change moved the backup power source to a redundant power source,.

which resulted in 8usY-01 being able to automatically transfer between two safety related busses.

91 4/10/1998 Positive IA 98003 NAC Engineering SC Good progress had been made in addressing the individual issues from the Design Inspection conducted from September 16 through November 14, 1997; however, the collective significance of the issues was still being.

reviewed.

e 92 4/1/1998 Positive IA 98004 NAC Operations 1A The control room had a quiet, business like environment in which operators could conduct control room operations. The control room operators were professional and maintained the appropriate focus on plant evolutions In progress. The large number of control room panel caution tags could potentially have a detrimental effect on efficient plant operations. (Section 01.1) 93 4/1/1998 Positive IA 98004 NAC Operations 1C Operator license conditions were in conformance with program guidance and regulatory requirements. (Section OS.6) 94 4/1/1998 Positive IA 98004 NAC Operations 1C

. Mechanisms for feedback of performance weaknesses to the operators and training staff existed. The training program feedback process appeared to be satisfactorily implemented. (Section OS.4)

Page 16 of 39

PLANT ISSUES MATRIX 11/23/98 Palisades*

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "10/1/97" ; Ending Date = '9/30/98" lw1 DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION 95 4/1/1998 Negative IR 98004 NRC Operations 1C 3A The licensee aqministered the operating examination in accordance with their program guidance, and regulatory requirements. The licensee displayed.several attention to detail weaknesses and a failure to apply a rigorous standard during performance evaluations. The licensee's JPM validation process failed to identify poorly written procedures before they e were administered during the annual requalification examination. The licensee had an effective operating examination security program.

(Section 05.3) 96 4/1/1998 Negative IR 98004 NRC Operations 1C 3A SA Operator performance during the annual requalification examination.

demonstrated a lack of commitment in complying with the facility's conduct of operations procedures. Communications activities during crew briefs and routine operations did not consistently meet the licensee's expectations. Operators and training staff tolerated poorly written procedures and failed to identify those procedures for revision. (Section 01..1) 97 4/1/1998 VIO/SL-IV IR 98004 NRC Operations 1C 38 The quality of the Category B examination questions was poor and.

resulted in a Level IV violation. The operating examinations (Job Performance Measures (JPM) and dynamic simulator scenarios) were generally at the appropriate level of difficulty to distinguish between competent and non-competent operators. The quality of the dynamic simulator scenario could be imprpved by consistently providing expected operator actions to evaluators and developing challenging technical specification problems. (Section OS.2) e 98 4/1/1998 Positive IR 98004 NRC Operations 1C SC The remediation program was being implemented in accordance with the licensee's program and regulatory requirements. (Section 05.S) 99 4/1/1998 Negative IA 98004 NRC Operations 3A 1C Operator error related events were not directly attributable to inadequate or ineffective traini~g. but rather due to a lack of application of training on the part of the operators. (Section.05.1)

Page17 of 39

1w1 DATE II 100 3/31/1998 PLANT ISSUES MATRIX Palisades.

11/23198 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = '10/1/97' ; Ending Date = '9/30/98' TYPE II SOURCE II ID BY II SALP II SMM CODES II VIO/Sl-111 IA 97014 EA 97-NRC Operations 1A 28 569 Page 18 of 39 DESCRIPTION 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 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 froin 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 observin~ 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 A change In scope was not adequately communicated to maintenance or W

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 4/2/98).

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column c 'Date' ; Beginning Date = '10/1/97' ; Ending Date = '9/30/98' IC!JI DATE II TYPE II SOURCE II IDBY II SALP II SMM CODES II DESCRIPTION 11 101 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.

• e

• Before starting the repair, maintenance personnel incorrectly 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 tp maintenance 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. Inherent in the failure of the e staff to recognize the Increased maintenance work scope and the need for additional post maintenance testing was the staff's 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).

102 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 19 of 39

'j

PLANT ISSUES MATRIX Palisades 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date = '10/1/97' ; Ending Date = '9/30/98' 101 DATE II TYPE II SOURCE II 103 3/13/1998 Positive IA 98002 104 3/13/1998 Weakness IA 98002 1 OS 3/13/1998 Negative IA 98002 106 3/13/1998 Positive IA 98002 107 3/13/1998 Negative IA 98002 108 3/13/1998 Positive IA 98002 109 3/13/1998 VIO/SL-IV IA 98002 IDBY II SALP II SMM CODES II NRC Plant 1C 3A Support NRC Operations 2A 28 NRC Engineering 2A SC NRC Operations 3A 1 A NRC Maintenance 3A 2A NRC Maintenance 3A 28 NRC Operations 3A 58 Page 20 of 39 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).

The Inspectors noted that previously Identified procedural weaknesses In e the cold weather checklist still existed. More significantly, the Inspectors 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 01.3).

Problems with control rod drive contactors continue. However, the problem associated with Control Rod Drive 3S was caused by an error in reassembly of the contactor after cleaning and inspection. Post maintenance testing for CAD 3S was considered appropriate (Section M4.1).

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

• The failure to properly 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 correctiye actions were more thorough (Section 02.1 ).

PLANT ISSUES MATRIX Palisades 11/23198 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" ; Beginning Date = "10/1/97" ; Ending Date = "9/30/98"

\\C!JI DATE II TYPE 11

• SOURCE 110 311311998 Positive IA 98002 111 311311998 NCV IA 98092 112 311311998 Negative IA 98002

. 113 311311998.

NCV IA 98002 114 2/17/1998 LEA LEA 9800S 115 2/16/1998 LEA LEA 98004 116 1/27/1998 NCV IA 97018 II ID BY II SALP II SMM CODES II DESCRIPTION 11 NRG Operations SA 3A An Independent team completed an audit in the area of 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 concerns In this area (Section 07.1)

Licensee Operations SA SB SB The licensee Identified a condition outside the design basis involving*

NRC NRC Plant Support Engineering SA SC 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).

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 CHA event were rigorous. This resulted in Identification of a condition outside design basis regarding the containment radiation monitorin11system. The proposed corrective actions were considered thorough. This was considered a non-cited violation (Section E7).

Licensee Maintenance 2A Actuation of Containment Isolation Caused by an Inadvertent Containment High Radiation Signal Licensee NRC Plant Support 4A 1C Discovery of Card Reader Vulnerability and Incorrect Compensatory Measures Taken Engineering 1A 2B

• 4B During a closeout of a licensee event report, the inspectors identified a Page 2fof 39 non"Cited violation for failure to meet Technical Specifications testing requirements of the emergency escape air lock (Section E8.3).

PLANT ISSUES MATRIX Palisades 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date *= "10/1/97" ; Ending Date = "9130198" IC!JI DATE II TYPE II SOURCE 117 1/27/1998 Positive IA 97018 118 1/27/1998 VIO/SL-IV IA 97018 119 1/27/1998 URI IA 97018 II ID BY II SALP II SMM CODES II DESCRIPTION NAC Operations 1 B 38 SB The operators responded appropriately to a loss of component cooling NRC Engineering 2A NAC Maintenance 2A Page 22 of 39 water event that occurred on January 1, 1998. The licens~e established an incident response team (IRT) to investigate the circumstances surrounding the event, and the Inspectors concluded that the tRrs findings and proposed corrective actions were thorough. However, the

.A 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).

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 point drain problem and the lack of corrective action for the air filter placement problem led to failure of CV-3018's air regulator. A violation of NRC requirements was Identified (Section E 1.1 ).

The inspectors concluded that the spent fuel pool maintenance activity to repair body to bonnet leaks on t't'o 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).

. e

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date" : Beginning Date = "10/1/97" : Ending Date = "9/30/98" lw1 DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION 120 1/27/1998 ED IA 97018 EA 96-NRC Engineering 2A 4B 4C Three 10 CFA 50, Appendix A, issues were of concern because of the 131 IA 97011 LEA safety significance associated with plant equipment configuring that did 97-01-0 not meet 10 CFA Part 50, Appendix A, safe shutdown requirements for a design basis fire. These issues would normally be designated as a Severity Level Ill problem in accordance with the NAC's NUAEG-1600, e "General Statement of Policy and Procedures for NAC Enforcement Actions," (Enforcement Policy). However, enforcement discretion will be used in accordance with Section Vll.B.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 corisideration 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 A deficiencies. Palisades identified the issues detailed above and promptly notified the NAC; 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 NAC to explain their efforts to resolve these issues, which were outlined in their reply dated September 12, 1996.

121 1/27/1998 Positive IA 97018 NRC Operations 2B 3A Following the discovery of a mispositioned valve at a nitrogen station, the licensee instituted an equipment status control record to enhance the e operations department's control of equipment. To date, no discrepancies have been identified (Section 01.3).

122 1/27/1998 Negative IA 97018 NAC Engineering 3A The inspectors concluded that the system engineer had adequately prepared to perform leak checks on the radwaste evaporator component cooling water supply and return valves. However, the inspectors noted 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).

123 1/27/1998 Positive IA 97018 NAC Plant 3A The inspectors concluded that radiological practices observed during the Support maintenance activities and plant daily walkdowns were adequate.

Page 23 of 39

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date = '10/1/97' ; Ending Date = '9/30/98' 101 DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION 124 1/16/1998 Negative IA 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. e The posting of the entrances into two large areas in the Auxiliary Building were Inconsistent with NRC guidance (Section R4.1 ).

125 1/16/1998 Weakness IA 970.16 NRC Plant 1C 3A C&RS personnel have experienced communication problems with other Support station departments. The C&RS management was aware of these.

communication issues and indicated that there would be continued attention to Improve the performance in this area (Sections ~1.4, R4.1, R4.3, and R4.4).

126 1/16/1998 Positive IA 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).

127 1116/1998 URI IA 97016 NRC Plant 2A The materiel condition and mechanical isolation performance of the Support accident high range monitors was very good, as evidenced by surveillance testing. However, the C&RS staff's failure to change out this filter resulted In greatly exceediQg the shelf life of the iodine cartridge and the radiochemistry laboratory did not have a calibrated geometry to e

analyze this cartridge. Discrepancies in various documents indicated Inattention to detail. As the licensee may not have been able to

• sufficiently determine the iodine release in stack effluents under accident conditions, this issue Is being considered an Unresolved' Item (Section R2.4).

128 1/16/1998 Negative IA 97016 NRC Plant 2A The training and inventories for the post accident sample monitoring Support (PASM) system were conducted iri accordance with procedure. However, the performance 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).

Page 24 of 39

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date = '1011197' Ending Date = '9130198'

• 1w1 DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION 11 129 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 e indicated a strong commitment to excellent plant water quality (Section R1.1).

130 1/16/1998 Positive IR 970~6 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).

131 1116/1998 Positive IR 97016 NRC Plant 2A SA Overall, the quality assurance and materiel condition of the laboratory and Support 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).

132 1/16/1998 Positive IR 97016 NRC Plant 28 Station staff conducted effective oversight of the respiratory protection

• Support program, as. the surveillances S(ld maintenance were satisfactorily completed as required. The equipment was in good working order and e was cleaned and stored appropriately. Personnel using the equipment were properly trained, medically qualified, and properly fit-tested (Section R1.3).

133 1/16/1998 VIO/SL-IV IR 97016 NRC Plant 3A 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 cont_ributing 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).

Page 25 of 39

PLANT ISSUES MATRIX Palisades 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Data' ; Beginning Data = '10/1/97' ; Ending Data = '9/30/98'

.. \\01 DATE II TYPE II SOURCE 134 1/16/1998 Positive IA 97016 135 1/16/1998 Positive IR 97016 136 1/16/1998 Positive IR 97016.

137 1/13/1998 LEA LEA 98003 138 1/1211998 LEA LER 98002.

II 1D ev II SALP llsMM coDEsll DESCRIPTION NAC NRC NRC Plant Support Plant Support Plant Support SA SA SA Licensee Operations 3A 1 A Licensee Engineering 4A 48 Page 26 of 39 ALARA post-job reviews were well done and thes& reviews demonstrated that the staff was appropriately critical of licensee performance in a variety of areas. The reviewers identified several significant lessons learned which should enable the plant personnel to improve dose control for future outages (Section R4.2).

The licensee's fuel integrity group effectively monitored a wide variety of chemistry parameters to ascertain the fuel integrity. In particular, the staff concluded that the current data indicated th.e existence of one fuel defect, which Is probably a large pinhole leak. The inspectors concluded that the fuel integrity group utilized appropriate methodology for this determination (Section R1.2).

The Nuclear Performance Audit Department audit team was highly qualified, and the chemistry audit was extensive. This audit effectively Identified areas for Improvement and followed-up past issues to ensure proper resolution {Section A7.2).

Watertight door Improperly latched. A maintenance worker found watertight door #S9 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 properly latch the door, the door could not have performed as designed. TIJe door is part of the wall separating the East and West Engineered Safeguards Rooms and is relied upon to

• prevent a flooding event from affecting both rooms. The door is also e required to maintain the fire barrier between the rooms.

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.

PLANT ISSUES MATRIX Palisades 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "10/1/97" ; Ending Date =

09/30/98° lw1 DATE 11

• TYPE 11 139 1/1/1998 LEA 140 12111 /1997 Positive 141 12111 /1997 Positive 142 12111 /1997 Positive 143 12111 /1997 Positive 144 12111 /1997 Positive 145 1215/1997 VIO/SL-IV SOURCE LEA 98001 IR 97017 IR 97017 IR 97017 IA 97017 IA 97017 IR 97017 IA 97013

. l I

II ID BY. II SALP II SMM CODES II Licensee Maintenance 2A NRC Maintenance

• 28 NRC Maintenance 28 DESCRIPTION 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 mVmin 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 W'

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.

• An Inspection follow-up item regarding the acceptability of proposed changes to the reliability criterion for the reactor protection system was ci~~.

For the three additional systems reviewed, the maintenance rule program was adequately implemented and the systems were appropriately

• classified.

NRC Maintenance 28 NRC Maintenance 28 NRC Maintenance 28 NRC Operations 1 C Page 27 of 39 An Inspection follow-up item involving performance of periodic assessments, reliability-availability balances, and use of industry operating experience was closed.

An Inspection follow-up Item regarding an evaluation of the reactor protection system for classification as category (a)(1) was closed.

The licensee properly addressed all open items that were identified during the Maintenance Rule 8aseli~e Inspection.

The inspectors identified a violation in that procedure SOP-1, "Primary Coolant System,* Revision 38, was inappropriate for the circumstances.

This procedure allowed the operators to start a primary coolant pump 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).

lw1 DATE II 146 1215/1997 147 1215/1997 148 1215/1997 149 121511997 150 1215/1997 PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date =

• 10/1 /97" ; Ending Date = "9/30198" TYPE II sqURCE II ID BY II Negative IR 97013 Self-Revealed Positive IA 97013 NRe Positive IR 97013 NRe Positive IR 97013 NRe Positive IR 97013 NRe SALP II SMM CODES II Operations 2A Maintenance 28 Maintenance 28 3A Engineering 48 Engineering 48 Page 28 of 39 DESCRIPTION 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 (eves) 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 requirements were adequate. The inspectors frequently observed supervisors and 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 tiad overall responsibility for scheduling and completing the repair (Section M1.2).

The engineering department's operability evaluation and assistance for preparations for the repairs to main steam isolation valve (MSIV) MO-0510 were thorough. The engineering department's efforts had improved over those associated with previous similar MSIV repairs (Section E1.2).

The inspectors determined that the licensee's actions were adequate to address the atmospheric dump valve hot short Appendix R scenario and rebaselining of fire dampers and b.arrlers. 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 ).

Ii 9*

PLANT ISSUES MATRIX Palisades 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date ~ '10/1/97' ; Ending Date = '9/30/98' IC!JI DATE II TYPE II 151 12/5/1997 Positive 152 11/19/1997 Negative 153 11/19/1997 EEi SOURCE

• IR 97013 IR 97014 IR 97014 l:A 97-569 (see 3/31/98 entry)

II ID BY II SALP II SMM CODES II NRC NRC NRC Plant Support Operations 5A 1A Operations 1 A 28 Page 29 of 39 DESCRIPTION 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 performed 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 question the appropriateness of removing power from all the control rods with the plant at power. (Section 04)

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 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 by 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 e(i!uipment 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 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)

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes {Ascending): Search Column = "Date* ; Beginning Date = '10/1/97" ; Ending Date = '9/30198' 101 DATE II TYPE II SOURCE II IDBY II SALP II SMM CODES II DESCRIPTION 154 11/19/1997 VIO/SL-111 IA 97014 EA 97-NRC Maintenance 1A 28 A severity level Ill violation was issued on April 2, 1998, regarding 567 (see 3/31/98 conduct of operation and maintenance activities (see 3/31/98 entry).

entry}

Multiple apparent violations regarding maintenance activities occurred which included: (1) the failure to satisfy the control rod drive system e

conditions required by the maintenance procedure; (2) the failure to Identify that the maintenance activity could not be performed as 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 failure 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 "false sense of comfort* 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 requiretl.

The number of failures that occurred indicated a programmatic breakdown regarding maintenance activities during control rod #38 repairs. (Section M1) 155 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) 156 11/14/1997 Negative IA 97201 NRA 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 30 of 39 i

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PLANT ISSUES MATRIX Palisades 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date = '10/1/97' ; Ending Date = '9/30/98~

101 DATE II TYPE II SOURCE 157 11 /14/1997 Negative IR 97201 NRR 158 11/14/1997 Negative IR 97201 NRR 159 11 /14/1997 Negative IR 97201 NRR II ID BY II SALP II SMM CODES II DESCRIPTION NRC Engineering 3A 28

• NRC Engineering 3A 4A NRC Engineering 4A Page 31 of 39 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 A

injection tank vent valves and operation of the relief valve inside W

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 ~nalytical inputs changed, such as SI pump horsepower inputs to the_ emergency diesel generator loading calculation and load changes, which affected the main electrical lo~d 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 was issued without verifying all input parameters or

• providing any conclusion on the ~cceptability of the de system. Failure to

. maintain design-basis calculations current was apparently due, in part, to a a weakness in the transfer of information between engineering gr.cups.

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 from these flow elements was used in postaccident monitoring and control

!lCtivities.

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Data* ; Beginning Date = *10/1197" ; Ending Date = "9/30/98',

IC!JI DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION 160 11/14/1997 Negative IA 97201 NRA NRC Engineering 4A 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 e currents were not evaluated at the correct locations.

161 11/14/1997 Negative IA 97201 NRA 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 ana!ysis 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.

162 11/14/1997 Negative IA 97201 NRA 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 10 CFR Part 21 notification concerning Agastat relays, and a missed Sl.U'Veillance for safety-related overcurrent relays. The team also identified a number of discrepancies in the FSAR, -

08Ds, and other plant documents.

163 11/14/1997

. Negative IA 97201 NRA 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.

164 11/14/1997 Positive IA 97201 NRA NRC Engineering 4A 4C 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 of the Inspection were comprehensive.

Page 32 of 39

PLANT ISSUES MATRIX Palisades 11/23/98

.Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = *1011197* ; Ending Date = "9/30198" 1w1 DATE 11 TYPE 11 SOURCE 165 11/14/1997 Negative IR 97201 NRA 166 11/14/1997 Positive IR 97201 NRA 167 11/10/1997 LEA LEA 97013 168 1117/1997 VIO/SL-IV IR 97015 169 1117/1997

• VIO/SL-IV IR 97015 II ID BY II SALP I( SMM CODES II NRC

• Engineering 4C NRC Engineering 5C Licensee Maintenance 28 NRC NRC Plant Support Plant Support 3A 3A Page 33 of 39 DESCRIPTION If 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 specification 6.5.7. Check valves in the minimum flow recirculation 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 wece 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.

9*

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).

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 ).

PLANT ISSUES MATRIX Palisades*

11/23/98 Search Sorted by Date (Descending) end.SMM Codes (Ascending): Search Column = "Date* ; Beginning Date =

0 10/1/97° ; Ending Date = "9/30/98" l~I DATE II TYPE II SOURCE 170 1117/1997 VIO/SL-IV IA 97015 171 1117/1997 Positive IA 97015 172 1117/1997 Positive IA 97015 173 10/2511997 Positive IA 97012 17 4 10/25/1997.

Positive IA 97012 II ID BY II SALP II SMM CODES II DESCRIPTION NRC NRC NRC NRC NRC Plant Support Plant Support Plant Support Plant Support Plant Support 3A 38 SB 1C 1C Page 34 of 39 Routine radiological surveys were generally done in accordance with station procedures, and the surveys were adequate to inform workers 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 A

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).

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 RS.1 ).

The corrective action program was effectively implemented in 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 progr~m was well managed and implemented in A 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).

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 procedures indicated a lack of attention to detail by Chemical and Radiological Services (C&RS) staff (Section R1.1).

=============::::::==============================================================================-

\\C!JI DATE II 175 10/25/1997 PLANT ISSUES MATRIX Palisades

!i 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = "10/1/97" Ending Date = "9/30/98" TYPE II SOURCE II ID BY Positive IR 97012 NRC II SALP Plant Support II SMM CODES II DESCRIPTION 3A 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 176 10/25/1997 Misc IA 97012 NRC Plant Support SA SC comprehensive (Section R4.1 ).

9, 177 10/25/1997 Positive IR 97012 NRC 178 10/17/1997 Positive IA 97011 NRC 179 10/17/1997 Positive

.IA 97011 NRC Operations SC SA Operations 1 A Operations 1A Page 35 of 39 Engineering staff effectively Identified and addressed 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 effectively Implemented these actions during a recent spent resin sluice.

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 decid.!=!d to shut down the plant due fo a relatively minor increase in contilinment unidentified leakage. The inspectors noted that control room operators performed well in bringing the plant to hot shutdown.

The IAspectors 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 repairs 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).

-~r:,

=

PLANT ISSUES MATRIX 11/23/98 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date = '1011/97' ; Ending Date = '9/30/98' l~I DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION 180 10/17/1997 NCV IA 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 1 O 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 Policy (NCV No. 50-255/97011-02).

181 10/17/1997 Positive IA 97011

• 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).

182 10/17/1997 Negative IA 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).

183 10/17/1997 VIO/SL-IV IA 97011 NRC Maintenance 28 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 to question the potential for a breach of the waste gas surge tank discharge piping. Also, adequate equipment controls were not provided to prevent personnel contamination. The inspectors concluded that the use of a 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).

184 10/17/1997 Positive IA 97011 NRC Plant 28 The licensee's actions to improve the resin transfer process resulted in an

• Support error-free evolution for the spent fuel pool job (Section R 1.1 ).

185 10/17/1997

. LEA LEA 97012 Licens~e Maintenance 28 38

.CONTROL RODS DEENERGIZED WHILE IN POWER OPERATION Page 36 of 39

PLANT ISSUES MATRIX Palisades 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date = '10/1/97' ; Ending Date = '9/30/98' l~I DATE II TYPE II SOURCE 186 10/17/1997 Positive IR 97011 187 10/14/1997 Misc IR 97009 188 10/14/1997 Negative IA 97009 189. 10/14/1997 Positive IA 97009 190 10/14/1997 Negative IA 97009 191 10/14/1997 Misc IA 97009 192 10/14/1997

• Positive IR 97009 II ID BY II SALP II SMM CODES II NRC

• Engineering 4B NRC Operations 1 A licensee. Operations 1A 3A licensee Engineering 1B 2A NAC Engineering 2B NAC Maintenance 2B NAC Engin~ering SA Page 37 of 39 DESCRIPTION If The inspectors found the compensatory measures taken for the identified -

Appendix A issues to be adequate. The Appendix R enhancement review was found to be progressing slowly. However, the review appeared to be thorough (Section E1.1).

The inspectors concluded that although the Consumers Energy load e distribution center and the Michigan Electric Power Coordination Center are an integral part of the Consumers Energy system, these organizations exert minimal influence on the Palisades facility. The Palisades facility is unique in that personnel maintain control of the 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).

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

The inspectors concluded that the new perspective used by system engineers to perform system health assessments resulted in identification of system performance 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 determine system performance and incorporating support system performance, showed a willingness of system engineers to be critical of their respeGtive systems. (Section E1.4).

=======================================================================================================<.-

PLANT ISSUES MATRIX Palisades 11/23/98 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'Date' ; Beginning Date = '10/1/97' ; Ending Date = '9/30/98' IC!JI DATE II TYPE II SOURCE 193 10/14/1997 Negative IA 97009 194 10/12/1997 LEA LEA 97011 II IP BY II SALP II SMM CODES II NAC Engineering SA SB SC Licensee Operations 3A 1A Page 38 of 39 DESCRIPTION The specific root cause for the *c* channel thermal margin monitor 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 early 1997 and was slow to focus adequate resources to solve the problem (Section E1.1).

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

\\I

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11/23/98 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRG 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 t,he LEA or inspection report date.

TYPE The categorizatio~ of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IA for NRC Inspection Report or LEA for Licensee Event Report.

IDBY Identification of who discovered the issue - see table.

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

SMM CODES Senior Manager Meeting Codes - see table.

DESCRIPTION Details of the is5ue from the LEA text or from the IA Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRG Reauirements

. EEis are apparent violations of NRG 1

Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A-Normal EEi" Escalated Enforcement Issue - Waitina Final NRC Action escalated enforcement action in accordance 8-During Transients LEA License Event Report to the NRC with the "General Statement of Policy and C - Programs*and Processes Procedure for NRC Enforcement Action*

Llcenslna Licensina Issue from NRA (Enforcement Policy), NUREG-1600.

2 Material Condition:

Misc Miscellaneous (Emeraencv Preparedness Findina, 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 Neaatlve Individual Poor Licensee Performance Identified by the EEis and the PIM entries 3

Human Performance:

Positive

• Individual Good Licensee Performance may be modified when the final decisions A.. Work Performance Stren!:lth Overall Strona 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 provided with an opportunity to either VIO/SL-1 Notice of Violation - Severity Level I (1) respond to the apparent violation or 4

Engineering/Design:

VIO/SL-11 Notice of Violation - Severity Level II (2) request a predeclsional 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 acceptable item, a deviation, a ID BY nonconformance, or a violation. However, B - Analysis the NRG has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Reaulatorv Commission entries may be modified when the final Self-Revealed Identification by an event (e.a., equipment breakdown) conclusions are made.

Other Identification unknown Page 39 of 39

.. -.....