ML18066A446

Advises of Planned Insp Effort Resulting from Palisades PPR Review,Which Was Completed on 990203.Overall Performance at Palisades Was Acceptable

ML18066A446
Person / Time
Site:	Palisades
Issue date:	03/26/1999
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 9904070105
Download: ML18066A446 (60)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill Mr. Thomas J. Palmisano 801 WARRENVILLE ROAD LISLE, ILLINOIS 60532-4351 March 26, 1999 Site Vice President and General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Coyert, Ml 49043-9530

SUBJECT:

PLANT PERFORMANCE REVIEW - PALISADES

Dear Mr. Palmisano:

On February 3, 1999, the NRC staff completed a Plant Performance Review (PPR) of the Palisades plant. The staff conducts these reviews for all operating nuclear power plants to deveiop an integrated understanding of safety performance. The results are used by NRG" management to facilitate planning and allocation of inspection resources. Plant Performance Reviews provide NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting (SMM) reviews. Plant Performance Reviews examine *information since the last assessment of licensee performance to evaluate long-term trends, but emphasize the last 6 months to ensure that the assessments reflect current performance. The PPR for Palisades involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period January 24; 1997, to January 1999. The NRC's most recent summary of licensee performance was provided in a letter dated January 24, 1997, and was discussed in a public m~eting with yo.u on February 7, 1997.

As discussed in the NRC's Administrative Letter 98-07 of October 2, 1998, the PPR provides an assessment of licensee performance during an interim period that the NRC has suspended its Systematic ~ssessment of Licensee Performance (SALP) program. The NRC suspended its SALP program to complete a review of its processes for assessing performance at nuclear power plants. At the end of the review period, the. NRC will decide whether to resume the SALP program or terminate it in favor of an improved process.

During this period the plant was operated at full power until April 24, 1998, when the plant was shut down for. a refueling outage. Following the refueling outage, the plant was returned to power operations on June 7, 1998; however, the plant was shut down on June 9, 1998, because of high vibrations on the main turbine. The plant was returned to power operations on June 10, 1998. The plant was operated at full power until July 21, 1998, when the operators manually tripped the reactor in response to a main feedwater pump mechanical failure. The plant was returned to power operations on July 22, 1998, on a single main feedwater pump and

/

operated at 71 percent power until July 26, 1998. Following repairs to the main feedwater

'1 1

pump, the plant operated at full power from July 27, 1998, until September 26, 1998, at which time powerwas reduced to 44 percent to repair main condenser tube leakage. Following repairs to the main condenser, the plant operated at full power from September 28 9904070105 990326

~DR ADOCK 05000255 PDR

until December 13, 1998, when the plant was shut down to repair primary coolant pump oil leaks. The oil leaks and other emergent equipment problems were repaired and the plant was restarted on January 7, 1999. The plant was operated at or near full power for the duration of the assessment period:

Overall, performance at Palisades was acceptable. The plant continued to be operated in a deliberate and conservative manner even though the plant staff was frequently challenged by equipment problems. Areas requiring improvement include the focusing of maintenance and engineering efforts to improve the material condition of the plant to minimize the challenges to the control room operators, and the continuation of efforts to improve operator performance.

Overall performance in the Operations area remained consistent. Operator performance in response to plant transients was excellent. In addition, control room decorum was noted as a strength. Contrary to these observations, plant events periodically occurred due to a lack of rigor or attention to details during the preparation for and conduct of operations activities. For example, equipment manipulations were not made in a timely manner and wrong components were sometimes operated which resulted in plant parameters exceeding procedural limits.

Though the safety consequences were not significant, the events were of concern because *Of their recent occurrence and the fundamental nature of the errors. The performance during this period does not warrant any additional inspection effort above the core NRG inspection program, although some increased emphasis through resident inspector regional initiative inspections will be placed on the areas identified above.

Performance in the maintenance area was consistent during this period. Observed maintenance and surveillance activities were accomplished in accordance with plant procedures, and were appropriately documented. Maintenance was not fully effective in sustaining the material condition of the plant in that equipmerit problems frequently challenged the operators and the plant. Inspection of the licensee's lnservice Inspection Program indicated that the program was well implemented. However, the licensee missed an opportunity to identify a leak at the reactor coolant pump P-50A cover to casing joint during the June 1998, system pressure test. Further, the licensee failed to submit to the NRC a structural evaluation on the degraded pump joint which demonstrated a poor understanding of the applicable Code requirements. The licensee's ability to identify and resolve problems was also inconsistent.

Planned NRC inspections of this area include normal core inspections complimented by resident inspe'ctor regional initiative inspections to assess the effectiveness of maintenance in addressing and preventing plant equipment problems.

Engineering support of plant activities was consistent with some noted deficiencies early in the assessment period. For example, engineering support of activities related to the auxiliary feedwater flow controllers and the turbirie generator control systems was hampered by a lack of engineering personnel knowledge of flow controllers. An NRC engineering and technical support inspection, completed on July 24, 1998, concluded that overall design control improved.

In addition, the licensee was continuing efforts to improve the modification process. The licensee's corrective action, audit, and self-assessment programs were effective. Quality assurance activities were of appropriate depth and scope. Planned NRC inspections of this

T. Palmisano. area include normal core inspections complimented by resident inspector regional initiative inspections to assess the effectiveness of engineering support to plant activities in addressing and preventing plant equipment problems.

Radiation protection (RP) performance was consistent. Overall, improvements in radiological planning resulted in improved outage performance and reduced radiation exposure. However, weaknesses in the coordination of work activities, in the oversight of contract personnel, and in the communication with the RP staff challenged radiological controls. The long-term effectiveness of the licensee's actions to correct these problems has *not been fully assessed.

The emergency preparedness (EP) program was effectively maintained in a state of operational readiness. Overall performance during the 1998 EP exercise was very good. Personnel also demonstrated their ability to properly implement the. emergency plan for an actual onsite seismic event. Security force performance was good and generally consistent. However, some performance weaknesses were identified. The fire protection program was acceptable but with some weaknesses, including weak administrative controls and.a lack of substantive inspections in the auxiliary building. Planned NRC inspections of this area consist of routine core inspections with focus on radiological protection improvement efforts. contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were considered during this PPR process to arrive at an integrated view of licensee.

performance trends. The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and the Consumers Energy Company. The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately. Rather, the NRC only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance. In addition, the PPR may also have considered some predecisional and draft material that does not appear in the enclosed PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration. This material will be placed in the Public Document Room as part of the normal issuance of NRC inspection reports and other correspondence.

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

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

The inspection schedule is subject to revision because of anticipated changes to the NRC's inspection program. We will promptly notify you of any changes. If you have any questions, please contact Tony Vegel at (630) 829-9620.

Docket No. 50-255 License No. DPR-20

Enclosures:

1. Plant Issues Matrix

2. Inspection Plan See Attached Distribution Sincerely, ls/Geoffrey E. Grant Geoffrey E. Grant, Director Division of Reactor Projects DOCUMENT NAME: G:\\PALl\\INSPPLN8.PAL

• See previous concurrences To receive a coov of this document. indicate in the box "C" = Coov without attachmenVenclosure E" ='Coov with attaChmenUenclosure "N" =No coov OFFICE

• Riii I

• Riii I

Riii I

NAME

• CPhillips:nh:co AVeqel Grant C:iv DATE 03/19/99 03122199 03nio 19.9 ()

OFFICIAL RECORD COPY I

The inspection schedule is subject to revision because of anticipated changes to the NRC's inspection program. We will promptly notify you of any changes. If you have any questions, please contact Tony Vegel at (630) 829-9620.

Docket No. 50-255 License No. DPR-20 Enclpsures:

1. Plant Issues Matrix

2. Inspection Plan Sincerely, Geoffrey E. Grant, Director Division of Reactor Projects cc 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 INPO DOCUMENT NAME: G:\\PALl\\INSPPLN8.PAL with attachmenUenciosure "N" = No OFFICE Riii Riii NAME Grant DATE 03/ /99 OFFICIAL RECORD COPY

cc w/encls:

R. Fenech, Senior Vice President, Nuclear Distribution:

CAC (E-Mail}

RPC (E-Mail)

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 The Honorable George Sink S. Banninga, City Manager of Bangor The Honorable Ted Johnson G. Gallagher, City Manager of Hartford The Honorable James Mills A. Vanderberg, City Manager of South Haven K. Higgs,* Administrator, Allegan County.Courthouse D. Haverdink, Allegan County Sheriff B. Brunett, Allegan County Emergency Management Coordinator J. M. Henry, Berrien County Coordinator R. Kimmerely, Berrien County Sheriff J. Collins, Berrien County Emergency Management

0. Hanson, Van Buren County Board Chairman D. R. Gribler, Van Buren County Sheriff Sergeant Alaine Svilpe, Van Buren County Emergency Preparedness Coordinator The Honorable Daniel P. ~chofield, Jr.

The Honorable Robert Wooley INPO G. Tracy, OEDO w/encls Chief, NRR/DISP/PIPB w/encls T. Boyce, NRR w/encls Project Director, NRR w/encls Project Mgr.. NRR w/encls J. Caldwell, Riii w/encls B. Clayton, Riii w/encls R. Lickus, Riii w/encls SRI Palisades w/encls DRP w/encls DRS (2) w/encls Riii PRR w/encls PUBLIC IE-01 w/encls Docket File w/encls GREENS

Page: 1of8 INCLUDES DRAFT ITEMS Region Ill PALISADES Date Source 0111211999 1998022 01/1211999 1998022 01/1211999 1998022-01 01/1211999 1998022 11/25/1998 1998019 11/25/1998 1998019 11/0311998 1998007 11/0311998 1998007 Functional Area Prl:QPS Sec:

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ID NRC NRC NRC NRC NRC NRC NRC NRC United States Nuclear Regulatory Commission PLANT ISSUE MA TRIX

'Date: 03/it/1999 Time: 08:58:13 Type POS POS By Primary Functional Area Template Codes Item Description

. Prl: 1A Sec:

'Te*r:

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The action taken to place the plant In cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the minor leakage from control rod drive 02 was conservative when considering technical specifications and demonstrated a positive focus on safety. (Section 01.3) l Ter:

Control room operator response to a loss of a safeguards transfonner event was effective. A positive questioning attitude and a pro-active initiative were demonstrated by the operating crew and outage management regarding briefing the potential for a loss of off-site electrical power because of ongoing activities for the plant conditions that existed. This was considered as a positive attribute regarding operator perfonnance and contributed to the crew's exemplary perfonnance while responding to a loss of the safeguards transfonner. (Section 04.2) e NCV NEG NEG POS NEG NEG Prl: 1A Sec:

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A number of operator errors and operational problems occurred due to a lack of consistent comprehensive pre-evolution briefings, and a lack of rigor re!;larding attention to detail by the operators while perfonnlng assigned duties. Operator perfonnance deficiencies contnbuted to the cooling tower basin bein!;l overfilled twice, two Instances where primary coolant system pressure exceeded procedural limits, and not recognizing Technical Specification requirements when the main steam Isolation valves did not go fully closed. In addition, an operator's failure to conduct self-checking activities while manipulating equipment was a concern in that it directly resulted in placin~ a safety-related system In a configuration that was contrary to procedural requirements which was a Non-Cited Violation. (Section 04.5)

An operator work around was created by the inoperable pressurize power operated rellef valve position Indication lights.

The work around had minimal impact on the operators and the appropriate contingency actions were established.

(Section 01.2)

Weak equipment status control for the hrdrazine addition system, a system nonnally operated by chemistry personnel, contributed to the inadvertent draining o hydrazine Into the turbine building sump. ihe Incident was considered minor because an Inadvertent release of hydrazine to the environment did not occur and there was no Impact on nuclear safety. However, the incident highlighted the need for Improved equipment status control, effective lnter~epartmental communications, and Increased rigor by operations personnel when they are conducting evolutions on equipment that Is nonnally operated by other plant department personnel. The recovery efforts were well coordinated between operations and environmental department personnel. Immediate corrective actions were considered appropriate.

In general, the conduct of operations continued to be professional with the control room environment free of unnecessary distractions. No significant emergent equipment problems challenged plant operations during this inspection period.

The failure to recognize Technical Specification implications contributed to the incident (valve alignment resulting In the inoperabllity of both trains of HPSI) in that It allowed the inadequate procedure to be perfonned. The Incident was non-risk significant and had no actual safe~ consequences. Safety significance was high regarding the potential consequences In that emergency core coohn!;l criteria regarding peak clad temperature would have been exceeded for a design based small break loss of coolant accident assuming no operator action. The Inspectors noted that the required operator actions were not complex and could have been accomplished in a timely manner which would mitigate the potential consequences.

The crew's knowledge regarding the Technical Specification requirements associated with the high pressure safety injection system surveillance test was poor. Also, the crew demonstrated a poor questioning attitude regarding the test lineup and a lack of awareness regarding the relationship between the high pressure safety Injection system manipulations that were perfonned and the purpose of the test.

Item Type (Compliance,Followup,Other), From 10/0111997 To 01131/1999

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2 ofB United States Nuclear Regulatory Commission Date: 03i1911999 l INCLUDES DRAFT ITEMS Time: 08:58:13 Region Ill PLANT ISSUE MATRIX PALISADES By Primary Functional Area Functional Template Date Source Area ID Type Codes Item Description 11103/1998 1998007 Prl:OPS NRC NEG Prl:20 The Inspectors concluded that licensee personnel aggressively pursued and Identified the ap~roeJ1ate root causes for Sec:

Sec:

this Incident. The licensee's Incidence response team ':?corously evaluated the Incident and e entffled corrective actions were thorough. Multiple barriers to preclude pe orming an inadequate procedure failed for several years which Ter:

contnbuted to the incident. Regulatory significance was hlPrh ~ardlng the fallure to perform sa~

reviews for procedure revisions that affected the high pressure safety ~ect1on system's safety analysis. The llure to perform adequate safety reviews for the procedure revisions resulte In the development of Inadequate Procedure RT-710.

11/03/1998 1998007-01 Prl:OPS NRC EEi Prl: 1A Surveillance test procedure, RT-710, directed the oi:rators to close the normally open HPSI cold~ ln~ectlon orifice Sec:

~ss valves (M0-3080 and M0-3081) and open t e normally closed ho~ I~ Injection valves (MO- 08 and Sec: MAINT 3083). This allgned both trains of HPSI cold leg Injection through the o ices In all four cold :JI'*.

The normal at Ter:

rn:er HPSI cold leg Injection lineup bypassed the orifices. Consequently, the test lineup rende both trains of HPSI e operable due to the reduced flow through the cold legs.

10/0711998 1998017 Prl:OPS NRC POS Prl: 1A Conduct of operations was professional with a focus on safety. Senior Reactor Operators' command and control of control room activities had Improved from previous.Inspection periods and was generally ~ood with one noted Sec:

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exception. Control room operators demonstrated a questioning attitude regarding schedu ed activities on a more Ter:

frequent basis.

10/07/1998 1998017 Prl:OPS NRC POS Prl: 1A The operating crew demonstrated a good questioning attitude regarding a potential condition that could render both trains of control room ventilation Inoperable.

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10/07/1998 1998017 Prl:OPS NRC POS Prl: 1A The operators demonstrated good self checking and procedure adherence during performance of the safety Injection Sec:

quarterly surveillance. However, the Control Room Supervisor did not demonstrate positive command and control Sec:

following receipt of an unexpected annunciator. Augmenting the on-shift crew with operators responsible for performing Ter:

the surveillance test emphasized safe conduct of operations.

. 10/0711998 1998017 Prl:ops NRC POS Prl: 10 The control room crew declared an unusual event and exercised the emergency plan Implementing procedures as Sec:

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required for seismic activity onsite. The seismic activity was low level and did not cause any damage onslte.

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e 01/1211999 1998022 Prl: MAINT NRC POS Prl:20 Outage planning and scheduling personnel addressed the emergent Issues In a deliberate manner which demonstrated a positive focus on safety. Also, a positive focus on safety was demonstrated by having a shift outage manager Sec:

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stationed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time the forced outage commenced until the plant was returned to full power. (Section Ter:

M1.1) 01/12/1999 1998022-03 Prl:MAINT NRC VIO IV Prl: 2A The licensee missed an opportunity to Identify the leak at the reactor coolant pump P-50A cover to casing joint during the June 1998, system pressure test, which Indicated a lack of rigor In the conduct of this testing. Further, the licensee Sec: ENG Sec:

had falled to submit a structural evaluation on the degraded pump joint to the NRC which was a violation of regulatory Ter:

requirements and demonstrated a poor understanding of the applicable Code requirements. (Section M1.2) 11125/1998 1998019 Prl: MAINT NRC POS Prl:3A Maintenance and surveillance activities were conducted in a professional manner and workers actively utilized and

. Sec:

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adhered to procedures. The safe~-related battery charger and instrument Inverter system modification has been effectively coordinated with operations.

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Item Type (Compliance,Followup,Other), From 10/0111997 To 01131/1999

Page: 3 of 8 INCLUDES DRAFT ITEMS Region Ill PALISADES Date Source 10107/1998 1998017 10/07/1998 1998017-01 06130/1998 1998-009-00 06109/1998 1998-008-00 0111211999 1998022 01/1211999 1998022-04.

01/1211999 1998022-05 11125/1998 1998019 Functional Area Prl: MAINT Sec:

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United States Nuclear ReguJatory Commission PLANT ISSUE MATRIX

. Date: 03f1911999 l Time: 08:58:13

• ID Type NRC POS NRC NCV Licensee LER Licensee LER NRC POS NRC NCV NRC.

NCV NRC POS l

. By Prtmary Functional Area Template Codes

. Item Description Prl: 3A Sec:

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Prl:49 Sec:

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Procedures were adhered to, three way communications and self checking practices were utilized, and good as low as reasonably achievable practices were demonstrated during the observed surveillance tests.

A non~ted violation resulted when licensee personnel Identified that a temporary modification should have been utilized when a relief valve was removed that resulted In an alteration to the Waste Gas Surge Tank while It was operable. The licensee's evaluation of this event was thorough and the corrective actions appeared adequate to prevent recurrence.

During the leak test following the replacement of the Primary Coolant System Sample Isolation Valves, a sman pinhole leak was found by the licensee on one of the welds. During the leak test following the repair of this weld a second pinhole leak was found on another weld made during the replacement. These weld were located In piping connected to the Primary Coolant System but were normally Isolated by valves. The piping was also part of the containment boundary. The licensee Identified the root cause as the welder's mistaken belief that residual moisture had been removed from the weld area. The licensee's evaluation was that there were no significant safety Implications due to the size of the line and the amount of leakage.

On May 11, 1998, during a review of a Technical Specification Surveillance Test Procedure, It was discovered that the procedure did not fully satisfy the requirement to test the High Startup Rate Trip function (94) within seven days prior to each plant startup.Thls event was caused by a misunderstanding of the testing requirements as described In the Technical Specifications. Corrective actions Included revising the Technical Specification Surveillance Test Procedure to Include appropriate completion of the Channel Functional Test for the RPS High Startup Rate Trip function within seven days prior to plant startup; and completion of a review of other Technical Specification Survelllance Test Procedures needed for the current plant *startup which require a Channel Functional Test, to assure associated Technical Specifications have been properly addressed. No other occurrences were found.

Also, the walkdown that was performed during this outage demonstrated a positive questioning attitude and a pro-active Initiative by system engineering personnel that contributed to the identification of the le.ak on Primary Coolant Pump P-SOA. (Section E4)

Engineering personnel conducted thorough testinlJ and performed an In-depth analysis regarding the failure of the mal steam Isolation valves to close which was determined to be a maintenance preventable functional failure. lnoperabll of the main steam Isolation valves from May 29, 1998, until the condition was corrected on December 19, 1998, was a Non-Cited Violation System engineering l'ersonnel demonstrated a positive questioning attitude during the outage that contributed tQ Identifying that the primary coolant pumps' oil.collection system did not meet regulatory requirements. However, engineering personnel missed an earlier opportunity to Identify the deficiency during an engineering analysis that was conducted ln the eariy 1990's which demonstrated a lack of rigor during performance of the analysis. The Inadequate primary coolant pumps' oil collection system was a Non-Cited Violation Key Information pertaining to system status was provided to plant management during the system health assessment presentations. Documenting operator concerns and maintenance staff concerns In the system health reports Integrated the various pl_ant departments.in the process, which was considered a positive attribute.

Item Type (Compliance,Followup,Other), From 10/01/1997 To 01131/1.999

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' Date: 03/1911999 INCLUDES DRAFT ITEMS United States Nuclear Regulatory Commission Time: 08:58:13...

.'i.'

Region Ill PLANT ISSUE MA TRIX I

PALISADES By Prtmary Functional Area Functional Template Date Source Area ID Type Codes Item Descrtptlon I.

1112511998 1998019 Prl:ENG NRC POS Prl:49 To date, the safety-related battery charger and instrument inverter modification project has proceed8d wlthout any significant problems. Assigning two licensed operators to the modification team was a positive action in that It fostered Sec: OPS sec:1c a strong tie between operations and the modification work woup. The status of the new and existing~ 8Qulpment was Ter:

displayed in the control room and was continuously availab e to the control room operators, which was also a positive action.

• 1 10/07/1998 1998017 Prl:ENG NRC POS Prl: 1A The Inspectors concluded that the new computer points added to the plant computer by nuclear engineering could be Sec:

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used effectively to monitor steady state reactor power on a real time basis to ensure that the license power level would not be exceeded. Also, maintaining steady state reactor power based on a 4-hour average was considered Ter:

conservative.

10/07/1998 1998017 Prl: ENG NRC POS Prl:49 Engineering personnel provided an operability reassessment to operations regarding the control room ventilation

• Sec:

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system in a timely manner. The reassessment was thorough in that it provided operations personnel the information that was necessary to make an operability determination.

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01/22/1999 1999002-02 Prl:PLTSUP NRC VIOIV Prl:3A The inspector identified a violation involving two security procedures which detailed specific compensatory measures for Sec:

• Sec:

some degraded security equipment which were not marked as containing "Safeguards Information," and six copies of one procedure were not stored prope~. Licensee security personnel had mistakenly concluded that the Information In Ter:

the pro~dures was not Safeguards In ormation. Effective and prompt corrective action was Implemented.

01/12/1999 1998022 Prl:PLTSUP NRC POS Pr1:4C Effective dose management was demonstrated during the outage. Also, flush of the shutdown cooling heat Sec:

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exchangers, a first time evolution, demonstrated a positive pro-active initiative to reduce radiation dose rates In plant areas that were routinely toured by plant personnel, the safeguards rooms. (Section R 1. 1)

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12104/1998 1998021 Prl:PLTSUP NRC NEG Prl: 1A A,rsroblem was identified in the Simulator Control Room regarding the timeliness of the initial Alert notification to the o site agencies, Sec:

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12104/1998 1998021 Prl: PLTSUP NRC NEG Prl: 1A The OSC lacked any emergency lighting which was further evidenced by the pre-staging of a battery powered emergency light Sec:

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12104/1998 1998021 Prl: PLTSUP NRC NEG Prl: 1C A problem with the autodialer delayed event notification from the Simulator Control Room to the State of Michigan.

Later, problems with the autodialer phone line and extensions made the line inoperable.

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12104/1998 1998021 Prl: PLTSUP NRC POS Prl: 1A Overall performance during the 1998 Emergency Preparedness exercise was very good and demon.strated that emergency plan Implementation activities met regulatory requirements.

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Item Type (Compliance,Followup,Other), From 10/01/1997 To 01131/1999.

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Page: 5of8 United States Nuclear Regulatory Commission

. Date: 03.'1911999 INCLUDES DRAFT ITEMS Time: 08:58:13 PLANT ISSUE MATRIX Region Ill PALISADES By Primary Functional Area Functional Template Date Source Area ID Type Codes Item Description 12104/1998 1998021 Prt: PLTSUP NRC POS Prt: 1A Overall performance in the Simulator Control Room was good. Proper assessments of plant conditions were made by Sec:

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the crew. The transfer of command and control to the Technical Support Center's (TSC) Site Emergency Director (SEO) was orderly and rapid. Communications between the control room crew and other emergency response staff Tar:

were frequent and detailed.

12104/1998 1998021 Prl: PLTSUP NRC POS Prl: 1A The Technical Support Center (TSC) staffs performance was excellent The SED's command and control* and the TSC Sec:

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staffs communications in the facility and to staffs of other facilities were effective. Status boards were very informative and changing plant conditions were proactively monitored to ensure the emergency classification was correct Ter:

12104/1998 1998021 Prl: PLTSUP NRC POS Prl: 1A Staff performance In the Ofrerations Support Center (OSC) was excellent with rapid facility activation, well utilized status Sec:

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boards, efficient team brie ing and dispatch, and effective response to the scenario's loss of power to the OSC's lighting*

and dose tracking system.

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12104/1998 1998021 Prl: PLTSUP NRC POS Prl: 1A Overall performance of the Emergency Operations Facility (EOF~ res~onders was very competent. The EOF staff Sec:

performed their duties in an orderly and efficient manner. Trans er o command and control to the EOF Director was Sec:

smooth and effective. The Health Physics team was very effective In their assessment of the offslte Impact of the Ter:

radiological release and their related communications to the EOF Director. (

12104/1998 1998021 Prl:PLTSUP NRC PQS Prl: 1A Initial critiques following termination of the exercise were thorough and self-critical. Exercise controllers effectively Sec:

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solicited verbal and written Inputs from exercise participants.

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12104/1998 1998021 Prl: PLTSUP NRC POS Prl: 1A The actual shift supervisor provided excellent response to a real time failure of the TSC's missile door and ensured safety of the plant personnel assembled in the control room/TSC area.

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e 12/04/1998 1998021 Prl: PLTSUP NRC POS Prl: 1A A post-exerCise demonstration of the recovery procedure was very good.

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11125/1998 1998019 Prl: PLTSUP NRC POS Prl: 1A Security personnel maintained positive control of the vital area doors that had inoperable card readers during the Sec:

ongoing security system modification project.

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• 11125/1998 1998019 Prl: PLTSUP NRC POS Prl:3A Actions taken by chemistry personnel follow1n9 the Inadvertent draining of the hydrazine addition tank were timely.

Feedwater and steam generator chemistry hy razlne concentrations were restored to normal values In less than 2 Sec:

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hours.

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Item Type (Compliance,Followup,Other), From 10/01/1997 To 01/31/1999

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6 of8 United States Nuclear Regulatory Commission

. Date: 0311911999 INCLUDES DRAFT ITEMS Time: 08:58:13

. Region Ill PLANT ISSUE MATRIX PALISADES By Primary Functional Area Functional Template Ii Date Source Area ID Type Codes Item Description 11125/1998 1998019 Prl: PLTSUP NRC POS Prl:39 The fire protection depa~ent eff~ctlvely used an unannounced drill to challenge the fire brigade and;to exercise Sec:

response from off-site assistance to the fire scene.

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11125/1998 1998019 Prl: PLTSUP NRC POS Prl:5A The emergency planning personnel's critique of the emergency drill was self-critical and appropriate remediation Sec:

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training was conducted to address the identified concerns.

Ter:

e 10/3011998 1998020 Prl:PLTSUP NRC NEG Prl: 1A A miscommunication between operations personnel resulted in additional dose during an at-power containment entry.

Sec:

(Section R1-2)

Sec:

Ter:

10/30/1998 1998020 Prl: PLTSUP NRC POS Prl: 1A The Chemical and Radiological Services (C&RS) staff effectively implemented the REMP and land use census, and the Sec:

Sec:

1997 data demonstrated that there was no discemable impact on the environment from plant operations.

Ter:

. 10/30/1998 1998020 Prl: PLTSUP NRC POS Prl: *1A The radiological controls throughout the facility were well implemented and wol'X during the at-power containment entry Sec:

Sec:

was property controlled.

Ter:

10/30/1998 1998020 Prl: PLTSUP NRC POS Prl: 1A The licensee's evaluation of a specialized transportation cask determined that significant voids In the lead shleidi:lH and Sec:

Sec:

the potential for movement of the surveillance cafisule during transport were the root causes for the excessive rad aUon levels on the outer surface of the cask upon rece pt at the vendor's facility. The inspectors' review of the data indicated Ter:

that the licensee's determination was appropriate.

e 10/30/1998 1998020 Prl: PLTSUP NRC POS Prl: 1A The C&RS staff developed adequate corrective actions for REFOUT98 radiation protection violations and neither the Sec:

Sec:

plant person!lel nor NRC inspectors identified a~ recurrence. In addition, C&RS staff have conducted periodic analyses of post accident sampling monitor (PA M) samples and the results indicated that the PASM delivered a Ter:

representative sample of the primary system.

10/0711998 1998017 Prl: PLTSUP NRC NEG Prl:3c Management attention to improperlh stored fire v.ear was warranted. The deficiencies did not result in any actual Sec:

Sec:

• adverse consequences; however, t ey could de ay the fire brigades response time.

Ter:

09/0211998 1998018 Prl: PLTSUP NRC NEG Prt:3A The shipping papers for t_he radioactive material shipment were prepared in accordance with regulations, plant Sec:

Sec:

pr<?cedures. and expecta~1ons. 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 Ter:

personnel resources contributed to these deficiencies.

Item Type (Compliance,Followup,Other), From 10/01/1997 To 01/31/1999

Page:

7 of 8 INCLUDES DRAFT ITEMS Region Ill PALISADES Date Source 09/02/1998 1998018-01 Functional Area Prl: PLTSUP Sec:

ID NRC United States Nuclear Regulatory Commission PLANT ISSUE MATRIX

• Date: 0311911999 Time: 08:58:13 Type

. EEi By Primary Functional Area Template Codes Item Description Prl:

Sec:

Ter:

An apparent violation was Identified concerning the failure to transport a 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 actual root cause of the violation could not be detennlned at the time of the inspection.

Item Type (Compliance,Followup,Other), From 10/01/1997 To 01/31/1999

Page:

8 of 8 INCLUDES DRAFT ITEMS Type Codes:

BU Bulletin CDR Construction DEV Deviation EEi Escalated Enforcement Item IFI Inspector follow-up item LER Licensee Event Report LIC Licensing Issue MISC Miscellaneous MV Minor Violation NCV NonCited Violation NEG Negative NOED Notice of Enforcement Discretion NON Notice of Non-Conformance P21 Part 21 POS Positive SGI Safeguard Event Report STR Strength URI Unresolved item VIO Violation WK Weakness United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Legend Template Codes:

Functional Areas:

1A Normal Operations OPS Operations 18 Operations During Transients MAINT Maintenance 1C Programs and Processes ENG E~gineering 2A Equipment Condition.

PL TSUP. Plant Support 2B Programs and Processes OTHER Other 3A Work Performance 38 KSA 3C Work Environment 4A Design 48 Engineering Support 4C Programs and Processes 5A Identification 5B Analysis 5C Resolution ID Codes:

NRC NRC Self Seif-Revealed Licensee Licensee

. Date: 03119M999 Time: 08:58:13

• EEis are apparent violations of NRC Requirements that are being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action" (Enforcement Polley), NUREG-1600. However, the NRC has not reached its final enforcement decision on the issues identified by the EEis and the PIM entries may be modified when the final decisions are made.

URls are unresolved items about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation. A URI may also be a potential violation that is not likely to be* considered for escalated enforcement action. However, the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final conclusions are made.

Item Type (Compliance,Followup,Other), From 10/01/1997 To 01/31/1999

PLANT ISSUES MATRIX Palisades I

I

~.

3/18/199g Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Operations* ; Beginning Date = "10/111997" ; Ending Date = "3/~0/1999"

/w1 DATE 11 TYPE 11 SOURCE II ID BY II 8/24/1998 Positive IA 98015 NRC 2

8/24/1998 Negative IA 98015 NRC 3

7/1/1998 Positive IA 98010 NRC 4

7/1/1998 Positive IA 98010 NRC 5

7/1/1998 VIO/SL-IV IA 98010 NRC SALP. I I SMM CODES 11 Operations 1A Operations 28 3A Operations 1C Operations 2A 58 Operations 3A 1A Page 1 of 11 DESCRIPTION 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 posi.tive command and control during implementation of the emergency operating procedures. (Section 04)

The inspectors concluded that poor job planning by operations personnel e 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)

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).

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 ).

Proper plant configuration was not maintained during performance of surveillance refueling test (RT)-8C 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-8C 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 (Sect!on 01.3).

PLANT ISSUES MATRIX Palisades J;

i*

3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Operations' ; Beginning Date = '10/1/1997' ; Ending Date = '3130/1999' leiJI DAT~ II TYPE II souRcE 11 m av II sALP llsMM cooEsll 0EscR1PT10N II 6

7/1 /1998 NCV IA 98010 7

7/1 /1998 Positive IA 98010 8

S/6/1998 Positive IA 9800S 9

S/6/1998 Positive IA 9800S Licensee Operations NAC

. Operations NAC Operations NAC Operations 3A

• 1 C 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 A primary indicating position associated with the plant computer, contribute~

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. However, the initial actions taken by the on-shift crew to determine the cause were considered weak (Section 01.2).

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 ).

1 A The control room operators successfully operated the plant while the turbine control system was restricted to an off-normal, manual mode of operation. Coordination among crew members was good during those activities performed to shut down the plant for the scheduled refueling A

outage.. The crew transferred feed to the steam generators from the mai*

feedwater system to the auxiliary feedwater system during the plant shutdown without causing an unnecessary transient which reflected improved performance from past evolutions. (Section 04) 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 conservative 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)

P.age.2 of. 11

PLANT ISSUES MATRIX Palisades I

l!

3/18/1999 Ending Date = *~,011999*

11 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *sALP* ; SALP Area = 'Operations* ; Beginning Date = *10/1/1997" ;

1w1 DATE 11 TYPE 11 10 5/6/1998 Positive 11 5/6/1998 Negative 12 4/1/1998 Positive 13 4/1/1998 Positive 14 4/1/1998 Positive 15 4/1/1998 Negative SOURCE IR 98005 IR 98005 IR 98005 IR 98004 IR 98004 IR 98004 IR 98004 11 m ev II NRC NRC NRC NRC NRC NRC SALP. 11 SMM CODES 11 Operations 18 Operations 2A 1A Operations 1A Operations 1C Operations 1C

. Operations 1C 3A Page 3. of 11 DESCRIPTION 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 froni a failure of governor Valve #1 to close following a turbine trip. (Section 02) e 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 in 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)

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)

Mechanisms for feedback of performance weaknesses to the operators A and training staff existed. The training program feedback process W

appeared to be satisfactorily implemented. (Section 05.4)

Operator license conditions were in conformance with program guidance and regulatory requirements. (Section 05.6)

The licensee administered the operating examination in accordance with their program guidance, and regulatory requirements. The licensee displayed severa.1 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 were administered during the annual requalification examination. The licensee had an effective operating examination security program.

(Section 05.3)

PLANT ISSUES MATRIX Palisades

. 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ;* SALP Area = 'Operations' ; Beginning Date = "10/1/1997' ; Ending Date a '3130/1999' lwl DATE II TYPE II SOURCE II 1D BY II SALP llsMM CODEsll DESCRIPTION 11 16 4/1 /1998 Negative IR 98004 NRC 17 4/1/1998 VIO/SL-IV IR 98004 NRC 18 4/1/1998 Positive IR 98004 NRC 19 4/1/1998 Negative IR 98004 NRC Operations Operations 1 C 3A 5A 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 A

procedures and failed to identify those procedures for revision. (Section W 01.1) 1 C 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 improved by consistently providing expected operator actions to evaluators and developing challenging technical specification problems. (Section 05.2)

Operations 1 C 5C The remediation program was being implemented in accordance with the licensee's program and regulatory requirements. (Section 05.5)

Operations*

3A 1 C Page 4 of 11 Operator error related events were not directly attributable to inadequate or ineffective training, but rather due to a lack of application of training on the part of the operators. (Section 05.1)

PLANT ISSUES MATRIX Palisades l,

3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Operations' ; Beginning Date = '10/1/1997' : Ending Date.. '3130/1999'

/~I DATE II TYPE II SOURCE 11 io sv II SALP llsMM CODEsll DESCRIPTION II 20 3/31/1998 VIO/Sl-111 21 3/13/1998 Positive IR 97014 EA 977 569 IR 98002 NRC

• Operations 1 A 28 NRC Operations 1 A Page 5 of 11 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 weakn~~sesthin tpre-evltoldu~iontharybprepkadrationsf, com~uhnticatdions, an.d. e superv1s1on a resu e in e rea own o overs1g an coiitro1 01 operations activities. Specifically, during the preplanning of this activity, the operating crew failed to implement a plant procedure mandating that a safety assessment be conducted to ensure the system configuration was acceptable for the current plant status. The crew incorrectly removed power from all of the control rod drives without communicating that system configuration to the shift supervisor. Five of the on shift licensed operators did not realize that removing power to all of the control rod drives, during power operation, was a system configuration that the Technical Specifications only permitted for a limited time. Before removing power from all of the control rods, the operating crew erroneously referenced a previous tag out that had removed power from all of the control rod drives during shutdown conditions. The shift management team failed to exercise its oversight responsibilities by failing to stop the maintenance activity or expand the scope of the post maintenance test after observing a mechanic exceed the scope of the.

maintenance activity by removing and reinstalling additional relays. As a A result, an inadequate post maintenance test was performed because the...,

change in scope was not adequately communicated to maintenance or operations personnel. When the expanded maintenance scope was discussed with the operations manager, the post maintenance test was still not revised to include the expanded maintenance scope (EA 97-569 cover letter 4/2/98).

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).

PLANT ISSUES MATRIX 3/18/1999 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = *operations' ;

Beglnnln~ Date =

• 10/1 /1997' ; Ending Date * '3130/1999' lw1 DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION 11 22 3/13/1998 Weakness IA 98002 NAC Operations 2A 28 The inspectors noted that previously identified procedural weaknesses in 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 l9ng delay of incorporating procedure changes would have a negative impact in that licensee personnel would e be reluctant to submit additional needed procedure change requests.

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

23 3/13/1998 Positive IA 98002 NAC Operations 3A 1A The crew used procedures appropriately and completed the mitigative actions in a timely manner for the inadvertent containment high radiation

. signal and resultant containment isolation signal. Crew communications, at times, were weak (Section 04.3).

24 3/13/1998 VIO/SL-IV IA 98002 NAC Operations 3A 58 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

59. The primary concern was a lack of safety focus associated with the engineering department's review of the undogged door. The re-review and proposed corrective actions were more thorough (Section 02.1 ).

25 3/13/1998 Positive IA 98002 NAC Operations

. 5A 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 e 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) 26 3/13/1998 NCV IA 98002 Licensee Operations 5A 58 58 The licensee identified a condition outside the design basis involving inadequate procedural guidance to ensure that high pressure air is restored during a LOCA concurrent with a loss of power to the high pressure air compressors. Prompt appropriate corrective actions were taken. This was considered a non-cited violation. (Section 03.2).

Page 6 of 11

PLANT ISSUES MATRIX Palisades 3/1811999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Operations' ; Beginning Date = '10/1/1997' ; Ending Date " '3130/1999' IC!JI DATE II TYPE II souRCE 11 m sv II SALP llsMM coDEsll DESCRIPTION 11

• 27 1 /27 /1998 Positive IR 97018 NRC Operations 28 1/27/1998 Positive IR 97018 NRC Operations 29 1/13/1998 LEA LEA 98003 Licensee Operations 30

• 12/5/1997 VIO/SL-IV IR 97013 NRC Operations 1 B 38 SB The operators responded appropriately to a l9ss of component cooling 28 3A 3A 1A 1C P~ge 7 _of 11 water event that occurred on January 1, 1998. The licensee established an incident response team (IRT) to investigate the circumstances surrounding the event, and the inspectors concluded that the IRT's findings and proposed corrective actions were thorough. However, the inspectors identified several IRT weaknesses, most significantly, the e 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).

Following the discovery of a mispositioned valve at a nitrogen station, the licensee instituted an equipment status control record to enhance the operations department's control of equipment. To date, no discrepancies have been identified (Section 01.3).

Watertight door improperly latched. A maintenance worker found watertight door #59 between the East and West Engineered Safeguards

.Rooms closed but not latched. Without being closed and latched, and with no personnel in the area to properly latch the door, the door could not have performed as designed. The door is part of the wall separating the East and West Engineered Safeguards Rooms and is relied upon to prevent a flooding event from affecting both rooms. The door is also required to maintain the fire barrier between the rooms.

e 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 e_vent identified in Inspection Report No. 50-255/97008 (Section 01.2).

PLANT ISSUES MATRIX Palisades 3/18/1999 I

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Operations' ; Beginning Date = '10/1/1997' ; Ending Date a 'Jq0/1999'

\\w1 DATE 11 TYPE 11 SOURCE II 1Dev II SALP 31 1215/1997 Negative IA 97013

$elf-;

Operations Revealed 32 11 /19/1997

• Negative IA 97014 NRC Operations llsMM coDEsll 2A 1A Page 8 of 11 DESCRIPTION 11 The licensee was required to enter a second forced outage to repair relief valve RV-2013 bellows. An operator workaround for chemical volume and control system (CVCS) pressure control, in conjunction with material condition problems on the turbine stop valve bypass valves and an unusual eves system configuration~ resulted in an RV-2013 bellows failure. The inspectors concluded that adequate corrective actions had e been planned or taken to prevent recurrence of this problem (Section 01.2).

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)

PLANT ISSUES MATRIX Palisades i*

I 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Operations" ; Beginning Date = '10/1 /1997" ; Ending Date = "3/~0/1999"

\\wl oATE II TYPE II souRcE II 10 sv II sALP llsMM cooEsll 0EscR1PT10N II 33 11/19/1997 EEi 34 11 /19/1997 Negative 35 10/25/1997 Positive IR 97014 EA 97.:

569 (see 3/31/98 entry)

IR 97014 IR 97012 NRC Operations NRC Operations NRC Operations 1A 28 38 5C 5A Page 9 of 11 A severity level Ill violation was issued on April 2, 1998, regarding conduct of operation and maintenance activities (see 3/31/98 entry).

Multiple apparent violations regarding 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 e ensuring that Technical Specification limiting conditions for operations were met prior to removing the equipment from service; (3) the failure to complete the required risk-based assessment prior to maintenance; (4) the failure to perform operability testing following maintenance activities that had the potential to affect equipment operability; and (5) the failure to perform post ma.intenance 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 A

tagout and that work was performed outside the work order's scope.

'9 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)

The October 17, 1997, "A" shift licensed operators' knowledge and understanding of T/S 3.10.4 was poor. (Section 04)

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 ).

PLANT ISSUES MATRIX 3/18/1999 Palisades

~ :

I Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Operations* ; Beginning Date = "10/1/1997" l

Ending Date = "31,30/1999" 101 DATE II TYPE II SOURCE II IDBY II SALP llsMM CODEsll DESCRIPTION II 36 10/17/1997 Positive IR 97011 NRC Operations 1A The inspectors concluded that the licensee provided good management oversight during the reactor startup, including the approach to critical with a reactivity manager and reactor engineering stationed onshift to augment shift coverage. Good conservative decision making took place on several occasions, specifically: to return the plant to a hot shutdown condition by inserting regulating rods during troubleshooting and repairs to CROM 39, e 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).

37 10/17/1997 Positive IR 97011 NRG Operations 1A The licensee conservatively dedded to shut down the plant due to a relatively minor increase in containment unidentified leakage. The inspectors noted that control room operators performed well in bringing the plant to hot shutdown.

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

39 10/17/1997 Positive IR 97011 NRC Operations 1A 48 The inspectors noted that operators were thoroughly prepared for a plant e downpower and main turbine valve testing evolutions. Reactor engineering, system engineering and the procedure sponsor provided good support for these evolutions (Section 01.2).

40 10/14/1997 Misc fR 97009 NRC Operations 1A The inspectors concluded that although the Consumers Energy load 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 add.itional reliability (Section 01.3).

41 10/14/1997 Negative IR 97009 Licensee Operations 1A 3A Operators missed several opportunities to notify plant management of a step change in main turbine vibration (Section 01.2).

42 10/12/1997 LER LER 97011 Licensee Operations.

3A

.1A Starting of primary coolant pump with steam generator temperatures greater than cold leg temperatures.

. Page 1 ff of 11

3/18/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC internal editing.

I 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 d.ate or a date of identification, use the LEA or inspection report date.

TYPE The categorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the i~ue information:* IA for NRC Inspection Report or LEA for Licensee.Event Report.

ID BY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and All/Multiple {i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

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

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements

. EEis are apparent violations of NRC 1

Operational Performance:

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

Escalated Enforcement Issue - Waitinq Final NRC Action escalated enforcement action in accordance B - 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" Licensing Licensing Issue from NRA

{Enforcement Policy), NUREG-1600.

2 Material Condition:

Misc Miscellaneous (Emergency Preparedness FindinQ, 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 NeQatlve 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 Strength Overall Strong Licensee Performance are made. Before the NRC makes its B - Knowledge, Skills, and Abilities enforcement decision, the licensee will be URI**

Unresolved Inspection Item provided with an opportunity to either C

• Work Environment 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 11 (2) request a predecisional enforcement A - Design.

VIO/SL-111 Notice of Violation* Severity Level Ill conference.

B

• Engineering Support

• • URls are unresolved items about which C - Programs and Processes VIO/SL-IV Notice of Violation

• Severity Level IV Weakness Overall Weak Licensee Performance more information is required to determine 5

Problem Identification and Resolution:

whether the issue in question is an acceptable item, a deviation, a*

• A

• Identification ID BY nonconformance, or a violation. However, B *_Analysis the NRC has not reached its final C

• Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed Identification by an event (e.g., equipment breakdown) concJusioris are made.

Other Identification unknown Page 1' of 11

.PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Maintenance' ; Beginning Date = '10/1/1997' ; Ending Date.. 'W30/1999'

\\WI DATE II TYPE II souRcE 11 m ev II SALP llsMM cooEsll DESCRIPTION II 8/24/1998 Positive IA 9801S..

2 8/24/1998 Positive IA 9801S 3

7/1/1998 Positive IA 98010 4

7/1/1998 Positive IA 98010 5

S/14/1998 Negative IA 98006 6

S/14/1998 Positive IA 98006 NAC

• Maintenance 2A SA NAC Maintenance 28 NAC Maintenance 28 NAC Maintenance S8 SC NAC Maintenance 2A NAC Maintenance 28 Page 1 of 9 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 maintenance 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) e The inspectors concluded that the observed maintenance and surveillance aetivities 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 corrective actions implemented by licensee personnel were considered appropriate. (Section M1)

Overall, the inspectors observed during maintenance and surveillance activities, good procedure adherence and maintenance and radiation

• work practices (Section M1 ).

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 ).

The inspector considered ttie material condition of safety-related systems9 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-SOA, which the licensee had not previously identified. (Section M2.1)

The eddy current examination scope and methods met or exceeded the Technical Specification requirements and were consistent with licensee responses to GL 9S-03 and GL 97-0S. 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)

. PLANT ISSUES MATRIX Palisades 3118/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP' ; SALP Area = "Maintenance* : Beginning Date = *101111997* ; Ending Date s: *313011999*

IWI DATE II TYPE II souRcE 11 m ev II sALP llsMM coDEsll DEscR1PT10N II 7

5/14/1998 Negative IR.98006

• NRC Maintenance 28 8

5/14/1998 Positive IA 98006 NRC Maintenance 28 9

5/14/1998 Negative IA 98006 NRC Maintenance 28 10 5/14/1998 Negative IA 98006 NRC Maintenance 28 Page 2.of 9 The inspector found that the inservice 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-A service, that was not consistent with plant operation focused on safety. W (Section M3.1)

Overall, the inspector concluded that the licensee's implementation of the lnservice Inspection Program was consistent with Code requirements and NRC relief request commitments. The inspector considered the use of a camera mounted on a robot to perform 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)

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 A

considered an opportunity for lnservice Inspection Program

'9' improvement. (Section M7.1)

The inspector identified a lack of independent field observation with qualified personnel during audits of past and present inservice inspection activities, 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)

~

PLANT ISSUES MATRIX 3/18/1999 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Maintenance" ; Beginning Date = "10/1/1997" Ending Date.. "3130/1999" l~I DATE II TYPE II SOURCE II IDBY II SALP llsMM coDEsll DESCRIPTION 11 11 5/14/1998 Positive IA 980o6 "*

NAC 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) 12 5/14/1998 Positive IA 98006 NAC Maintenance 28 38 The licensee inservice inspection personnel performing nondestructive examination of Code Class 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) 13 5/6/1998 Negative IA 98005 NAC Maintenance 2A Several examples of maintenance cleanliness and foreign material exclusion issues were identified by licensee personnel during the early stages of the outage. Individually, the identified cleanliness and foreign material exclusion issues were considered minor; however, collectively they indicated that additional management attention in this area was warranted. (Section. M 1.1 )

14 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 e

procedural requirements existed for foreign material exclusion controls pertaining to electrical components which was a violation of regulatory requirements. (Section M3) 15 5/6/1998 Positive IA 98005 NRC 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) 16 5/6/1998 Positive IA 98005 NRC Maintenance 28 3A Overall, the inspectors observed, during maintenance and surveillance activities, good procedure adherence, and maintenance and radiation work practices. (Section M1.2)

Page 3 of 9

PLANT ISSUES MATRIX Palisades 3118/199'9 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Maintenance" ; Beginning Date = "10/1/1997" ; Ending Date.. "3130/1999" lwl DATE II TYPE II souRcE II 1D sY II sALP llsMM coDEsll DEscR1PT10N II 17 5/6/1998 Positive IR 98005

, NRC Maintenance SA 18 3/31/1998 VIO/SL-111 IR 97014, EA 97-NRC Maintenance 1 A 28 567 Page 4 of 9 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 aGldress reliability of the personnel and emergency air locks due to the safety significance of these components regarding e containment integrity as well as personnel safety. (Section M2.1)

A severity level 111 violation was issued on April 2, 1998, regarding conduct of operation and maintenance activities. Errors were made by maintenance personnel who failed to follow maintenance-related procedures when power was removed from all of the control rod drives during power operation to facilitate the repair of a single control rod drive.

Before starting the repair, maintenance personnel incorrectly 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 A

failed to exercise its oversight responsibilities by failing to stop the 9'

maintenance activity or expand the scope of the post maintenance test after observing a mechanic exceed the scope of the maintenance activity by removing and reinstalling additional relays. As a result, an inadequate post maintenance test was performed because the change in scope was not adequately communicated to maintenance or operations personnel.

When the expanded maintenance scope was discussed with the operations manager, the post maintenance test was still not revised to include the expanded maintenance scope. Inherent in the failure of the 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).

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search-Column = 'SALP' ; SALP Area = 'Maintenance' ;* Beginning Date = '10/1/1997' ; Ending Date.. '3/30/1999' lwl DATE II TYPE JI SOURCE II io BY II SALP llsMM CODEsll DESCRIPTION 19 3/13/1998 Negative 20 3/13/1998 Positive 21 2/17 /1998 LEA 22 1 /27 /1998 URI 23 1/1 /1998 LEA.

24 12/11/1997 Positive 25 12/11/1997 Positive 26 12/11 /1997 Positive IA 98002 IA 98002 LEA 98005 IR 97018 LEA 98001 IR 97017 IR 97017 IA 97017 IA 97017 NRC Maintenance. 3A 2A NRC Maintenance 3A 28 Licensee Maintenance 2A NRC Maintenance 2A Licensee Maintenance 2A NRC Maintenance 28 NAO Maintenance 28 NAO Maintenance 28 Page 5 of 9 -

Problems with control rod drive contactors continue. However, the problem associated with Control Rod Drive 35 was caused by an error in reassembly of the contactor after cleaning and inspection. Post maintenance testing for CAD 35 wa$ 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).

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

Large leak of component cooling water during power operation. A component cooling water leak on the 'A' Radioactive Waste Evaporator Distillate Cooler incre*ased from about 1 oo ml/miri 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 e

resulted in a reduction in the normal CCW Discharge header pressure of about 120 psi to 98 psi. The operators used Off Normal Procedure 6;2 for Loss of Component Cooling Water and isolated applicable components.

The leak was identified and isolated by the operators within about 15

. minutes. No abnormal component temperatures were observed and no effect on the Primary Coolant Pump seals was identified.

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

An inspection follow-up item regarding the acceptability 9f proposed changes to the reliability criterion for the reactor protection system was closed.

The licensee properly addressed all open items that were identified during the Maintenance Rule Baseline Inspection.

PLANT ISSUES MATRIX Palisades Search Sorted tiy Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Maintenance* ; *Beginning Date = "10/1/1997" Ending Date.. "3130/1999" le!JI DATE II TYPE II SOURCE 11 m sv II SALP llsMM coDEsll DESCRIPTION II 27 12/11/1997 Positive IR 97017 28 12/11/1997 Positive IR 97017 29 12/5/1997 Positive IR 97013 30 12/Si1997 Positive IR 97013 NRC Maintenance 28 NRC Maintenance 28.

NRC Maintenance 28 Maintenance 28 3A Page 6 of 9 For the three additional systems reviewed, the maintenance rule program was adequately implemented and the systems were appropriately classified.

An inspection follow-up item involving performance of periodic assessments, reliability-availability balances, and use of industry operating experience was closed.

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 had overall responsibility for scheduling and completing the repair (Section M1.2).

PLANTISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Maintenance" ; Beginning Date = "10/1/1997" ; Ending Date.. "3130/1999"

\\WI DATE 11 TYPE 11 souRcE 11 m sv II sALP llsMM coDEsll DEscR1PT10N ii 31 11/19/1997 VIO/SL-111 IR97014EA97,~

32 11/10/1997 LER 33 10/17/1997 Negative 567 (see 3/31/98 entry)

LER 97013 IR 97011 NRC Maintenance 1 A 28 Licensee Maintenance 28.

NRC Maintenance 2A 1 A Page 7 of 9 A severity level Ill violation was issued on April 2, 1998, regarding conduct of operation and maintenance activities (see 3/31/98 entry).

Multiple apparent violations regarding maintenance activities occurred which included: (1) the failure to satisfy the control rod drive system conditions required by the maintenance procedure; (2) the failure to 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 required.

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

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.

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 ).

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Maintenance* ; Beginning Date = *101111997* ; Ending Date.. "3130/1999" IC!JI DATE II TYPE II souRcE II 1D sv II SALP llsMM coDEsll DESCRIPTION.

II 34 10/17/1997 VIO/SL-IV 35 10/17/1997 36 10/14/1997 LER Misc IR 97011 LEA 97012 IR 97009 NRC Maintenance 28 Licensee Maintenance 28 38 NRC Maintenance 28 Page_ a of 9 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 gasA sample. The use of the procedure should have caused operators to W

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).

CONTROL RODS DEENERGIZED WHILE IN POWER OPERATION 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 testing evolution was performed in an orderly manner with appropriate controls in place (Section M 1.1 ).

3/18/1999 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 the LEA or inspection report date.

TYPE The categorization of the issue

• see the TYPE ITEM CODE table.

SOURCE The document that contains the is,s.ue i~formation~. IA for.NRG Inspection Report or LEA for Licensee Event Report.

ID BY Identification of who discovered the issue* see table.

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

SMM CODES Senior Manager Meeting Codes

• see table.

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

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

. EEis are apparent violations of NRG 1

Operational Performance:

ED Escalated Discretion

• No Civil Penalty requirements that are being considered ior A* Normal EE1*

Escalated Enforcement Issue* Waiting Final NRG.Action escalated enforcement action in accordance B

• During Transients LEA License Event Report to the NRG with the "General Statement of Policy and C

• Programs and Processes Procedure for NRG Enforcement Action" Licensing LicensinQ Issue from NRA (Enforcement Policy), NUREG-1600.

2 Material Condition:

Misc Miscellaneous (EmerQency Preparedness Finding, etc.)

However, the NRG has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B

• Programs and Processes Negative 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 Strenqth Overall Strong Licensee Performance are made. Before the NRG 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 predecisional enforcement A* Design VIO/SL-111 Notice of Violation - Severity Level Ill conference.

B

• Engineering Support VIO/SL*IV Notice of Violation - Severity Level IV

• • URls are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Performance more information is required to determine 5

Problem Identification and Resolution:

whether the issue in question is an acceptable item, a deviation, a A

• Identification IDBY nonconformance, or a violation. However, 8 *Analysis the NRC has not reached its final C

• Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear ReQulatorv Commission entries may be modified when the final Self-Revealed Identification by an event (e.o., equipment breakdown) conclusions.are made.

Other Identification unknown Page.~ of 9

PLANT ISSUES MATRIX Palisades 3118/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ;. SALP Area = 'Erigineerlng' ; Beginning Date = '10/1/1997' ; Ending Date.. '3130/1999'

\\GJI DATE II TYPE II souRcE 11 m sv II SALP llsMM cooEsll DESCRIPTION II 8/24/1998 Positive IA98015 NAC Engineering 48 58 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 1 A trip was thorough.

(Section E2) 2 7/24/1998 Positive IA 98012 NAC 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).

3

.7/24/1998 Positive IA98012 NAC Engineering 48 1A Surveillance Test Procedure M0-7A-1 for the diesel generator went beyond the specific warning contained in IN 97-16 to assure that any adverse condition found concerning liquid in the cylinderswould be formally documented and evaluated (Section E2.1 ).

4 7/24/1998 Positive IA 98012 NAC Engineering 48 4C Overall, the 10 CFA 50.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 eva!uations (Section E3.1 ).

s 7/24/1998 Positive IA 98012 NAC 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 because the conditions were not precisely the same as those at Palisades, rather than taking the broader view of how 9-and where there were si.milarities (Section E2.1 and E7.3).

6 7/24/1998 Positive IA 98012 NAC Engineering 4C SA Overall, for the S1 CAs reviewed, the corrective actions taken were good and root cause determinations* 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 E1.1 ).

7 7/24/1998 VIO/SL-IV IA 98012 NAC 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 ).

Page 1 of 12

PLANT ISSUES MATRIX Palisades 3118/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Engineering* ; Beginning Date = *10/1/1997' ; Ending Date.. '31301199£1*

lwl DATE II TYPE II SOURCE II 1D BY II SALP. llsMM CODEsll DESCRIPTION 8

7/24/1998 Positive IA 98012 9

7/24/1998 Positive IA 98012 10 7/24/1998 Positive IA 98012 11 7/1/1998 Misc IR 98010 12 7/1/1998 NCV IR 98010 13 7/1/1998 NCV IA 98010 NAC.

Engineering SA NAC Engineering SA NRC Engineering SC SB NRC

• Engineering.

• 2B Licensee Engineering 3B Licensee Engineering. SA Page 2 of 12 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 CAs written against themselves to be negative. *Overall, the licensee has been effective in the identification and resolution of problem9, (Section E7.2).

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.

Areas of concern identified by audit findings were promptly and effectively

• corrected (Section E7.4).

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).

The licensee struggled with planning and execution of the primary coolant pump lube oil system modifications. The licensee is aware that planningai and completing modifications is an area for improvement, but as yet has 9' been unsuccessful in resolving the problems (Section E2.1 ).

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 functional test. 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).

Inadequate auxiliary feedwater pump low suction pressure trip setpoints (Section E8.4).

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Engineering' ; Beginning Date = '10/1/1997' ; Ending Date.. '3/3011999'

\\wl DATE II TYPE 11 souRcE II 1D sv II sALP

• 11sMM coDEsll DEscR1PT10N II 14 6/4/1998 NCV IR 98011..

15 6/4/1998 NCV IR 98011 16 6/4/1998 URI IR 98011 17 6/4/1998 Positive IR 98011 18 6/4/1998 Positive IR 98011 19 5/14/1998 IR 98006 20 5/6/1998 Negative IR 98005 21 5/6/1998 Positive IR.98005 Lioensee Engineering 4A Licensee Engineering 4A NRC Engineering 48 NRC Engineering 58 5C NRC Engineering 5C

• 48 NRC Engineering 4C NRC Engineering 38 48 NRC Engineering 48 Page 3 of 12 The EOG fuel oil supply and associated piping did not meet licensing basis (Section E8.7).

Class 1 E and non-Class 1 E circuits were not isolated or separated as required by the FSAR (Section E8.8)

The engineering staff was effective in the identification and resolution of 9' 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) 50-255/98011-03 and URI 50-255/98011-04, respectively).

Corrective actions and root cause analyses were acceptable (all sections).

System engineering involvement in the corrective action process was good (all sections).

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)

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 control systems. (Section E4)

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 supported these activities in a timely manner. (Section E1.1)

PLANT ISSUES MATRIX 3/18/199.9 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Engineering" ; Beginning Date = "10/1/1997" ; Ending Date * '313011999'

\\01 DATE II TYPE II SOURCE II ID BY II SALP llsMM cooesll DESCRIPTION 11 22 S/6/1998 Positive IA 9800S...

NRC Engineering 48 4C The inspectors noted that the follow-up to correct identified deficiencies with inservice testing requirements was thorough. However, system engineering supervision relied on engineering personnel to identify errors in the IST program data base. (Section E2) 23 4/10/1998 VIO/SL-IV IA 98003 NRC Engineering 4A SA A violation was identified for problems with the origi.nal p*lant design: Two 9 vent pipes, which connected the containment sump to the S90 ft.elevation of the containment, did not have screens ir:istalled 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.

24 4/10/1998 DEV IA 98003 NRC Engineering 4A SA A deviation from a commitment to Regulatory Guide (AG) 1.97 was identified when CCW flow could not be measured from 0-110 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.

2S 4/10/1998 VIO/Sl-IV IA 98003 NRC Engineering 48 3A Failure to follow procedures resulted in a violation. Test results could not be located to verify that testing had been completed during the 199S e refueling outage for overcurrent relays for supply breakers 1 S2-1 OS and 1S2-106 to Bus 1 C as required by the procedure.

26 4/10/1998 VIO/Sl-IV

• IA 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.S feet (cabinet height +S feet).

27 4/10/1998 VIO/SL-IV IA 98003 NRC 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.

Page _4 of 12

i PLANT ISSUES MATRIX 3/18/1999 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Engineering* ; Beginning Date = '10/1/1997' ; Ending Date " '3130/1999' lw1 DATE II TYPE II SOURCE II ID BY II SALP llsMM coDesll DESCRIPTION II 28 4/10/1998 VIO/SL-IV IR 98003 -, _

NRC Engineering 4B 3A SA Failure to follow procedures resulted in a violation. Fi'(e 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.

29 4/10/1998 VIO/SL-IV IR 98003 NRC Engineering 4B 4C A violation was identified for a recent failure to scope and include in the e 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.

30 4/10/1998 DEV IA 98003 NRC Engineering 4B SC A deviation from a commitment to RG 1.6 was identified when a design change moved the backup power source to a redundant power source, which resulted in Bus Y-01 being able to automatically transfer betwe-en two safety related busses.

31 4/10/1998 Positive IR 98003 NRC 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.

32 3/13/1998 Negative IA 98002 NRC Engine~ring 2A SC 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 ).

e 33 3/13/1998 NCV IR 98002 NRC Engineering 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 monitoring system. The proposed corrective actions were considered thorough. This was considered a non-cited violation (Section E7).

34 1/27/1998 NCV IR 97018 NAC Engineering 1A 2B 4B During a closeout of a licensee event report, the inspectors identified a non-cited violation for failure to meet Technical Specifications testing requirements of the emergency escape air lock (Section EB.3).

Page S of 12

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Engineering* ; Beginning Date = '10/1/1997' ; Ending Date.. '3130/1999' I[!] I DATE II TYPE II SOURCE II ID BY II SALP 11 SMM CODES II DESCRIPTION 35 1/27/1998 VIO/SL-IV 36 1/27/1998 ED 37 1/27/1998 Negative IR 97018 IR 97018 EA 96-131IR97011 LEA 97-010 IR 97018 NRC NRC NRC Engineering Engineering Engineering 2A During follow up to a March 1997 failure of CV-3018 to reposition, the inspectors concluded that the corrective action for air 'line filter placement for pressure control valves (PCVs) was inadequate In that the licensee failed to correct a previously identified condition adverse to quality. The inspectors further concluded that placement of low point drains In the air A lines leading to the PCVs was inadequate. The low point drain problem W 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 ).

2A 48 4C Three 1 O CFR 50, Appendix R, issues were of concern because of the safety significance associated with plant equipment configuring that did not meet 10 CFR Part 50, Appendix R, safe shutdown requirements for a design basis fire. These issues would normally be designated as a Severity Level Ill problem in accordance with the NRC's NUREG-1600, "General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy). However, enforcement discretion will 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 consideration of the following: 1) significant NRC enforcement action (EA 96-131) was taken against the Consumers Energy Company for several examples of a failure to take prompt corrective actions related to Appendix R deficiencies. Palisades identified the issues detailed above 9 and promptly notified the NRC; 2) corrective actions were immediate and encompassed the root causes for these issues; 3) some of the issues were related to activities that were in progress before the enforcement action was issued; 4) the issues would not be classified at a severity level higher th.an Severity Level Ill; and 5) Consumers Energy Company met with the NRC to explain their efforts to resolve these issues, which were outlined in their reply dated September 12, 1996.

3A Thei 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).

Page 6'of 12

PLANT ISSUES MATRIX Palisades 3118/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Engineering' ; Beginning Date = '10/1/1997' ; Ending Date.. '3130/1999' I[!] I DATE II TYPE 11 SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION 38 1/1211998 LER LER 98002 :,..

Licensee' Engineering 4A 48 39 12/5/1997 Positive IR 97013 NRC Engineering 48 40 12/5/1997 Positive IR 97013 NRC Engineering 48 41 11/14/1997 Negative IA 97201 NRR NRC Engineering 2A 3A 42 11/14/1997 Negative IR 97201 NRR NRC Engineering 3A 28 Page 7 of 12 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.

The inspectors determined that the licensee's actions were adequate to A address the atmospheric dump valve hot short Appendix R scenario and W rebaselining of fire dampers and barriers. The inspectors also concluded that the Appendix R review team was adequately staffed and supported.

However, the inspectors were concerned with plans to potentially reduce the Appendix R evaluation effort should resources be needed to support the upcoming 1998 refueling outage. The inspectors also stressed the importance of a timely response to the longstanding Appendix R issues (Section E1.1 ).

The engineering department's operability evaluation and assistance for preparations for the repairs to main steam isolation valve (MSIV) MO-051 O were thorough. The engineering department's efforts had improved over those associated with previous similar MSIV repairs (Section E1.2)..

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 improper!

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.

The team identified several valves that performed a safety function which were not included in the in-service testing (IST) program. Check valves in the high pressure SI (HPSI) pump minimum-flow recirculation lines, which prevented overpressurization of HPSI pump suction lines, were not tested to verify closure. There were requirements for closure of the safety injection tank vent valves and operation of the relief valve Inside containment on the CCW return line in the event of an accident.

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

PLANT ISSUES MATRIX Palisades*

3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'En.gineering' ; Beginning Date = '10/1/1997' ; Ending Date.. '3/30/1999' j[!]I DATE II TYPE II SOURCE II 1D BY II SALP llsMM CODEsll DESCRIPTION II 43 11 /14/1997 Negative IR 97201 NRR..

NRC Engineering 3A 4A 44 11 /14/1997 Negative IR 97201 NRR NRC Engineering 4A 45 11/14/1997 Negative IR 97201 NRR NRC Engineering 4A Page Bof* 12 The team identified numerous deficiencies in the control and performance of calculations. Several calculations were not updated when analytical inputs changed, such as SI pump horsepower inputs to the emergency diesel generator loading calculation and load changes, which affected the main electrical load analysis. Errors in calculations included failure to A

consider specific uncertainty values in instrument setpoint calculations W

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 acceptability of the de system. Failure to maintain design-basis calculations current was apparently due, in part, to a weakness in the transfer of information between engineering groups.

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 activities.

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

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

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column =

0 SALP 0

SALP Area =

0 Engineering* ; Beginning Date = "10/1/1997" ; Ending Date = "3130/1999' IGJI oATE II TYPE II souRcE 11 m ev II sALP llsMM cooEsll 0EscR1Pr10N II 46 11 /14/1997 Negative IR 97201 NRR..

NRC 47 11/14/1997 Negative IR 97201 NRR NRC 48

• 11 /14/1997 Negative IR 97201 NRR NRC 49 11 /14/1997 Positive IR 97201 NRR NRC Engineering 4A Engineering 4A 48 Engineering 4A 48 Engineering 4A 4C

_ P~ge 9 of 12 The licensee had no evidence that the CCW pumps met the vendor-recommended minimum flow requirement under all operating conditions.

A preliminary analysis showed that the flow was adequate to meet a revised vendor recommendation. The team identified other instances in which the design basis was not adequately documented. No analysis was available to show that the de loads would operate at the minimum W

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.

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.

Other discrepancies included a potential-path for debris to bypass the containment sump screens, installation of incorrectly rated solenoid coils, incorrect implementation of the design-basis lifetime of Agastat time delay relays, incomplete evaluation of a 1 O CFR Part 21 notification concerning Agastat relays, and a missed surveillance for safety-related overcurrent relays. The team also identified a number of discrepancies in the FSAR,.

080s, and other plant documents.

e 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 08Ds reviewed provided comprehensive information for personnel involved in plant modifications and evaluations. Operability assessments performed during the course of the inspection were comprehensive.

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Engineering* ;. Beginning Date = "10/1/1997" ; Ending Date.. "3130/1999" I[!] I DATE 11 TYPE 11 SOURCE 11 ID BY 11 SALP 11 SMM CODES 11 DESCRIPTION SO 11/14/1997 Negative IR 97201 NRR..

NRC Engineering 4C S 1 11 /14/1997 Positive

• IR 97201 NRR NRC Engineering SC S2 10/17 /1997 Positive IR 97011 NRC Engineering 48 S3 10/14/1997 Positive IR 97009 Licensee Engineering 18 2A S4 10/14/1997 Negative IR 97009 NRC

• Engineering 28 5S 10/14/1997 Positive IR 97009 NRC Engineering 5A Page 10 of 12 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 W

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.

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 ).

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 e 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 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 respective systems. (Section E1.4).

PLANT ISSUES MATRIX Palisades 3i1e11999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column.: "SALP" ; SALP Area = "Engineering* ; Beginning Date = "10/1/1997" ; Ending Date a "3130/1999"

\\C!JI DATE II TYPE. II SOURCE II 1D ev II SALP llsMM CODEsll DESCRIPTION II 56 10/14/1997 Negative IR 97009 :,..

NRC Engineering 5A 58 5C Page 11 of 12 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 ).

3/18/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NRC internal editing.

DATE The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. For issues that do not have an actual date or a date of identification, use the LEA or inspection report date.

TYPE The categorization 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.

ID BY Identification of who discovered the issue - see table.

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

SMM CODES Senior Manager Meeting Codes - see table.

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

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements

. EEis are apparent violations of NRC 1

Operational Performance:

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

Escalated Enforcement Issue - Waiting Final NRC Action escalated enforcement action in accordance B - 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 Licensing Issue from NRA

. (Enforcement Policy), NUREG-1600.

2 Material Condition:

Misc Miscellaneous (Emergency Preparedness Findinq, 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 Strenath Overall Strong Licensee Performance are made. Before the NRG makes its B - Knowledge, Skills, and Abilities enforcement decision, the licensee will be URI..

Unresolved Inspection Item provided with an opportunity to either C - Work Environment VIO/SL*I 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 predecisional enforcement A - Design VIO/SL-111 Notice of Violation - Severity Level Ill conference.

B - Engineering Support VIO/SL-IV Notice of Violation - Severity Level IV

• • URls are unresolved items about which C - Programs and Processes Weakness Overall Weak Licensee Performance more information is required to determine

• s Problem Identification and Resolution:

whether the issue in question is an A - Identification acceptable item, a deviation, a IDBY nonconformance, or a violation. However,*

B - Analysis the NRC has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed Identification by an event (e.g., equipment breakdown) conclusions are made.

Other Identification unknown Page.12 of 12

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending):. Search Column = "SALP" ; SALP Area = "Plant Support" ; Beginning Date = "10/1/1997" ; Ending Date.. "3130/1999" lwl oATE II TYPE II souRcE II m av II sALP llsMM cooEsll 0EscR1PT10N II 9/2/1998 EEi IR 98018 *,,

Self-Revealed 2

9/2/1998 Negative IR 98018 NRC 3

8/24/1998 Positive IR 98015 NRC 4

8/14/1998 Negative IR 98016 NRC 5

8/14/1998 Positive IR 98016 NRC 6

8/14/1998 Positive IR 98016 NRC Plant Support Plant Support Plant Support Plant Support Plant Support Plant Support 1C 3A 1A 1C.

1C 3B 2A 1C Pag~ 1of 13 An apparent violation was identified concerning the failure to transport a 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 actual root cause of the violation could not be determined at the time of e the inspection. (Section R 1.1)

The shipping papers for the radioactive material shipment were prepared 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 ).

The inspectors concluded that the fire brigade responded to a minor electrical fire wearing the appropriate safety gear in a timely manner and that the post-fire critique was effective. A plant wide generic communication and a procedure change request appropriately addressed the licensee identified deficiency regarding individual responsibilities for plant personnel during a fire: (Section F4)

With one exception, reviewed sections of ttie emergency plan and implementing procedures were consistent with regulatory guidance.

A Approved staffing commitments were not consistent with regulatory W'

guidance. The EP staff is evaluating this issue. The emergency implementing procedures were very detailed and thorough. (Section P3)

Overall, the EP program had been maintained in an effective state of operational readiness. Management support to the program was apparent and interviewed key emergency response persc,mnel.

demonstrated competent knowledge of responsibilities and emergency procedures. (General)

The inspected emergency response facilities, equipment, supplies, and prompt alert and notification system sirens were well-maintained.

Semiannual augmentation tests have been acceptably conducted by the licensee. (Section P2.1)

PLANT ISSUES MATRIX 3/18/1999 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Plant Support* ; Beginning Date = *1011Ji997* ; Ending Date.. *313011999*

\\w1 DATE* II TYPE II SOURCE II 1DBY II SALP llsMM coDesll DESCRIPTION 11 7

8/14/1998 Positive IR98016 "*

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 P5) e 8

8/14/1998 Positive IA 98016 NRC Plant 5A The licensee's 1997 and 1998 EP program audits were effective and Support satisfied the requirements of 10 CFR 50.54(t). (Section P7) 9 7/29/1998 Positive IR98013.

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) 10 7/29/1998 Positive IA 98013 NRC Plant 1C During this inspection period, minimai"amounts of combustible material Support were noted in the plant. The material condition of most fire protection 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) 11 7/29/1998 Negative IA 98013 NRC Plant 1C A potential weakness was noted in the control of combustible materials 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 e 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) 12 7/29/1998 URI JR 98013 NRC Plant 4A The hydraulic calc.ulation 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).

Page 2 of 13

PLANT ISSUES MATRIX 3/18/1999 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Plant Support' ; Beginning Date = '10/1/1997' ; Ending Date.. '3130/1999'

\\w1 DATE II TYPE II SOURCE II IDBY II SALP llsMM coDesll DESCRIPTION II 13 7/29/1998 URI IR 98013.,,,

NRC Plant 4A-The corrective actions modifying 16 MOV circuits for the conditions Support identified in Information Notice 92-18 did not address the consequences of multiple hot shorts. The new cables/conductors, installed during the modifications, remained susceptible to shorts to grounds and shorts between cable conductors. The current circuit design appeared to be e contrary to the requirements of 1 O CFR 50, Appendix R, Section 111.G.2.

This is an unresolved item pending generic resolution of multiple hot short circuit analysis requirements. (Section F2.2) 14 7/29/1998 Negative IR 98013 NRC Plant 5A 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) 15 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 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 ).

16 7/10/1998 Positive IR 98014 NRC Plant 1C The C&RS staff conducted the daily, monthly, and quarterly channel e 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).

17 7/10/1998 Positive IR 98014 NRC Plant 1C The Chemical and Radiological Services (C&RS) and operations staffs Support effectively coordinated and controlled the activities associated with the fu~I 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 R1.1).

Page 3. of 13

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Plant Support' ; Beginning Date = '10/1/1997' ; Ending Date.. '3/30/1999'

\\wl DATE II TYPE II souRcE II 1D av II sALP llsMM coDEsll DEscR1PT10N II 18 7 /1 O/f998 Negative 19 7 /1 /1998 Positive

• 20 6/1 /1998 Positive 21 6/1/1998 NCV 22 6/1/1998 Strength 23 6/1 /1998 Negative

. IR 98014 NRC IR 98010 NRC IR98009 NRC IR 98009 Licensee IR 98009 NRC IR 98009 NRC Plant Support Plant Support Plant Support Plant Support Plant Support Plant Support 1C 3A 1C 1C 1C 1C 1C 3A Page 4 of 13 The management of the personal contamination monitors was effective, as evidenced by the successful completion of calibrati.ons 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 addition, the low limit fail setpoints for the PCM-1 Bs were not set e

conservatively (Section R2.3).

Radiological practices observed during the maintenance activities and

'plant walkdowns were adequate (Section R8.1 ).

The ALARA/work planning and implementation for the hot spot retrieval from the reactor floor vacuum was well done. The pre-job brief was thorough, the work control was effective, and the task was accomplished for 55% of the dose estimate (Section R4.3).

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 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).

A 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 A1.2).

Sinc.e 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&AS was evidence of continuing communication problems, and indicated a weakness in the work planning process (Section R4.5).

PLANT ISSUES MATRIX 3/18/1999 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' : SALP Area = 'Pla_nt Support' ; Beginning Date = '10/1/1997' ; Ending Date * '3130/1999' IC!JI DATE II TYPE II SOURCE II ID BY II SALP llsMM coDesll DESCRIPTION 24 6/1/1998 VIO/SL-IV IR 98009 *..

NRC Plant 1C 3A 5C A review of REFOUT98 radiological incidents and condition reports, and Support interviews with health physics technicians, indicated that there was inadequate oversight of outage activities - particularly for work conducted by contract personnel. THREE violations (with multiple examples) of basic radiation protection requirements were identified. Although the e 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 protection program at the station (Section R4.2}.

25 6/1/1998 Positive IR 98009 NRC Plant 2A The licensee successfully completed crud bursts during an earlier cold Support shutdown in 1998 and in REFOUT98, which reduced the primary coolant system (PCS) source term by approximately 500 curies. However, the reduction of steam generator dose rates was less th~n expected. The use of new resins improved PCS lithium removal and installation of 0.1 micron PCS filters should further reduce the source term (Section R1,3).

26 6/1/1998 Negative IR 98009 NRC 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 severa19 opportunities to improve the process (Section R4.4).

27 6/1/1998 NCV IR 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 REFOUT98 which indicated a poor understanding of radiation protection requirements and expectations. The C&RS 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 RWP (Section R4.1}.

28 5/8/1998 Negative IR 98008 NRC 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)

.*Page 5 of 13

PLANT ISSUES MATRIX*

3/18/1999 Palisades Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = "Plant Support* ; Beginning Date = "10/1/1997" ; Ending Date * "3130/1999" IGJI DATE II TYPE II SOURCE II ID BY II SALP llsMM coDEsll DESCRIPTION II 29 S/8/1998 Negative IR 98008 *,.

NRC Plant 3A SA..

The inspector identified that required reviews of some security and Support contingency procedures were not documented. The licensee initiated corrective measures to ensure that completed procedure reviews are properly documented. (Section S3.1) 30 S/8/1998 Positive IR 98008 NRC Plant 3A SB SC Security personnel generally demonstrated an appropriate level of e

Support awareness and knowledge of security requirements to effectively implement security plan requirements and to respond to routine security issues and reactive problems. Security management was properly focused to address security issues. (Section S4) 31 S/8/1998 Negative IR 98008 Licensee Plant 3A SC 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) 32 S/6/1998 Positive IR 9800S NRC Plant 1C The inspectors concluded that radiological practices observed during Suppo*rt maintenance activities and plant daily walkdowns were adequate.

(Section R8.1) 33 3/13/1998 Positive IR 98002 NRC Plant 1C 3A Emergency Planning personnel effectively used an emergency drill to Support accomplish stated objectives and to conduct training. The problems associated with an untimely response of a search and rescue team e identified last year was not evident during this drill (Section PS).

34 3/13/1998 Negative IR 98002 NRC Plant SA SC The inspectors identified a common misunderstanding among licensee Support personnel for the posted radiological requirements applicable to 2400 volt electrical Bus 1 C. Prompt and thorough corrective actions were taken (Section R8.1 ).

3S 2/16/1998 LEA LEA 98004 Licensee Plant 4A 1c Discovery of Card Reader Vulnerability and Incorrect Compensatory Support Measures Taken 36 1/27/1998 Positive IR 97018 NRC Plant 3A The inspectors concluded that radiological practices observed during the Support maintenance activities and plant daily walkdowns were adequate.

. Page6 of 13

PLANT ISSUES MATRIX Palisades 3118/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" : SALP Area = "Plarit Support* : Beginning Date = "10/1/1997" : Ending Oate = "3130/1999" I[!] I DATE II TYPE II SOURCE II ID BY II SALP II SMM CODES II DESCRIPTION 37 1 /16/1998 Negative IR 97016 38 1 /16/1998 Weakness IR 97016 39 1 /16/1998 Positive IR 97016 40 1 /16/1998 Positive IR 97016 41 1 /16/1998 Positive IR 97016 NRC NRC NRC NRC NRC Plant Support Plant Support Plant Support Plant Support Plant Support 1C 1C 3A 2A.

2A 2A Page_7'of. 13 Infrequent evolutions were generally well managed and expended reasonable radiation dose. However, the sludge solidification work exceeded the dose estimate partially due to the vendor's incorrect determination, based on cursory analyses, that sludge from the chemistry/laundry tank was compatible with the solidification process.

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

C&RS personnel have experienced communication problems with other 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 R1.4, R4.1, R4.3, and R4.4).

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

The make-up water system was well maintained and well managed, and the system effectively met plant needs for ultrapure water. The reliability ~

and materiel condition of the various components were very good, as "W'

evidenced by the recent exceptional operating history (Section R2.1 ).

The licensee conducted effective oversight of the control room heating, 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).

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Plant Support' ; Beginning Date = '10/1/1997' ; Ending Date = '313011999'

\\GJI DATE II TYPE II souRCE II 10 BY II SALP llsMM cooEsll DESCRIPTION II 42 1 /16/1998 URI 43 1/16/1998 Negative 44 1/16/1998 Positive 45 1 /16/1998 Positive IR 97016 *.*

NRC IR 97016 NRC IR 97016 NRC IR 97016 NRC Plant Support Plant Support*

Plant Support Plant Support 2A 2A 2A 5A 28 Page a of 13 The materiel condition and mechanical isolation performance of the 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 exceeding the shelf life of the iodine cartridge and the radiochemistry laboratory did not have a calibrated geometry to A

analyze this cartridge. Discrepancies in various documents indicated W

inattention to detail. As the licensee may not have been able to sufficiently determine the iodine release in sta.ck effluents under accident conditions, this issue is being considered an Unresolved Item (Section R2.4).

The training and inventories for the post accident sample monitoring (PASM) system were conducted in 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).

Overall, the quality assurance and materiel condition of the laboratory and in-line instrumentation were very good, as evidenced by function checks and laboratory inter/intracomparison data. However, staff experienced.

communication problems regarding calibration of the gamma spectrometry system and infrequent problems with various chemical analyses (Section R7.1 ).

Station staff conducted effective oversight of the respiratory protection program, as the surveillances and maintenance were satisfactorily completed as required. The equipment was in good working order and was cleaned and stored appropriately. Personnel using the equipment were properly trained, medically qualified, and properly fit-tested (Section R1.3).

e

PLANT ISSUES MATRIX Palisades 3/18/1999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = 'Plant Support' ; Beginning Date = '10/1/1997' ; Ending Date.. "3130/1999"

\\WI oATE II* TYPE II souRcE 11 m sv II sALP llsMM cooEsll 0EscR1PT10N II 46 1/16/199~

VIO/SL-IV.

IR 97016 "**

NRC 47 1/16/1998 Positive IR 97016 NRC 48 1 /16/1998 Positive IR 97016 NRC 49 1 /16/1998 Positive IR 97016 NRC 50 1215/1997 Positive IR 97013 NRC.

Plant Support 3A Plant 5A Support Plant 5A Support Plant

• 5A Support

• Plant 5A Support Page 9 of 13 One violation for the failure to post the high radiation area In the waste gas surge tank room was identified. Poor communications between the operations and Chemistry and Radiological Services (C&RS) departments was a significant contributing factor for this occurrence. In particular, the control room operators did not communicate sufficiently A

with C&RS regarding plant evolutions and the C&RS staff exhibited a narrow focus in their communications with operations staff (Section R1.4).

ALARA post-job reviews were well done and these 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 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 R7.2).

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 the existence of one fuel defect, which is probably. a large pinhole leak. The inspectors concluded thai ih~

fuel integrity group utilized appropriate methodology for this determinatiolW (Section R1.2).

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 tirneliness concerns (Section P1.1).

PLANT ISSUES MATRIX Palisades 3ha119g9 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' ; SALP Area = 'Plant Support' ; Beginning Date = '10/1/1997' ; Ending Date.. '3130/1999' lwl DATE II TYPE II souRcE II 1D sv II sALP llsMM coDEsll DEscR1PT10N II 51 11/7/1997 VIO/SL-IV IR 97015

~.

NRC 52 11/7/1997 VIO/SL-IV IR 97015 NRC 53 11/7/1997 VIO/SL-IV IR 97015 NRC 54 11 /7/1997 Positive IR 97015 NRC Plant Support Plant Support Plant Support Plant Support 3A 3A 3A 38 Page 10 of 13 One violation for the failure of a health physics technician to be aware of dose rate levels or have a radiation dose rate mete~ 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 A

the downed high radiation area posting was correct, and the lack of a W

clear communication. of management expectations were identified as weaknesses (Section R4.1 ).

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 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).

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

Other postings that were inconsistent or lacked the proper material to

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

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

PLANT ISSUES MATRIX Palisades 3/18/1999-oJ Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column =' 'SALP' ; SALP Area = 'Plant Support' : Beginning Date = '10/1/1997' : Ending Date = '3130/1999' lwl DATE II TYPE II SOURCE 11 m BY II SALP llsMM CODEsll DESCRIPTION 11 55 11 /7 /1997 Positive IR 9701 S *..

NRC 56 10/25/1997 Positive IR 97012 NRC 57 10/25/1997 Positive IR 97012 NRC SB 10/25/1997 Positive IR 97012 NRC 59 10/2S/1997 Misc IR 97012 NRC

• .Plant Support Plant Support Plant Support Plant Support Plant

. Support SB 1C 1C 3A SA SC Page 11 of 13 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

.A reluctance for initiating condition reports due to unclear management expectations (Section R7.1 ).

The radiological effluents program was well managed and implemented in accordance with the Technical Specifications (TS) and OOCM. 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).

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

Engineering staff effectively identified and 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 conditio.n 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 ).

PLANT ISSUES MATRIX Palisades 3J1a11999 Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' : SALP Area = 'Plant Support' ; Beginning Date = '10/1/1997' ; Ending Date = '3130/1999'

!CUI DATE II TYPE II.

souRcE 11 m BY II SALP llsMM CODEsll DESCRIPTION II 60 10/17 /1997 Positive IR 97011 *..

NRC Plant Support 28 Page f2 of 13 The licensee's actions to improve the resin transfer process resulted in an error-free evolution for the spent fuel pool job (Section R 1.1 ).

r*

t I 3118/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS A counter number used for NAC internal editing.

DATE The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. For issues that do not have an actual date or a date of identification, use the LEA or inspection report date.

TYPE The categorization of the issue

• see the TYPE ITEM CODE table.

SOURCE The document that contains the i~~ue information: IA 'for NAC Inspection Report or LEA for Licensee Event Report.

ID BY Identification of who discovered the issue

• see table.

SALP SALP Functional Area Codes

• Engineering, Maintenance, Operations, Plant Support and All/Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes

• see table.

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

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NAC Aeauirements

. EEis are apparent violations of NAC 1

Operational Performance:

ED Escalated Discretion

• No Civil Penalty requirements that are being considered for A* Normal EEl 0

Escalated Enforcement Issue* Waiting Final NAC Action escalated enforcement action in accordance B

• During Transients LEA License Event Report to the NAC with the "General Statement of Policy and C - Programs and Processes Procedure for NAC Enforcement Action" LlcenslnQ LicensinQ Issue from NRA (Enforcement Policy), NUAEG-1600.

2 Material Condition:

Misc Miscellaneous (Emeraencv Preparedness FindinQ, etc.)

However, the NAC has not reached its final A

• Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B

• Programs and Processes NeQatlve 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 StrenQth Overall Stronq 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*I Notice of Violation

• Severity Level I (1) respond to the apparent violation or 4

Engineering/Design:

VIO/SL*ll Notice of Violation* Severity Level II (2) request a predecisional enforcement A - Design VIO/SL*lll 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 NRC has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Requlatorv Commission entries may be modified when the final Self-Revealed Identification bv an event (e.Q., eauipment breakdown) conclusions are made.

Other Identification unknown Page 13 of 13

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

Regional Initiative - Discretionar-Y' Inspections NUMBER OF INSPECTION NRC I

TITLE I PROGRAM AREA INSPECTORS/

ACTIVITY INDIVIDUALS Tl2515/140 Periodic Verification of MOV 2

Capability IP83750 Radwaste, Radiation Protection 2

IP86750 Licensed Operator E?<amination 3

IP81700 Security (SEC2) 1 IP f10R'>1

!=:ni:mt F1 IPI nru r'<::i~k ~tnr~np 1-?

Notes:

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

PLANNED DATES May 3 - 7, 1999 May 3 - 7, 1999 June 6 - 18, 1999 September 20 - 24, 1999 TRn

~

TYPE OF INSPECTION/

ACTIVITY-COMMENTS Regional lnitiative<D Core Core l';nrA