ML20153C363
| ML20153C363 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/12/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20153C360 | List: |
| References | |
| 50-255-86-01, 50-255-86-1, NUDOCS 8602190148 | |
| Download: ML20153C363 (41) | |
See also: IR 05000255/1986001
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SALP 6
SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASS' , MENT OF LICENSEE PERFORMANCE
86001
Inspection Report No.
Consumers Power Company
Name of Licensee
Palisades Nuclear Generating Station -
Name of facility
November 1, 1984 to October 31, 1985
Assessment Period
B602190148 860 j55
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance:(SALP) program is an
integrated NRC staff effort to collect available observations and data on-
a periodic basis and to evaluate licensee performance based upon this
information. SALP is supplemental to normal regulatory processes used -
to ensure compliance to NRC rules and regulations. .SALP is-intended to
be sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant construction and operation.
A NRC SALP~ Board, composed of staff members listed below, met on
January 6 1985, to review the collection of performance observations
and data to assess the licensee performance in accordance with the
guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee
Performance." A. summary of the guidance and evaluation criteria is
provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at-the Palisades plant for the period November 1, 1984
,
through October 31, 1985.
SALP Board for Palisades:
Name Title
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A. B. Davis Deputy Regional: Administrator
J. A. Hind Director, Division of Radiation
Safety and Safeguards (DRSS)
C. E. Norelius Director, Division of Reactor
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Projects (DRP)
C. J. Paperiello Director,. Division of Reactor
Safety (DRS)
A. Thadani Director, PWR Project Directorate
No. 8, NRR
T. V. Wambach Licensing Project Manager, NRR
R. M. Perfetti Project Engineer, NRR
i N. J. Chrissotimos Chief, Projects Branch 2, DRP
C. W. Hehl Chief, Projects Section 2A, DRP
E. R. Swanson Senior Resident Inspector,
Palisades
l C. D. Anderson Resident Inspector, Palisades
!
L. A. Reyes Chief, Operations Branch, DRS
. W. D. Shafer Chief, Emergency Preparedness
and Radiological Protection Branch,
DRSS
3- L. R. Greger Chief, Facilities Radiation
Protection Section, DRSS
M. P. Phillips Chief, Emergency Preparedness Section,
DRSS
,
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F.' C. Hawkins Chief, Quality Assurance Programs
Section,'DRS
J. R. Creed. Chief, Safeguards Section, DRSS.
M. C. Schumacher Chief, Radiological Effluents and
Chemistry Section, DRSS
C.~ F. Gill Radiation Specialist, DRSS
J. P. Patterson Emergency-Preparedness Analyst,- DRSS
T. E.. Taylor. Reactor Inspector, DRS.
M. Pearson Licensing Assistant, DRP
J. F. Suermann Project Manager, DRP
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II. CRITERIA
The licensee performance is assessed in selected functional areas
depending whether the facility is in a construction, preoperational
or operating phase. Each functional area normally represents areas
significant to nuclear safety and the environment, and are normal
programmatic areas. Some functional areas may not be assessed because
of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used in assessing
each functional area.
1. Management involvement in assuring quality
2. Approach to resolution of technical issues from a safety
standpoint
3. Responsiveness to NRC initiatives
4. Enforcement history
5. Reporting and analysis of reportable events
6. Staffing (including management)
~ 7. Training effectiveness and qualification
'
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is
classified into one of three performance categories. The definition
of these performance categories is:
Category 1: Reduced NRC attention may be appropriate. Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so
that a high level of performance with respect to operational safety or
construction is being achieved.
Category 2: NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and
are reasonably effective such that satisfactory performance with
respect to operational safety or construction is being achieved.
L Category 3: Both NRC and licensee attention ~should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
be strained or not effectively used so that minimally satisfactory
i performance with respect to operational safety or construction is being
achieved.
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-Trend: -The SALP Board has'also categorized the performance trend in
each functional area rated over the course of the SALP assessment period.
The. categorization describes the general orfprevailing' tendency (the
performance gradient) during the SALP period. The performance trends
are-defined as follows:
Improved: Licensee performance has generally improved over
-the course of the SALP assessment period.
Same: Licensee performance has remained essentially constant
over the course of_the SALP assessment period.
Declined: Licensee performance has generally declined over
the course'of the SALP assessment period.
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III. SUMMARY OF RESULTS
The licensee's overall performance for this assessment period showed a
considerable decline, reflecting a continuation of the poor performance
noted in some areas at the end of the last assessment period. Three
functional areas (Maintenance, Surveillance and Quality Programs)
recorded a decline in performance to the Category 3 level and the
performance trend in two of these areas showed no overall improvement
over the course of the assessment period. Of the remaining seven areas
rated only three areas showed an improving performance trend and one-
area reflected a declining trend. None of the areas rated received a
Category 1 rating.
Rating Last Rating This
Functional Area Period Period Trend
A. Plant Operations 2 2 None
B. Radiological Controls 2 2 Improved
C. Maintenance 2 3 Same
D. Surveillance 2 3 Improved
E. Fire Protection 2 2 Improved
F. Emergency Preparedness 2 2 Declined
G. Security 2 2 Same
H. Refueling 1 NR* None
I. Quality Programs and
Administrative Controls 2 3 Same
J. Licensing Activities 2 2 Improved
- NR - Not Rated (no basis for evaluation)
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IV. PERFORMANCE-ANALYSIS
A. Plant Operations
1. Analysis
,
Evaluation of this functional area is based on portions of
twelve inspections conducted by the resident inspectors
encompassing direct observation of activities, review of logs
and records, verification of selected equipment lineups for
operability and followup on significant operating events to
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verify conformance to the Technical Specifications and
administrative controls.
During this operating cycle Palisades experienced one of its
-best operating runs (maintaining an availability factor of 87%)
and set several generation records. Plant power operation was
characterized by one nine month period of continuous reactor
operation, a low number of automatic reactor trips from power
-(two), three-power reductions to add oil which had leaked from
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a primary coolant pump motor, eight turbine. generator shutdowns
for electro-hydraulic system leaks on the turbine governor valve,
and two power reductions as required by Technical Specification
action statements. Except for the two reactor trips which
involved personnel errors, operators demonstrated their
proficiency and coordinated operating ability by rapidly
r removing the turbine generator from service in response to
j secondary plant problems a number of times without tripping the
reactor. 'The operators performance is commendable in light of
i the operating difficulties posed by operating a plant where
!. Section IV.C. on Maintenance for more details).
Three violations were identified in this area. One, a Severity.
Level IV for late reporting of unidentified primary coolant
leakage in excess of 1 gpm (Inspection Report No. 50-255/84025),
was of concern since it showed.that operators were reluctant
to take action based on information and' indications which
should have been reliable. Corrective actions taken with
respect to this issue have been effective. The second, a
Severity Level IV for having two safety injection tanks below
the low level limit (Inspection Report No. 50-255/85002),was
of concern because operators failed to recognize the degraded
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equipment which eventually caused the violation. In this
[
latter event, leaking fill and drain valves on the tank,
I primary coolant system check valve leakage and uncalibrated.and
! unreliable' level indicators for the tanks all contributed to
l make the operator's job of maintaining compliance difficult.
I Both of the above violations had root causes related to poor
( maintenance which contributed to the operators' lack of
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confidence in their indications in the first case and then in
the second case, when they believed them, resulted in the
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violation. The reliability of indicators needs to be improved
so that operators can believe what they indicate and take
action without evaluating the operability of the indicator.
The third violation, a Severity Level IV, was for a licensee
identified situation where both licensed Senior Reactor
Operators concurrently left the control room for a short time
during power operation (Inspection Report No. 50-255/85027).
This event was viewed as an isolated occurrence of a communica-
tion failure.
Of the six Licensee Event Reports (LER) related to the area of
operations (LER 85-004,85-010, 85-014,85-015, 85-016, and
85-021), all of them involved operator personnel errors.
In addition, one of the six LERs involved the inadvertent
operation of a power operated relief valve and two involved
operator errors which resulted in reactor trips. Additionally,
a voluntarily submitted report (LER 85-001), involved personnel
error, when operators disbelieved a panel indicating light
which resulted in several days of operation with certain safety
injection actuation features blocked.
None of the events had any serious safety significance although
a statistic of increasing personnel errors warrants close
scrutiny. The licensee does trend personnel errors, but has
not observed any commonality which would warrant other than
event specific corrective action.
Staffing the Operations Department has been adequate.
Experience level at the plant is fairly good in the Reactor
' Operator positions but the Senior Reactor Oparator positions
were lacking some depth due to attrition and the infusion of
less experienced replacements. One of the decisions made,
based on the attrition of operators, was to go back to a
5 shift rotation for the foreseeable future. In spite of the
lack of experience, most of the newly licensed SR0s are
competent and conscientious operators.
Operator attitudes have improved somewhat over the evaluation
period, and no situations which were adverse to safe operation ~
were identified. The operators are generally conscientious and
attentive while on duty. Plant licensed operators conduct
themselves in a professional manner and have not been observed
engaged in any of the activities prohibited by the plant
administrative procedure on control room conduct (prohibits
radios, hobbies and non job-related reading material). No
formal dress policy has been established, but dress has
improved during this period since the identification of the
dress issue. Good progress has been made in the general
housekeeping of the plant and specifically in the auxiliary
building hallways and accessible rooms. Operators take an
active role in the plant-wide housekeeping efforts by reporting
and correcting situations which are discovered during their
tours.
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Management and supervisory decisions were characterized by a
realistic view of safety, but did not, on two occasions of
note, take a conservative approach to plant operation. A
recent example is the primary coolant system (PCS) leakage
event of October 15, 1985 (LER 85-022) where the decision was
made to increase power from 30% with a 0.8 gpm unidentified
leakrate and one valve packing leaking water and steam at about
0.7 gpm (part of the identified leakage). The licensee later
shut down after the valve leakage increased to over 3.0 gpm.
Another example from earlier in the period rel~ ted
a to decisions
not to exercise one control rod due to possible aggravation of
seal leakage and declaring it inoperable. When a second rod
became inoperable, the licensee then exercised the first rod to
avoid shutting the plant down to effect repairs. These
actions, although technically within the requirements of the
Palisades lic~ense, are considered somewhat imprudent by the
NRC.
During the report period, examinations were administered to 2
reactor operators (R0s), 7 senior reactor operators (SR0s),
and 7 instructors. The overall pass rate was 75%, which is
slightly below the national average of 80%. In addition,
requalification examinations were administered to five SR0s
and three R0s in July 1985 with unsatisfactory results for all
three R0s and one SRO. These individuals were removed from
licensed duties. The NRC reviewed and accepted an accelerated
requalification program for these individuals. Subsequently,
all four individuals passed the August re-examination and
returned to licensed duties. The licensee attributes these
failures in part to the lack of qualified instructors familiar
with the Palisades Plant. Actions are underway to improve this
situation by the licensee " growing" their own certified
instructors.
2. Conclusion
The licensee is rated Category 2 in this area with no discernable
performance trend noted. Although improvement since early in
the period was evidenced by a reduction in cited violations, the
number of personnel errors stayed relatively the same.
3. Board Recommendations
None
B. Radiological Controls
1. Analysis
Five inspections were conducted during this assessment period
by region based inspectors. These inspections included
radiation protection, radioactive waste management, TMI Action
Plan Items, environmental protection, radiochemistry, and
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confirmatory measurements. The_ resident inspectors also
reviewed this area during routine inspections. Four violations
were identified as follows:
- Severity Level IV - Failure to perform a safety evaluation
before filter elements were removed from the liquid
radioactive waste system. Because the elements were
removed, contaminated resin was pumped to the clean
radwaste system during resin sluicing operations.
(Inspection Report No. 50-255/85004)
- Severity Level IV - Failure to follow radiological access
control procedures in that an emergency door was routinely
used for auxiliary building ingress and egress without
required radiation safety approval, personnel commonly
used a shift log in/out option without required radiation
work permit (RWP) authorization, and two workers entered
a posted radiation area without being listed on a RWP and
without wearing the required self-reading dosimeters.
(Inspection Report No. 50-255/85010)
- Severity Level IV - Failure to follow radioactive material
control procedures in that several pieces of unlabeled
contaminated tools and material were found outside the
radiologically controlled area and contract workers exited
the control area with hand tools that had not been surveyed.
(Inspection Report No. 50-255/85010)
- Severity Level IV - Failure to follow liquid radwaste
release procedures in that incorrect iodine MPC values
were used in calculating several releases and on one
occasion, an actual release rate exceeded that authorized
by the shift supervisor. (Inspection Report
No. 50-255/85011)
These violations are indicative of a minor programmatic
breakdown in the areas of safety evaluations and procedure
adherence. Although licensee corrective actions have been
timely in most cases, procedure adherence problems were also
evident during the last assessment period. Licensee enforcement
history during this assessment period improved from the previous
assessment period.
Licensee staffing has generally improved during this assessment
period. One technician position was added and all positions are
filled. The staffir.g levels appear adequate to properly
1 establish acceptable radiation protection controls during
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station operation and to provide sufficient oversight of
- contracted radiation protection technicians during outages. The
radiation protection and chemistry staff turnover rate, which
had been quite high in the past, has stabilized. This stability
appears to have helped the licensee improve performance in the
area of radiological controls, although experience levels on
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the average remain quite low. Licensee organization changes
during this assessment period removed one intervening management
layer between the RPM and the plant manager in response to NRC
concerns. Other organizational changes resulted in the
separation of the chemistry and the radiological services
departments at the manager level.
The licensee's management involvement has improved during this
period and is generally adequate, with occasions of both good
and poor performance. Audits are thorough and timely, with
good responsiveness to findings. Significant progress was made
in development of chemistry procedures to satisfy a nuclear
operations department directive of 1982. This work had lagged
somewhat during the previous assessment period. Administrative
procedures required by the Chemistry Program Manual were
completed but not all subordinate working procedures had been
fully or adequately implemented. Progress in this area was
addressed in a detailed internal audit performed in September
1985 and a followup audit was scheduled for early 1986. In
addition to these problems, the audit identified procedural-
inconsistencies that required reconciliation. In addition,
improved management oversight is warranted in the radwaste
area where the inspector identified nonconservative errors in
procedures used for calculating beta components of airborne
releases and also significant typographical errors in
semiannual reports. No significant releases were involved and
the licensee was quick to correct the errors after they were
pointed out. The licensee has implemented measures to improve
workers adherence to station radiation protection procedures by
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better identification of offenders and stronger disciplinary
actions. These improvements, in conjunction with increased
surveillances and program changes, are expected to reduce the
number of radiological incident reports. Management control
initiatives during this assessment period resulted in:
improved ALARA outage pl=nning; reduction of contaminated areas
in the auxiliary building; plant visits by senior health physics
staff personnel to several NRC Region III nuclear power stations
with a SALP 1 rating in the area of radiological controls; an
improved and revised alpha surveillance program; NVLAP
accreditation of the TLD dosimetry program; and several trending
programs. Several items, however, have remained open for prolonged
periods including: the need to improve the radiological incident
reporting system; repair of minor radioactive system leaks in
the auxiliary building; and a failure to quantify or
alternatively eliminate occasional low activity steam releases
from the heating boiler in accordance with a commitment made
during an earlier inspection.
The licensee's responsiveness to NRC initiatives has generally
been adequate during this assessment period. As noted above,
several NRC concerns remained open for prolonged periods. On
the other hand, improvements were made for a number.of NRC
identified weaknesses, including those concerning the
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unauthorized use of'an emergency door for auxiliary building
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access; access control logging procedures; radiation work permit
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(RWP) adherence; radioactive ~ material control; the need to
improve the quality and timeliness of neutron assessment for
containment entries during power operations; the need to expand
the scheduled surveys of uncontrolled areas to include such
items as tool cribs,-ladders, and scaffolding; environmental
i monitoring; gamma spectrometer calibration; the lack of a
contamination area tracking system; and the need to improve the
sensitivity of the portal monitors.
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The licensee has satisfactory formal training / qualification
- programs for radiation protection technicians, contract
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technicians, plant workers, and plant visitors. A radiation
protection and chemistry training and qualification program has
been implemented for a large portion of the staff. The licensee
has a good seven to nine week training program established for
radiation protection and chemistry technicians. About 90
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percent of the technicians currently on staff have completed
this training.
The licensee's approach to the resolution of radiological
s technical issues have generally been technically sound, thorough,
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and timely. Although the adequacy of radiological involvement
l in outage preplanning could not be directly assessed because no
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extended outage occurred during this assessment period, it
appears that there needs to be a better working relationship
between the ALARA group and the Planning department. In response
to this concern, the ALARA Coordinator and the Radiological
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Services Manager acknowledged the need to improve prejob planning,
including: routine advance planning over a longer period of time;
ALARA staff attendance at pre-outage meetings; and possible
relocation of the ALARA staff closer to the planning staff. A
- review of a January 1985 entry into containment, while the
reactor was at 20 percent power, indicated that radiological
involvement and ALARA preplanning were adequate. The ALARA
program and corresponding management support appear to'have
been strengthened since the reorganization in November 1984,
j including: the appointment of a dedicated, full time ALARA
j coordinator; substantive commitments to INPO that should
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improve the ALARA program; improved ALARA goals and policies;
and increased efforts to improve job planning. During this
- assessment period there was a significant improvement in the
overall radiological control program. Specific improvement
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areas include: procedure adherence, staffing, ALARA, access
control, contaminated area reduction, incorporation of good
4 radiation protection practices gleaned from SALP 1 plant visits,
- the alpha surveillance program, the TLD dosimetry program,
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access control logging procedures, containment entry neutron
assessment, the uncontrolled area survey program, portal
j monitor sensitivity, and several trending programs.
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Personal. exposures during this assessment period were about
530 person-rem in 1984, and are estimated to be about 300
person-rem in 1985. These exposures are below the station
average over the previous five years (600 person-rem) and
less than the U.S. average for pressurized water reactors
(550 person-rem per reactor).
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. .The licensee's liquid radiological effluents continue to be
significantly lower than average for U. S. pressurized water
reactors. Reported noble gases effluents have shown an increase
during this assessment period but are still only about average
for U. S. pressurized reactors. '
.t is not yet certain whether
this apparent increase is real or an artifact of the new noble
gas-stack monitor. Licensee efforts are continuing to resolve
this matter. The solid radioactive waste volumes in 1984 and
1985 were significantly less than in recent years, and the
licensee has recently implemented a volume reduction program
and plans to begin segregation of dry active waste (DAW) in
the near future to reduce the amount of solid radwaste further.
Other planned improvements include: placing separate trash
containers in the RCA for potentially contaminated and clean
. DAW; limiting the issue of disposable " anti-C" clothing; and,
1 minimizing the amount of material, such as boxes or other
- packing material, taken into controlled areas. No transportation
problems were identified during this assessment period.
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Confirmatory measurements comparisons during this period were
I limited to gross beta, tritium, and strontium comparison on a
- liquid sample split near the end of the previous assessment
period. The licensee achieved agreement in all four
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comparisons. Counting room quality controls were generally
adequate. Performance tests on instruments are established,
completed as required, and are reviewed by a chemistry
supervisor. The absence of trend plotting of performance check
data and lack of a radiological crosscheck program with an
j independent laboratory were two weaknesses noted by the
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inspectors. Analysts interviewed and observed in the counting
room appeared knowledgeable regarding equipment and procedures.
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! 2. Conclusion
The licensee is rated Category 2 in this area. The licensee
received a rating of Category 2 in the last SALP period. An
improved performance trend was evident during this assessment
, period.
3. Board Recommendations
None
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C. Maintenance / Modifications
1. Analysis
Examination of this functional area consisted of two special
inspections by a Region III Maintenance Inspection Team, one
special inspection by two regional inspectors, one routine
inspection by a regional inspector, and portions of twelve
monthly inspections by the resident inspectors.
Activities inspected included the program and implementation of
maintenance and supporting activities (including calibration
and' control of test and measuring equipment), design changes
and modifications, and reviewing the cause and licensee
recovery efforts related to the failure of a shaft ~ joint on a
reactor coolant pump.
Seven violations were identified as follows:
a. Severity Level IV - Six examples were noted where
maintenance procedures related to preventive maintenance
and equipment control were not being followed. (Inspection
Report No. 255/85003).
b. Severity Level IV - Calibration was being performed
without a procedure. (Inspection Report No. 255/85003).
c. Severity Level V - A number of portable measuring and
testing devices were improperly controlled. (Inspection
Report No. 255/85003).
d. Severity Level V - Three examples were identified where
insufficient instructions were provided in maintenance
work orders. (Inspection Report No. 255/85003).
! e. Severity Level IV - Design considerations for redundancy,
diversity and separation were improperly applied to a
l modification of the Component Cooling Water (CCW)
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Containment Isolation valves. Purchase documents did not
- specify appropriate requirements for Class IE components
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(Inspection Report No. 255/85018).
f. Severity Level IV - Failure to conclude that an unreviewed
safety question existed when changing the CCW isolation
circuitry (Inspection Report No. 255/85018).
g. Severity Level IV - Failure to environmentally qualify the
temperature switches for the Safeguards Pump room cooling
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fan (Inspection Report No. 255/85027).
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Individually, many of the above violations were not significant,
but collectively they indicate significant program implementa-
tion problems in this functional area. No violations were
identified in this functional area during the previous SALP
period, and, although one would normally expect a concentrated
team inspection to identify some deficiencies, it is significant
to note that roughly half of the violations noted above were
identified by the resident inspector while performing the
routine inspection program. Inspections resulting in violation
a. above and violation a. under Paragraph IV.I. (Quality
Programs and Administrative Controls) showed that the Preventive
Maintenance Program at the plant has not been either of
sufficient scope or adequately implemented to provide the
desired reliability. Additionally, machinery histories were
not being maintained in useable form and no trending was being
done. These problems contributed to the poor plant material
conditions observed. Violations b., c., and d. above are
considered additional examples of program implementation
failures.
The violation of greatest concern is item e. above. Not only
were design inputs found to be inadequate, but the independent
licensee reviews also failed to identify any of the problems
that existed with the design. The safety evaluation (item f.
above) did not accurately describe the change and did not
identify that the change created an unreviewed safety question.
The failures represent. training and program implementation
problems. The licensee committed to reviewing other minor
modifications for similar modification errors. Additional
reviews of design change packages identified further violations
of documentation requirements, as detailed under Paragraph IV.I.
(Quality Programs and Administrative Controls).
Item g. above was a result of poor transfer of responsibility
for the resolution of the issue from one organization to another
within the company. It was considered an isolated event with
respect to the enti.re environmental equipment qualification
issue.
As a result of concerns over the effectiveness and progress of
the licensee's remedial maintenance program, a Confirmatory
Action Letter (CAL) was issued on October 30, 1985 to confirm
that certain agreed upon goals would be met prior to restart
from the December 1985 - February 1986 refueling outage.
Satisfactory progress had not been made in reducing the
maintenance backlog and Control Room deficiencies between the
initial special maintenance inspection in February 1985 and the
followup inspection approximately six months later. Additionally,
the followup inspection found no corrective actions were
apparent on some of the earlier identified violations and action
was incomplete on others.
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One LER (Report 85-011) showed an inadequate understanding
of a Safety Injection System (SIS) circuit which resulted in an
inadvertent SIS actuation while shutdown. Three LERs (Reports84-024, 84-025, and 85-022) reported high PCS leakage due to
various equipment failures. A control rod seal failure was
apparently due to operation with high total dissolved solids
in the Primary Coolant System (PCS) from a worn and damaged
pump impeller. Another report (84-027) identified two charging
pump breaker closing coil failures due to lack of preventive
maintenance. Two Safety Injection Tanks were below the low
level limit at the same time (Report No.84-026); this was a
direct result of instrument unreliability and lack of
calibration. A continued concern exists for the state of
maintenance and reliability of indications and controls as
' described in Paragraph IV.A. (Plant Operations). Although the
situation improved somewhat over the SALP period, further
engineering and design changes will be required to solve the
existing problems. The licensee does have plans to correct
most of the identified maintenance problems during the upcoming
refueling outage and this issue will be further addressed before
startup under the CAL.
Many existing maintenance problems have arisen due to equipment
age. Previously, a number of older problems had not been faced
squarely and resolved, but rather solutions were sought which
could be " lived with". Examples of these older problems
include the nuclear instruments, control rod drive indication
and seals, and Safety Injection Tanks, valves, and indications.
One example of the current management's desire to solve the
problems that have plagued operators was their successful
pursuit of the solution to the electro-hydraulic vibration
problems on the turbine governor valves. However, a number of
backlogged issues remain to be solved.
One major improvement in this appraisal period was the overhaul
of the maintenance work order system. With full employee
participation, a team was established which addressed the
" log jams" of the existing system and improved the controls
to improve the erficiency of the workers. This was considered
a key step towards reducing tho backlog. Other improvments
include: the system assessment program where major systems
were walked down to identify deficiencies; improved work order
prioritization through the use of an aggressive and experienced
Senior Reactor Operator; improved supervision of work in progress;
improved quality of work execution; and added engineering
support for resolution of chronic problem instrumentation.
2. Conclusion
The licensee is rated a Category 3 in this area. This rating
is lower than that for the previous SALP period and reflects
the actual performance level noted in this area at the end of
16
L
. ..
the last period. Deficiencies found in the areas of preventive
maintenance, design changes and documentation, corrective
maintenance, work supervision, machinery history and trending
support this rating. The performance trend improved over the
period in several of the areas noted above, but the lack of
results in lowering a large maintenance backlog resulted in the
overall performance trend remaining the same. The level of
performance overall continues to be a major concern at the
facility.
3. Board Recommendations
The Board recommends continuation of the increased level of
NRC inspection effort and licensee management involvement in
this area. The Board notes that subsequent to the issuance of
the CAL (but after the appraisal period ended) the licensee
implemented steps to reduce the maintenance backlog and the
number of outstanding Control Room deficiencies. The licensee
also initiated steps to implement various maintenance trending
programs.
D. Surveillance and Inservice Testing
1. Analysis
Evaluation of this functional area is based on parts of twelve
inspections by the resident inspectors and two inspecticns by
Region III specialist inspectors.
Six violations were identified as follows:
a. Severity Level IV - The PCS low flow trip setpoints for
both four pump and three pump operation were nonconservative
due to failure to perform a test (Inspection Report
No. 255/84027).
b. Severity Level IV - Safety Injection Tanks were not
sampled within the required frequency (Inspection Report
No. 255/85005),
c. Severity Level V - Temperature readings were not taken
as required by the procedure (Inspection Report
No. 255/85008).
d. Severity Level V - Electrolyte level not measured and
recorded as required (Inspection Report No. 255/85008).
e. Severity Level IV - Containment isolation check valves
were not stroke tested quarterly (Inspection Report
No. 255/85023).
17
.' ..
f. Severity Level IV - Procedure was not followed concerning
operability status of untested components (Inspection
Report No. 255/85023).
Although these violations do not represent a serious safety
problem, when added to the number of additional licensee
identified inadequate or incomplete surveillances, they indicate
the variety of shortcomings in the surveillance program.
Violations a. and e. above were indicative of weaknesses in the
scheduling for some surveillance tests. Violations b. c. and f.
and LER 85-003 indicate implementation of the surveillance
program was not given sufficient attention to ensure completion.
Item d. above, and item 1. from functional area I (Quality
Programs), and LERs85-019 and 85-020 are evidence that program
requirements were not correctly translated into written
procedures. Although perceived at times as narrow in scope,
the licensee's corrective actions have be.en generally effective
in preventing similar occurrences. A twofold' increase in the
number of cited violations was noted over the last assessment
period.
Other event reports included the failure of personnel
performing a Safety Injection System Test to recognize that
a blocking relay was left energized during several days of
operation (LER 255/85-001). The condition was indicated by a
panel light which when pursued by the resident inspector was
finally resolved. In another event report (LER 255/85-018)
eight pressure transmitters were calibrated incorrectly
resulting in nonconservative setpoints for the high pressure
reactor trip. This potentially serious error was due to
unfamiliarity with the equipment used for the calibration.
Subsequent review determined that the error was within the
assumptions made in the safety analysis. These two events
display cognitive personnel errors which would likely have
been avoided through better training.
As a result of the identified violations and a changeover in
personnel who administer the surveillance program, the licensee
embarked on initiatives to validate their program and computerize
the scheduling. Both efforts have for the most part been
completed. One of the results of the reviews of their program
was the identification and correction of at least four
deficiencies in their program and procedures. Provided that
these initiatives continue to be successful, the licensee
would not be expected to experience any further scheduling or
programmatic problems in the area of surveillance. Implementa-
tion of the program and procedural adherence will continue to
require licensee attention.
2. Conclusion
The licensee is rated Category 3 in this area due to program
weaknesses noted during the appraisal period and a significantly
18
_ _ _ . - __
.
worse enforcement history for the period compared to the last
appraisal period. The licensee's performance reflected an
increase in both the number of violations and the severity level
of the violations. An improving performance trend, however,
., was evident late in the appraisal period as a result of program
i adjustments and personnel changes made in the surveillance area.
3. Board Recommendations
The Board recommends that increased licensee management
attention be focused on both a review of the surveillance
program itself and the implementation of the program.
'
E. Fire Protection ard Housekeeping
1. Analysis
,
Evaluation of compliance to fire protection requirements and
i good housekeeping practices was accomplished as part of twelve
- routine inspections by the resident inspectors, who were
i assisted by Regional Fire Protection Specialists on one
occasion and part of the Maintenance Team inspection on
another occasion. Three violations were identified as follows:
'
a. Severity Level V - Administrative controls for
housekeeping were not being followed (Inspection
Report No. 255/85002),
b. Severity Level IV - Poor housekeeping: water, combustible
debris in a class IE cable tray, combustible material,
i
contaminated tools, aerosol can in safety related
electrical cabinets (Inspection Report No. 255/85003).
l,
!' c. Severity Level V - No fire watch or fire extinguisher
present during hot work (Inspection Report No. 255/85018).
Violation k. under functional area I (Quality Programs and
Administrative Controls) also represents a fire protection
violation, with the main concern being the adequacy of the
program and procedures. The above referenced violations are
a contrast to no violations in the previous assessment period.
This is especially of concern since one would not expect
- problems in this area without a large contract work force
1 onsite, and there was not a major outage during this period.
j Violation b. involved housekeeping in some obscure places but
1
was typical of the inspectors' observations. Well travelled
areas were well lighted, painted, and kept clean. Other areas
manifested a lack of routine cleaning and maintenance efforts.
In general, the licensee made headway in stopping minor
j equipment leaks and cleaning up the problem areas. A number
)
i
1
4 19
. - - - - . - - . _ _ - - - - - . -
..
of previously controlled contamination areas have been cleared
and opened for access in street clothes. This has been a real
benefit to operators and other workers.
With respect to final implementation of 10 CFR 50, Appendix R
requirements, all identified modifications are scheduled for
completion during the February 1986 refueling outage; however,
there are still two exemption requests being reviewed by the
Office of Nuclear Reactor Regulation. The first concerns
separation of_certain instruments inside containment. The
second concerns the use of high pressure coolant injection as
a source of primary makeup water if a fire occurs in the
charging pump area. These reviews are expected to be complete
during early summer 1986.
2. Conclusion
Although the performance trend in this appraisal period
improved, the licensee continues to be rated Category 2 in this
area, which is the same rating achieved in the last appraisal
period.
3. Board Recommendations
None
1. Analysis
Three inspections were conducted during the period to evaluate
the following aspects of the licensee's emergency preparedness
program: emergency detection and classification; protective
action decisionmaking; notifications and communications;
implementation of changes to the emergency preparedness program;
shift staffing and augmentation; emergency preparedness training;
dose calculation and assessment; public information program; and
independent audits of the emergency preparedness program. One
inspection involved the observance of the annual exercise. In
addition three management meetings were held; (one was held in
May 1985 and two were held in September 1985).
One Severity Level IV violation was issued because the licensee
had not provided the required annual training for some
individuals designated to fill key positions in the onsite
emergency organization. The training records, as reviewed by
the inspectors, were imp 1ssible to reconcile when comparing the
training records with the requirements of the training matrix.
The violation was indicative of a programmatic breakdown in
recordkeeping coupled with the significant change in personnel
in emergency response roles due to the transfer of personnel
20
.
.
from the discontinued Midland Plant to Palisades. The licensee's
corrective actions were thorough, including a review of the
administrative content of all training records and the
appointment of a new training administrator.
The licensee's performance in the August exercise was the
poorest of any Region III facility during 1985, in contrast to
a very good exercise in 1984. Six major exercise weaknesses
were identified as follows: (1) control room participants were
not given time by controllers to evaluate messages prior to
formulating an Alert classification; (2) lack of coordinated
effort between the Control Room and Technical Support Center;
(3) failure to adequately assess and trend radiological field
data; (4) poor and erratic contamination control techniques in
the Operational Support Center; (5) the Emergency Operations
Facility lacked sufficient space and communications equipment
to meet NUREG-0696 guidance; and (6) the offsite monitoring
teams did not decontaminate their vehicles upon leaving the
plume. With the exception of the fifth weakness, all of these
weaknesses related to poor adherence to procedures by response
personnel. On the positive side, the exercise scenario was a
very complicated one, and its complexity made dose assessment
evaluations and technical decisionmaking more difficult for
participants.
'
Management involvement in the emergency preparedness program
has needed improvement. While the licensee has been very
responsive to significant issues brought forward by the NRC,
they had failed to correct the problems prior to NRC management
meetings. The first example of this involved licensee failure
to adequately classify emergency conditions. Although this
issue had been brought up in the preceding SALP period, the
actions taken by the licensee had been ineffective prior to the
management meeting held in May to discuss timely classification
of emergencies and subsequent notifications to offsite
authorities, although the commitment to make classifications
based on initial leek rate calculations was met. As a result
of this meeting, licensee management took action to relieve the
Shift Engineer / Shift Techn % 1 Advisor of some of his emergency
duties. In additior, special training was conducted for all
SR0s on Emergency Action Levels, as well as simulator time
which addressed emergency plan duties as well as recovery of
the plant during accidents. This simulator time was expanded
from five days per year to eight days. The results of these
activities have been the elimination of conditions where
emergency classifications were missed.
Two management meetings were held as a result of the exercise
during which the licensee presented a comprehensive corrective
action program which should result in the improvement of the
1
21
- ._
_ - _ - _ _ _ - - -. -_ -__ - -
. _ _ - _ _ _ . -
.' .
licensee's performance during future exercises. The licensee's
corrective actions included a comprehensive review of EALs,
conduct of several table top exercise / discussions, revising
procedures to make them clearer, clarification of responsibili-
ties and authorities in the emergency organization, involve
General Office personnel in offsite monitoring team drills, and
upgrade the training program. All of these actions included
specified realistic completion dates.
During this SALP period, a significant change was made to the
emergency plan involving the elimination of the General Office
Control Center concept of operations. Licensee personnel
worked closely with their NRC counterparts to ensure that the
change was well coordinated and would meet all applicable NRC
requirements and guidance. This activity demonstrated
excellent responsiveness to technical issues from a safety
standpoint, ensuring that no decrease in the effectiveness of
the plan would occur as a result of the changes.
The licensee is maintaining nine key staff positions with
eleven additional support personnel available for duty in
30 minutes. An additional complement of 15 individuals can be
available in 60 minutes. Augmentation capabilities have been
adequately demonstrated by periodic drills. Both primary and
alternate persons have held key positions in emergency drills
and in the annual exercise, thus testing, where possible, a
second line of emergency expertise.
2. Conclusion
The licensee is rated a Category 2 in this area, the same as
for the previous SALP period. However, with the poor
performance demonstrated in the August exercise, the overall
trend is considered to have declined during this appraisal
period.
3. Board Recommendations
The Board notes that a subsequent inspection conducted after
the end of this SALP period showed that the licensee had made
considerable strides in improvinq their performance in
emergency preparedness. All cortective action completion dates
have been met, and the preliminary indications are that the
training and other activities committed to have resulted in an
improvement in this functional area.
G. Security
1. Analysis
Two routine inspections were conducted by region based inspectors
during this assessment period. The resident inspector also made
periodic inspections of security activities assessing routine
program implementation.
22
.' ..
One violation was identified as follows:
Severity Level IV - Physical Protection of Safeguards
Information: Some safeguards information was not properly
protected. (Inspection Report No. 255/84-24)
The violation did not represent a significant degradation in
the licensee's program to protect unclassified safeguards
information. In the previous SALP, four violations,
representative of significant programmatic weaknesses, were
identified.
The Corporate Property Protection Department's involvement in
site activities and in the performance of audits continued in
this evaluation period. Appropriate actions were taken by site
management in response to audit recommendations. Audit personnel
were qualified and experienced in the area of physical security.
In addition to the annual audit, required by the security plan,
the Corporate Property Protection Department conducted numerous
effective surveillances throughout the assessment period.
The key changes in plant management appear to have had some
positive impact on the overall security program. The security
organization managers appear to be receiving better support and
the new plant managers appear more receptive to ideas and
communication. They are more involved in working with and
monitoring the security organization and have begun to provide
a more cohesive approach to overall security program support.
This support is necessary due to the minimal manning levels of
security management, whose time is further split with functions
other than security. The Guard force size is likewise adequate.
Security records were generally complete, well maintained and
available.
The timeliness of resolution of technical issues was generally
adequate. However, we noted that although some actions were
taken regarding a problem with two vital area doors, final
resolution was not yet achieved. The problems were identified
in a special maintenance inspection in February 1985 and despite
actions by maintenance and engineering staffs those actions
were not successful. Consequently, a more thorough analysis
was completed, but those actions also did not achieve the
results expected as ordered replacement parts did not, in fact,
fit. The final solution is pending receipt of completely new
doors and frames. Additionally a problem regarding the closure
of an important vital area door, identified in October 1984,
has not been completely resolved. Although important progress
has been made, additional corrective actions were still
continuing at the conclusion of this evaluation period.
23
. ..
There have been few long-standing regulatory issues attributable
to the' licensee, with the exception of.the procurement of an
acceptable intrusion detection system for the protected area.
The licensee has adhered to this implementation schedule which
calls for completion of system installation and testing by
December 1986. Progress in the committed schedule has been
satisfactory.
Although there were no events reported to the NRC under the
provisions of the licensee's plan or 10 CFR 73.71(c) some
minor similarities were noted in the items required to be
logged (approximately 12). These similarities or events did
not demonstrate a significant adverse trend. The licensee did I
adequate review of the logged events in accordance with their
procedures. The number and type of logged events in relation
to possible reportable events is not representative of either a
positive or negative trend.
Key positions within the security organization were identified
and authorities were defined in security implementing procedures.
Staffing was minimally adequate. Although no significant
deficiencies in guard force performance were noted, interviews
with several guards and high personnel turnover rates appear
to be indicative of declining guard morale. A continuing
unresolved labor discute between the union and the security
force contractor has resulted in the lack of a contract for
two years. This has impacted individual guards, for example
expected pay raises have apparently not been forthcoming. The
disputes between the contractor's management and the guard union
may lead to a further decline in morale and an associated
degradation of performance and should be closely monitored by
the licensee's management.
The Training and Qualification Program contributes to an
adequate understanding of job responsibilities and fair
adherence to procedures with a modest number of personnel
errors.
2. Conclusion
The licensee is rated Category 2 in this area, the same as the
last SALP period. The licensee's performance has remained the
same over the course of the SALP assessment period.
3. Board Recommendations
None.
24
-. - . . - . - . ~ . _ _ _ _ - _ . _ - _ - - = . - . . -
. ..
1
H. Refueling
There were no refueling outages during this assessment period and
this functional area'was not rated.
I. Quality Programs and Administrative Controls Affecting Quality
.f
1. Analysis
! The assessment of performance in this functional area was based
i -on inspection by the Resident and Region based specialist
inspectors and on the effectiveness of the licensee's overall
management control system in achieving excellence of regulatory
performance.
.,
!
'
Specific directed quality assurance inspections were made
in the following areas: quality assurance program, audits,
,
QA/QC administration, design changes and modifications, test
i and experiments program, surveillance procedures and records,
surveillance testing and calibration control. Related
,
activities necessary t'o support inspections of other functional
l
areas were also inspected.
i Ten violations were identified as follows:
i
i
a. Severity Level IV - Inadequate corrective action for
' missed preventive maintenance of 480/460 volt switchgear
and administrative procedures overdue for biennial review
l (Inspection Report No. 255/85003).
- b. Severity Level IV - QA audit findings were not assigned
{ the appropriate level of corrective action (Inspection
Report No. 255/85003).
I c. Severity Level IV - The root causes for equipment
malfunctions were not being identified. (Inspection
,
Report No. 255/85003).
'
d. Severity Level V - Two rubber products were not controlled
for shelf life (Inspection Report No. 255/85003).
l
e. Severity Level IV - Failure to perform 10 CFR 50.59 review
l of leaving East Safeguards Pump room cooler isolated
- (Inspection Report No. 255/85009).
i
- f. Severity Level IV - Four examples were noted where QA
'
records were missing or were not retrievable. (Inspection
l
Report No. 255/85017).
1
! g. Severity Level IV - Five examples were identified where
l objective evidence did not exist that plant modifications
l were properly installed. (Inspection Report No. 255/85017).
i
l
25
_
. . - - _ - _
, ,. . _ ,_. . -_. _.
..
h. Severity Level IV - Failure to perform 10 CFR 50.59. review
when East Safeguards pump room roof hatches were removed
(Inspection Report No. 255/85018).
.
I i. Severity Level IV - Corrective actions were not timely
i after a QA audit identified a Technical Specification
,
i
violation (Inspection Report No. 255/85027).
I j. Severity Level IV - Three examples were identified where
i corrective actions were not completed as committed in
response to a prior Notice of Violation (Inspection
Report No. 255/85024). .
,
) Violations "a", "b" and "i" provide seven examples of the
failure to obtain or address adequate corrective action to
i prevent recurrence of noted quality-related problems.
!~ Violation "b" indicated a reluctance to assign high visibility
, corrective action status to audit findings. One of the six
!~ examples of failure to follow procedures listed unuer
i Paragraph IV.C. (Maintenance) (see violation "a") detailed
failures to implement. effective jumper, link and bypass
'
i controls despite repeated findings by the NRC and other
inspecting organizations. Subsequent review of this violation
, and others resulted in a further violation - item "j" above.
t An unresolved item identified in one of the inspections
i
disclosed that the quality trend program did not provide for
reporting of repetitive occurrences by cause o- type of
'
occurrence so that action to prevent recurrence can be taken.
] These findings indicate that management attention has not
resulted in timely and adequate corrective action necessary
i to correct the cause of quality problems at all levels of
! corrective action.
Items which required reporting or higher levels of response
]
were generally handled in a timely and appropriate manner. The
i licensee's Corrective Action Review Board and onsite Licensing
Group were major contributors to the success in this area.
f
} As discussed above and in Inspection Report No. 255/85003, a
number of adverse conditions were discovered where procedures
i were not used or not followed resulting in violations.
- Management does not yet appear to have taken the action
necessary to assure rigorous compliance with procedures. In
one case, a quorum of the Plant Review Committee decided on a
'
course of action which violated an administrative procedure
! (Paragraph-IV.D. violation "e").
i
'
Violations "c." ud "d." above are considered examples of
l inadequate Audit Program implementation. Both would likely
j have been identified by experienced auditors reviewing the
,
related areas. Otherwise, the audit program was found to be
I
i
1
'
i
26
!
i
, - - - -n--,,,, , , - - , ~-n-, , , . - ~ -, - . - - - , , .. .. --- n m n , n -- -.- - - n..-_ .-,---nm-.,.-.,.,,,- n,,m,,,, -----n-en--,,-,-,r,-
. . .- . - - -. . -_
, ..
a= well managed with the organization adequately staffed with
qualified personnel. Good use was made of " surveillance" type
'
activities at the plant, although some problems were r,oted in
the achievement of corrective actions as previously noted.
Violations "f." and Ug." indicate significant problems in
records preparation, storage and retrieval. A number of
records /providing objective evidence that installat_ ion of
design changes had been satisfactorily completed could not
be retrieved or were inramplete or missing. This indicates
problems in the preparation, checking, storage and retrieval
of QA records related to design charges.
i
Violations "e." and'"h." and item f. in Paragraph IV.C.
J (Maintenance) all relate to inadequate or missing 10 CFR 50.59
'
! safety evaluations. These violations, however, were somewhat
dissimilar in root cause; and one related to maintenance, while
'
the other two related to either operations or design engineering.
The licensee's corrective action to the 10 CFR 50.59 violations
included providing special training sessions for personnel who
may be involved in the modification of systems, and the writing
i of safety evaluations or reviewing them.
l
The design change process, design and procurement control
i were found to be adequate with the exception of one minor
modification (item e. under Paragraph IV.C., Maintenance).
A review of otner minor modifications is underway to assure
that no other similar violations of design control oc':urred.
s
Two Licensee Event Reports (LERs) identified in this area were
- asscciated specifically with tracking system errors (LERs 84-23
and 85-17) but were not linked by any common fault.
. t
'
2. Conclusion
,
The licensee is rated Category 3 in this area. Program implemen-
'
tation problems were noted in the area of minor modifications.
Moreover, inspections indicate that the effectiveness of the
i
corrective action program has deteriorated. The problem does
not seem to be limited to a specific activity but appears to
5 bridge several activities in this functional areae A substantial
's increase in the number and significance of violations contributed
to this rating. Overall controls and management oversight
activities related to the maintenance and surveillance areas
were not effective in achieving the desired level of performance.
Based on plant conditions and operational problems experienced
throughout the period, the performance trend this area was
considered to have remained the same.
1
6
27
!
_ - _ - - . _ , - , _ . _ _ _ _ _ ____ . _.. .,, _... _ __ _ _ _ , _ _ _ _ _ , _ . _ _ .
..
3. Board Recommendation
Increased NRC activity should be provided in this functional-
area. A thorough review of QA program implementation including
maintenance, calibration, design changes, material storage, and
record storage and retrieval should be performed during the
next SALP period. ' Emphasis should be placed on reviewing the
corrective action system and adherence to procedures.
J. Licensing Activities
1. Analysis
The basis for this appraisal was the licensee's performance in
support of licensing actions that were either completed or had
a.significant level of activity during the current rating
period. These actions, consisting of amendment requests,
exemption requests, responses to generic letters, TMI items,
and other actions, include the following specific items:
Multiplant Action Items (MPAs) completed or having a
significant level of review include:
- Appendix R Exemptions (Local Tending of Diesel Generator)
Final Design Modification submitted; Others Completed
Final Submittal made incorporating resolution of NRC
comments
- Environmental Qualification of Safety Related Equipment,
Completed
- NUREG-0737 Items, 4 Completed
- NUREG-0737 Supplement 1
Safety Parameter Display System (SPDS) - Modified
submittal made - under review
Detailed Control Room Design Review (DCRDR) Plan -
Completed
Procedures Generation Package - Draft Safety Evaluation
Report (SER) w/open items
R.G. 1.97 - Request for Additional Information sent -
Licensee to respond May 1986
- Control of Heavy Loads, Phase II, Completed
- G.L. 83-28 Salem ATWS, 9 items completed, 9 remaining
items - submittals in - under review
- Technical Specifications affected by 10 CFR 50.72 and
10 CFR 50.73 (G.L. 83-43), Completed
28
< ,
.' .. ,
Plant Specific Action Items completed or having a significant
level of review include:
- Main Steamline Isolation Valve and Main Feedwater
Isolation Valve Probabilistic Risk Assessment
SER in final draft
- Allegation of inadequate cable tray supports, submittal
under review
- Technical Specification change for D/G surveillance
_
interval, Complete
- Detailed Control Room Design Review Program Plan, Complete
- Technical Specifications for Containment Purge and
Ventilation, Complete
- Technical Specification change for Plant Review Committee
(PRC) approval, Complete
- Environmental Qualification Implementation Extension,
Complete
- Radiological Effluent Technical Specifications (RETS)
Modification, Complete
- ECCS analysis errors, Complete
- Technical Specification change deleting Reactor Internals
Vibration Monitoring, Complete
- Supplement 1 NUREG-0737 Confirmatory Order, Complete
- Technical Specification change - Reactor Vessel
Pressure / Temperature Limits, Complete
A total of 30 licensing actions were completed.
t
Management Involvement and Control in Assuring Quality
With rare exception, there was evidence of prior planning and
assignment of appropriate priorities. Corporate management
made frequent visits to the site and was involved in site
'
activities. Licensing management visited NRC in Bethesda for
pre-submittal planning meetings for the PRA submittal, steam
generator inspection plan, fire protection exemption requests
and the up-coming submittals for spent fuel storage expansion.
Communications improved significantly. There were a few
exceptions to timeliness of submittals, such as the pressure /
temperature limit change in the Technical Specifications and
i
29
o
.__
.' ..
the diesel generator surveillance interval change. There were
changes in the licensing management made late in the report
period. Insufficient time has elapsed to judge the new
management.
Approach to Resolution of Technical Issues from a Safety
Standpoint
In general, the licensee demonstrated an understanding of the
issues, exhibited conservatism,'and provided viable, sound and.
thorough approaches. There were a few instances, however, where
a number of revisions had to be made by the licensee. These
included the revised Technical Specifications for Auxiliary
Feedwater, the justifications for continued operation associated
with extension of the EQ deadline for certain components, and
the yet to be completed resubmittal of Technical Specifications
for leak detection systems. The administrative requirements on ,
the licensee's part for approvals and committee reviews is
multiplied by the number of resubmittals that must be made.
These items could probably have been more expeditiously handled
if meetings were held with the staff or telephone calls made
prior to the formal submittal process. Similarly, the
. licensing process for the staff becomes more burdensome with
the pre-notice requirements for additional submittals.
'
Responsiveness to NRC Initiatives
Responses were generally timely; however, there were occasions
where responses were delayed. Two notable cases that have
experienced delays are the submittals associated with NUREG-0737,
Supplement 1 and the Technical Specifications for leak detection
equipment. Otherwise, the licensee has been very responsive in
meeting deadlines. A significant improvement has been made in
responding to informal requests for information. Commitments
,
made in telephone conversations and in the course of meetings
'
are followed up and this previous weakness (adverse comment in
the last three SALP reports) has been corrected.
"
Staffing
The licensing staff is excel. lent. There is a main licensing
, contact for all routine issues and the normal licensing
'
activities. Special projects, such as fire protection, spent
fuel storage, NUREG-0737, and auxiliary feedwater system
Technical Specifications have other licensing personnel
assigned for project management and co-ordination. However,
support for some of the projects has been light. As noted
previously, support for the activities associated with
NUREG-0737, Supplement 1 has had some problems with attrition
of operating personnel such that initially proposed schedules
had to be slipped. Also, there is apparently insufficient
support to respond to the NRC reviewer's questions regarding
the Technical Specification for leak detection systems.
30
_ _ _ _ __ _ _, . _ _ __ _. . _ _ _ .
- - -
___
..
2. Conclusion
The licensee is rated Category 2.in this area, which is the
same rating given in the previous appraisal period. The
performance trend, as noted.in several areas above, improved
during the appraisal period.
3. Board Recommendations
None.
,
31
. ..
V. SUPPORTING DATA AND SUMMARIES
A. Licensee Activit,ier
Due to heat transfer limitations resulting from steam generator tube
plugging done in the previous SALP period, reactor power was limited
to 98% maximum output for this SALP period. There were no major
planned outages (maintenance, refueling, etc.) during this SALP period.
In contrast to the previous SALP period where the plant experienced
extended outages (the year to date availability factor for 1984 ns
only 15.2 percent), the average monthly availability factor for 4 e
twelve months of this SALP period was approximately 90 percent. The
licensee experienced a relatively good operating cycle from startup on
November.21, 1984 to shutdown for a refueling / Environmental Equipment
Qualification outage on November 30, 1985 (one month after the end of
the appraisal period). In fact, several plant generation records were
set.
During the SALP period three power reductions were made to add oil
which was leaking from a reservoir on a reactor coolant pump (RCP).
Loss of condenser vacuum and numerous (eight) problems with the
turbine governor valve electrohydraulic control system required taking
the turbine off the line several times while maintaining the reactor
critical.
The reactor tripped automatically two times from power. The first
time on August 11, 1985 was due to equipment deficiencies and operator
error in co.ntrolling the main generator voltage. This trip was
followed with a two wod outage to repair RCP seal leakage and control
rod drive seals and to perform diesel generator preventive maintenance.
A second trip on August 30, 1985 was caused by incorrect isolation of
an auxiliary generator trip feature.
A manual shutdown on October 15, 1985 was required due to excessive
primary coolant system leakage from a shutdown cooling system valve.
The plant remained shutdown for four days.
No significant licensing actions or modifications were completed
during the operating cycle.
B. Inspection Activities
(1) There were two special team inspections in the maintenance area
conducted by Region III personnel during the assessment period.
The results of these inspections are discussed in Section IV.C.
(Maintenance).
(2) Facility Name: Palisades Nuclear Generating Station
Docket No: 50-255
Inspection Reports No. 50-255/84-23 through 50-255/84-25
No.'50-255/84-27 through 50-255/84-29
32
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No. 50-255/85001 through 50-255/85013
i No. 50-255/85015 throuch 50-255/85019
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No. 50-255/85021 through 50-255/85025
No. 50-255/85027
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TABLE 1
Inspection Activity and Enforcement
Functional
Areas No. of Violations in each Severity Level
I II III IV V
A. Plant Operations 3
B. Radiological Controls 4
C. Maintenance 5 2
D. Surveillance 4 2
E. Fire Protection 1 2
G. Securi ty 1
H. Refueling NOT RATED
I. Quality Programs and
Administrative Controls 9 1
J. Licensing Activities NA NA NA NA NA
TOTALS 28 7
34
'
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. .
C. Investigations and Allegations Review
On December 24, 1984, a former licensee employee contacted
Region III in regard to alleged test cheating during the auxiliary
operators examination. Although the circumstances alleged were not
substantiated, inspection of the matter disclosed that the licensee
did not have procedures in place to prevent such an occurrence from
potentially taking place. The allegation was documented in
Paragraph 3 of Inspection Report No. 50-255/85009. The allegation
was closed June 3, 1985.
On December 28, 1984, Region III received a call from a-private
citizen who had concerns regarding alleged procedural violations
involving radwaste processing. This was the same allegation as one
received earl.ier in the year, which was referenced in Paragraph 9
of Inspection Report No. 50-255/85004; no violations were cited.
Additional inspection was conducted and reported in Paragraph 10
of Inspection Report No. 50-255/85010. The allegation was closed
March 4, 1985.
On December 29, 1984, Region III received an anonymous telephone
call regarding security at the plant (mainly involving industrial
relations concerns such as low security guard morale caused by
understaffing, lost pay checks, security force overtime hours and
no union contract). The concerns were reviewed by a Region III
security specialist and no violations were identified. The results
were documented .in an internal Region III memorandum to files, which
is exempt from public disclosure due to 10 CFR 73.21 information
being contained therein. The matter is closed.
A January 10, 1985 report of a Midland plant (another Consumers
Power Company facility) allegation review conducted for Region III
by Brookhaven National. Laboratory contained allegations related to
the Palisades facility (see the Category E allegations). The
allegations related to the concerns of a former contractor employee
that: (1) quality control reports failed to reflect problems he had
discovered; (2) transition welds did not meet ASME code requirements;
(3) these were inadequate levels and weld transitions; and (4) there
was excessive fitting of pipe. On May 25, 1985 Region III sent a
letter to the alleger requesting more specific information. On
July 1, 1985 Region III sent a followup letter via certified mail to
the alleger and the receipt-was returned to Region III. No additional
information was received from the alleger and attempts to locate him
were unsuccessful through the end of the assessment period. Region III
intends to close out the allegation in late 1985 or early 1986 without
further action based on the lack of responsiveness of the alleger and
the inability to locate him.
On June 12, 1985, Region III received a letter from a former
licensee employee who alleged that in the event of an emergency at
the plant the operators would leave their posts to be with their
,
35
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I
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families (based on informal conversations the alleger took part in-
when he was a station employee). Based on a lack of specificity or
actual violation noted, the past allegation history of the
individual, and the fact that the alleger's suggested remedial
measures went beyond the scope of existing law and were outside the
jurisdiction of the agency, the matter was closed and documented in
a memorandum dated August 9, 1985 from the Region III Administrator
to the Director of the Office of Nuclear Reactor Regulation (NRR);
the memorandum indicated no further action would be taken by
Region III.but.that any generic implications prompting a review of
licensed operator requirements should be pursued if NRR deemed it
necessary.
An allegation was made on June 15, 1985 by a contractor employee
regarding potentially in~ adequate (re: seismic considerations)
cable tray supports and the possible failure to report the deficiency
pursuant to 10 CFR Part 21. The alleger was recontacted by Region III
and asked to provide additional information. Subsequently, per a
June 26, 1985 conference call between Region III and NRR, lead
responsibility for resolving the allegation was transferred to NRR.
.The allegation' remained open at the-end of the assessment period.
D. Escalated Enforcement Actions
1. Civil Penalties
There were no c ual penalties issued during the assessment
period.
2. Orders
Thee were no orders issued during the assessment period.
E. Management Conferences and Confirmatory Action Letters
1. Conferences
March 12, 1985 - Meeting with licensee management
representatives to discuss SALP 5 (Inspection Report
No. 50-255/85001).
May 3, 1985 - Meeting with corporate and site representatives
to discuss the role of the shift engineer and shift supervisor
regarding emergency classifications and notifications.
July 19, 1985 - Site tour by Regional Administrator and
presentation by licensee on Palisades Plant Plan.
September 5, 1985 - Meeting between Chief, Emergency
Preparedness Branch, Region III and Plant Manager at the site
to discuss concerns identified in last emergency preparedness
exercise.
36
, -. , . _ _ _ _ _ _ _ _ _
.' ..
September 20, 1985 - Meeting between Region III Emergency
, Preparedness representatives and Plant Manager / staff to discuss
emergency preparedness issues and develop activities plan to
improve licensee performance.
September 23, 1985 - Special Management meeting. conducted to
discuss weaknesses in the Palisades emergency preparedness
annual exercise of August 20, 1985 and to emphasize Region III's
concern with the overall trend and performance of Palisades
-emergency preparedness program.
October 2, 1985 - Enforcement Conference to review event
involving the failure to perform certain Technical
Specifications required surveillances.
October 17, 1985 - Management meeting between the Regional
Administrator and Consumers Power Company representatives to
discuss maintenance and other issues of mutual interest.
October 24, 1985 - Plant tour by'the Regional Administrator and
management meeting with licensee's Vice President for Nuclear
Operations / staff to discuss the licensee's maintenance program.
t
2. Confirmatory Action Letters (CAL)
July 16, 1985 - Letter confirming actions to be taken by
the licensee as a result of failures noted in the licensed
operator and senior operator NRC administered requalification
examinations conducted on July 1, 1985.
October 30, 1985 - Letter confirming the licensee's actions
to reduce the maintenance backlog which was still found
unacceptable after the maintenance team followup inspection.
F. LICENSEE EVENT REPORTS (LER), CONSTRUCTION DEFICIENCY REPORTS, AND
,
10 CFR 21 REPORTS
1. Licensee Event Reports (LER)
Note: Effective with the issuance of 10 CFR 50.73 (January 1,
1]84) reporting requirements were'significantly changed.
Therefore data for this SALP period are not directly
comparable with prior SALP statistics.
'
'LER No. 84023 through 84027
85001 through 85023
Of the twenty-nine reports submitted during this appraisal
period (SALP 6), six were classified as voluntary reports.
The proximate cause codes for this period's reports, as well
as those of previous periods, are as follows:
37
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n 3
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l
CAUSE CODE SALP 4 SALP 5 SALP 6
Personnel Error 3 15 14
Design Deficiency 5 6 1
Deficient Procedure 3 8 2
Component Failure 46 20 10
Other 15 10 1
72 59 28
In general, the LER's provided adequate information to give
a description of the occurrence, the: direct consequences of
the event and the licensee's corrective actions. Some event
reports that contained inadequate or incorrect information
were updated, when the deficiencies were pointed out to the
licensee. In some reports, however, the licensee's use of
tactful expression clouded the real issue of the event.
Three LERs (LER 85-010,85-013 and 85-016) collectively
reported two automatic trips from power and four subcritical
actuations of the reactor protection system due to nuclear
instrument noise.
Nevertheless, the number of events which were attributed'to
personnel error, in part or entirely in this SALP period
remained the same as the prior SALP period. Specific concerns
about these errors were discussed in their respective functional
areas in Section IV of this report. A second statistic of
concern is the number of events attributed to equipment or
component failure. A number of repetitive material problems
continued to plague the plant and are in need of attention,
although the number of events associated with this cause code
was greatly reduced from previous SALP periods. These were
previously discussed under Paragraph IV.C. " Maintenance."
During this assessment period, the NRC's Office for Analysis
.and Evaluation of Operational Date (AE0D) began using a new
methodology to assess the quality of LERs submitted by
licensees. A copy of the AE0D report on the Palisades plant
will be provided to the licensee under separate cover. Summary
comments, however, are provided here. In general, AE00 found
the LERs to be of above-average quality based on the
requirements contained in 10 CFR 50.73. The Palisades LERs
have the third highest overall average score of the 24 units
that have been evaluated to date using this methodology. This
was accomplished (1) without the use of an outline format which
the other high scoring units use, and'(2) in spite of the fact
that two of the ten LERs were of below average quality. If
Palisades were to implement the use of a good _ format and
improve their review process so as to identify and correct
those few LERs which are not meeting current requirements or
which contain minor deficiencies, Palisades could submit even
38
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._
higher quality LERs in the future. (Note: The AE0D report
only sampled ten of the twenty-nine LERs submitted during the
appraisal period.) AE00 noted the areas most needing
improvement in the LERs were: safety assessment inform'ation;
manufacturer and model number information; date and time
information; previous similar events; EIIS codes; text
presentation and readability; abstract; and coded fields.
2. Construction Deficiency Reports
There were no reports issued.
3. 10 CFR 21 Reports
There were no reports issued.
G. LICENSING ACTIVITIES
1. NRR Site and Corporate Office Visits
May 8, 1985 -
Site visit by J.-Zwolinski for his plant
orientation. Toured plant and met with
Vice President R. DeWitt, Plant Manager
J. Firlit, and other plant management
personnel.
May 9, 1985 -
Corporate office visit by J. Zwolinski to
meet with corporate licensing and engineering
staff. Discussed existing and future
licensing activities and priorities.
July 15, 1985 - Site visit to meet with CPCo and Be; Fuel
Corporation personnel regarding concu.ns
about cable trays in Switchgear Room. Held
meeting and toured Switchgear Room.
2. Commission Briefing
September 18, 1985 - Commission briefed on Main Steam Line
j Break Single Failure Issues at Palisades
3. Schedule Extension Granted
February 25, 1985 - Granted extension to November 30, 1985
for Equipment Qualification, 10 CFR 50.49
4. Relief Granted
None
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5. Exemptions Granted
July 12, 1985 - Granted exemption from the requirements of
Section III.G.3 of Appendix R to 10 CFR 50 for the Engineered
Safeguards Room and the Corridor Between.the Charging Pump Room
and IC Switchgear Room.
6. -Licensee Amendments Issued
Amendment No. 85, issued November 9, 1984, Radiological
Effluent Technical Specifications (RETS)
Amendment No. 86, issued December 10, 1984, Plant Review
Committee Review Process
Amendment No. 87, issued April 29, 1985, Two Modifications Made
to RETS issued in Amendment No. 85
Amendment No. 88, issued June 6, 1985, One time extension of
allowable outage time for emergency diesels from seven to 10
days for the month of May 1985
Amendment No. 89, issued August 21, 1985, Revised Pressure /
Temperature Limits for Reactor Vessel per Appendix G to 10 CFR 50
Amendment No. 90, issue'd August 26, 1985, Limiting Conditions
for Operation and Surveillance-Requirements for Containment
Purge and Vent
Amendment No. 91, issued September 5, 1985, Deletes
Specification 4.13 Reactor Internals Vibration Monitoring
Amendment No. 92, issued October 28, 1985, Revises Diesel
Generator Surveillance Frequency from every 18 months to each
refueling cycle
7. Emergency / Exigent Technical Specification
On May 24, 1985 an emergency Technical Specification change was
made to extend allowable outage time for diesel generators.
This change was formally issued as Amendment No. 88.
8. Orders Issued
Order Modifying License to Confirm Additional Licensee
Commitments on Emergency Response Capability (Supplement 1 to
NUREG-0737) was issued on July 1, 1985.
i
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9. .NRR/ Licensee Management-Conference
On August 21, 1985 CPCo Director of Licensing and two of his i
staff met with the Director, Division of Licensing, ONRR and
members of his staff to present an overview of the
single-failure issues associated with the main steam line break
accident analysis for Palisades.
t
41~
. _ _ .- - _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ - - _ - _ _ _ - _ _ - _ _ _ _ - - _ _ _ - _ - - _ _ _ - _ _ _ _____-. - _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ - - - _ -