ML040230196

IR 05000255-03-008; on 10/01/2003 - 12/31/2003; Palisades Nuclear Generating Plant; Equipment Availability, Reliability and Functional Capability (71111.EP). Non-Cited Violations Noted

ML040230196
Person / Time
Site:	Palisades
Issue date:	01/22/2004
From:	Eric Duncan NRC/RGN-III/DRP/RPB6
To:	Domonique Malone Nuclear Management Co
References
IR-03-008
Download: ML040230196 (60)

See also: IR 05000255/2003008

Text

January 22, 2004

Mr. Daniel J. Malone

Site Vice President

Palisades Nuclear Plant

Nuclear Management Company, LLC

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT:

PALISADES NUCLEAR GENERATING PLANT

NRC INSPECTION REPORT 05000255/2003008

Dear Mr. Malone:

On December 31, 2003, the U. S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Palisades Nuclear Generating Plant. The enclosed report documents the

inspection findings which were discussed on January 9, 2004, with you and other members of

your staff.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this inspection, two findings of very low safety significance (Green) were

identified, which were determined to involve violations of NRC requirements. However,

because these findings were of very low safety significance and because the findings have

been entered into your corrective action program, the NRC is treating these violations as

Non-Cited Violations in accordance with Section VI.A.1 of the NRCs Enforcement Policy.

If you contest the subject or severity of a Non-Cited Violation, you should provide a response

with a basis for your denial, within 30 days of the date of this inspection report, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-

0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -

Region III, 801 Warrenville Road, Lisle, IL 60532-4351; the Director, Office of Enforcement,

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident

Inspector at the Palisades facility.

D. Malone

-2-

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter

and its enclosure will be available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRC's

document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eric R. Duncan, Chief

Branch 6

Division of Reactor Projects

Docket No. 50-255

License No. DPR-20

Enclosure:

Inspection Report 05000255/2003008

w/Attachment: Supplemental Information

cc w/encl:

J. Cowan, Executive Vice President

and Chief Nuclear Officer

R. Fenech, Senior Vice President, Nuclear

Fossil and Hydro Operations

D. Cooper, Senior Vice President - Group Operations

Manager, Regulatory Affairs

J. Rogoff, Vice President, Counsel and Secretary

A. Udrys, Esquire, Consumers Energy Company

Director of Nuclear Assets, Consumers Energy Company

Supervisor, Covert Township

Office of the Governor

Michigan Department of Environmental Quality -

Waste and Hazardous Materials Division

Michigan Department of Attorney General

DOCUMENT NAME: S:\\ADMIN\\Karen's Docs\\ML040230196.wpd

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy

OFFICE

RIII

NAME

EDuncan:dtp

DATE

01/22/03

OFFICIAL RECORD COPY

D. Malone

-2-

ADAMS Distribution:

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HBC

JAL3

C. Ariano (hard copy)

C. Pederson, DRS (hard copy - IRs only)

DRPIII

DRSIII

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Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No:

50-255

License No:

DPR-20

Report No:

050000255/2003008

Licensee:

Nuclear Management Company, LLC

Facility:

Palisades Nuclear Generating Plant

Location:

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

Dates:

October 1 through December 31, 2003

Inspectors:

J. Lennartz, Senior Resident Inspector

M. Garza, Resident Inspector

R. Alexander, Radiation Specialist

A. Dunlop, Reactor Engineer

R. Jickling, Emergency Preparedness Analyst

Approved by:

Eric R. Duncan, Chief

Branch 6

Division of Reactor Projects

Enclosure

1

SUMMARY OF FINDINGS

IR 05000255/2003008; 10/01/2003 - 12/31/2003; Palisades Nuclear Generating Plant;

Equipment Availability, Reliability and Functional Capability (71111.EP).

This report covers a 3-month period of baseline resident inspections, two announced baseline

inspections in radiation protection, an announced heat sink performance inspection and a

routine baseline emergency preparedness inspection. The inspections were conducted by

resident inspectors, a regional inspector, a radiation specialist inspector, and an emergency

preparedness analyst. Two Green findings with associated Non-Cited Violations (NCVs) were

identified during the inspection. The significance of most findings is indicated by their color

(Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance

Determination Process, (SDP). Findings for which the SDP does not apply may be Green or

be assigned a severity level after NRC management review. The NRCs program for

overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A.

Inspector Identified Findings

Cornerstone: Mitigating Systems

C

Green. A finding of very low safety significance was self-revealed when High Pressure

Safety Injection Pump P-66B Subcooling Valve CV-3070 failed to stroke open during

surveillance testing. Licensee personnel improperly installed a flow control valve in the

operating air system which contributed to the valve failing to stroke open. The finding

was more than minor because the availability and capability of High Pressure Safety

Injection Pump P-66B was adversely affected. The finding was of very low safety

significance because there was not an actual loss of safety function for High Pressure

Safety Injection Pump P-66B for greater than the Technical Specification allowed outage

time.

Corrective actions to address this issue included reinstalling the flow control valve in the

proper direction, testing CV-3070 during a mid-surveillance cycle stroke test, and

generating a work order to inspect the CV-3070 valve internals at the earliest opportunity.

One Non-Cited Violation of 10 CFR 50, Appendix B, Criterion V, Instructions,

Procedures and Drawings, was identified. (Section 1REP)

Cornerstone: Barrier Integrity

C

Green. A finding of very low safety significance was self-revealed when the

Containment Spray Pump P-54C inboard motor bearing failed on August 21, 2003.

Following a scheduled oil change on the motor bearing, the bearing housing drain plug

was also replaced and enough oil was lost during this drain plug replacement to uncover

the bearing; however, the vent on the oiler had been plugged when the pump was

painted in June 2002 which resulted in an erroneous level indication in the oiler for the

bearing housing. Consequently, the operator did not add sufficient oil through the oiler to

the bearing housing after the drain plug was replaced. As a result, the inboard motor

bearing was inadequately lubricated which caused the bearing to fail when Containment

Enclosure

2

Spray Pump P-54C was started. This finding was more than minor because if left

uncorrected, it would become a more significant safety concern. Specifically, the painted

vent hole on the motor bearing oiler resulted in erroneous oil level indication and

prevented the oiler from adding oil to the bearing housing when the level decreased.

Consequently, an inadequately lubricated bearing would not be detected until the bearing

failed. The finding was of very low safety significance because it did not represent an

actual reduction of the atmospheric pressure control function of the reactor containment.

Corrective actions to address this issue included clearing the vent hole on the bearing

oiler, verifying that the oiler vent holes on other safety-related pump motors were not

painted over and replacing the inboard motor bearing on Containment Spray Pump

P-54C. One Non-Cited Violation of 10 CFR 50, Appendix B, Criterion V, Instructions,

Procedures and Drawings, was identified. (Section 1REP)

B.

Licensee Identified Findings

None.

Enclosure

3

REPORT DETAILS

A list of documents reviewed within each inspection area is included at the end of the report.

Summary of Plant Status

The plant operated at full power during the inspection period with the following exception:

C

On November 8, 2003, power was reduced to 85 percent to conduct scheduled turbine

valve testing. During these activities, Heater Drain Pump P-10B unexpectedly tripped

due to low level in Moisture Separator and Heater Drain Tank T-5. Site personnel

subsequently identified that T-5 Level Control Valve CV-0608 was not operating

properly. A trip of one heater drain pump with power at 85 percent did not require any

mitigating actions.

On November 9, 2003, during emergent maintenance on Moisture Separator Reheater

Stop Valve CV-0537, control room operators noted that Tank T-5 level was lowering

again. As a result, Heater Drain Pump P-10A tripped. Operators subsequently

stabilized power at 72 percent.

After the second heater drain pump tripped, operations personnel identified that the

discharge check valve on Heater Drain Pump P-10A was not fully seated and repairs

were required. While completing necessary repairs to the discharge check valve,

Heater Drain Pump P-10B was restarted on November 10, 2003, and power was

increased to 90 percent.

Following repairs, Heater Drain Pump P-10A was returned to service and the plant

returned to full power on November 13, 2003.

1.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and

Emergency Preparedness

1R01

Adverse Weather Protection (71111.01)

.1

Cold Weather Preparations

a.

Inspection Scope

The inspectors reviewed the sites Cold Weather Checklists that were completed from

October through November 2003 to assess the actions taken to prepare for the onset of

cold weather. The inspectors also performed walkdowns to verify the physical condition

of weather protection features for risk significant systems and components.

The inspectors reviewed selected condition reports related to cold weather preparation

problems and verified that identified problems were entered into the corrective action

Enclosure

4

program with the appropriate significance characterization and that planned and

completed corrective actions were appropriate.

b.

Findings

No findings of significance were identified.

.2

Entry into Off-Normal Procedure Because of High Winds

a.

Inspection Scope

The inspectors assessed the actions taken for one emergent adverse weather condition.

On November 12, 2003, operations personnel entered Off-Normal Procedure-12, Acts

of Nature, after the control room received a weather warning regarding sustained wind

speeds of 40 miles per hour and wind gusts to 50 miles per hour. The inspectors

verified that the actions specified in Off-Normal Procedure-12 were being accomplished

to the extent possible for this emergent adverse weather condition. Off-Normal

Procedure-12 was exited on November 13, 2003, after the high winds diminished.

b.

Findings

No findings of significance were identified.

1R04

Equipment Alignment

.1

Quarterly Equipment Alignment Walkdowns (71111.04Q)

a.

Inspection Scope

The inspectors performed two equipment alignment walkdowns to verify that the

following systems were properly aligned:

C

Instrument Air Compressors C-2A and C-2C

C

Control Room Heating, Ventilation and Air Conditioning Train B

For these systems, the inspectors verified that power was available, that accessible

equipment and components were appropriately aligned, and that no discrepancies

existed which would impact system function.

The inspectors also reviewed selected condition reports related to equipment alignment

problems and verified that identified problems were entered into the corrective action

program with the appropriate significance characterization and that planned and

completed corrective actions were appropriate.

b.

Findings

No findings of significance were identified.

Enclosure

5

1R05

Fire Protection

.1

Fire Area Walkdowns (71111.05Q)

a.

Inspection Scope

The inspectors toured the following six areas in which a fire could affect safety-related

equipment:

C

Battery Room #1 (Fire Area 12)

C

Electrical Equipment Room (Fire Area 21)

C

East Engineered Safeguards Room (Fire Area 10)

C

West Mechanical Equipment Room (Fire Area 31)

C

East Mechanical Equipment Room (Fire Area 30)

Auxiliary Building Level 590 Corridor (Fire Area 13)

The inspectors verified that transient combustibles and ignition sources were

appropriately controlled, and assessed the material condition of fire suppression

systems, manual fire fighting equipment, smoke detection systems, and fire barriers.

The inspectors also reviewed documentation for completed surveillances to verify that

fire protection equipment and fire barriers were tested as required to ensure availability.

The inspectors verified that the installed fire protection equipment in the fire areas

corresponded with the equipment which was referenced in the applicable portions of the

Updated Final Safety Analysis Report, Section 9.6, Fire Protection.

The inspectors reviewed selected condition reports related to fire protection problems

and verified that identified problems were entered into the corrective action program with

the appropriate significance characterization and that planned and completed corrective

actions were appropriate.

b.

Findings

No findings of significance were identified.

1R06

Flood Protection (71111.06A)

a.

Inspection Scope

The inspectors performed one inspection sample of internal flood protection features for

the safety-related batteries which the Updated Final Safety Analysis Report designated

as equipment that required protection from flooding due to failures of nonsafety-related

systems.

Enclosure

6

The inspectors conducted walkdowns noting the following attributes associated with the

battery rooms:

C

Holes or unsealed penetrations in floors, ceilings and walls;

C

Common drain system and sumps, including floor drain piping and check valves

where credited for isolation of flood areas; and

C

Sources of potential internal flooding that were not analyzed or were not

adequately maintained.

The inspectors also assessed condition reports related to flood protection problems to

verify that identified problems were entered into the corrective action program with the

appropriate significance characterization and that corrective actions were appropriate

and implemented as scheduled.

b.

Findings

No findings of significance were identified.

1R07

Heat Sink Performance (71111.07B)

a.

Inspection Scope

The regional specialist inspector reviewed documents associated with maintenance,

inspection, and thermal performance testing of the containment air coolers and the

control room heating, ventilation and air conditioning condensers (the heat exchangers

represented two inspection samples). These heat exchangers and coolers were chosen

based on previous corrosion and tube plugging concerns. While onsite, the inspector

reviewed completed surveillances, associated calculations, instrument calibration

records, and maintenance work orders, and performed independent calculations to

verify that these activities adequately ensured proper heat transfer. The inspector

reviewed the documentation to confirm that the test methodology was consistent with

accepted industry practices, that test acceptance criteria were consistent with design

basis values, and that the test results appropriately considered differences between test

and design conditions.

The inspector also reviewed documentation to confirm that methods used to inspect the

heat exchangers were consistent with expected degradation and that the established

acceptance criteria were consistent with accepted industry standards. The inspector

verified that systems and sub-components were free from clogging due to macrofouling

and that the licensee had adequate controls in place for biotic fouling.

In addition, the inspectors reviewed condition reports concerning heat exchanger and

heat sink performance issues to verify that the licensee had an appropriate threshold for

identifying issues and to evaluate the effectiveness of the licensees corrective actions

to address the identified issues.

b

Findings

No findings of significance were identified.

Enclosure

7

1R11

Licensed Operator Requalification (71111.11Q)

a.

Inspection Scope

The inspectors observed one crew of licensed operators during simulator training on

December 3, 2003. The inspectors assessed the operators ability to use Off-Normal

and Emergency Operating plant procedures to mitigate the following simulated events:

C

loss of two offsite power sources which resulted in a rise in switchyard voltage

concurrent with a failure of the automatic voltage adjuster on the main generator;

C

sequential high differential pressures in service water basket strainers due to

debris intrusion;

C

loss of one switchyard bus during a plant trip which resulted in emergency diesel

generators starting and energizing safety-related electrical loads; and

C

blockage of service water traveling screens due to frazil ice resulting in a loss of

service water.

The inspectors also verified that the Shift Manager implemented the Emergency Plan

Implementing Procedures in an accurate and timely manner when classifying the events

and notifying off-site authorities. In addition, the inspectors observed the post-scenario

critique to assess the licensee evaluators and the crews ability to self-identify

performance weaknesses.

b.

Findings

No findings of significance were identified.

1R13

Maintenance Risk Assessments and Emergent Work Evaluation (71111.13Q)

a.

Inspection Scope

The inspectors reviewed Operators Risk Reports, the Operations Log, and daily

maintenance schedules to verify that equipment necessary to minimize plant risk was

operable or available as required during planned and emergent maintenance activities.

The inspectors also conducted plant walkdowns to verify that equipment necessary to

minimize risk was available for use. The following four activities were reviewed:

C

Scheduled outage for Emergency Diesel Generator 1-2 during the week of

September 29, 2003;

C

Scheduled surveillance testing for the Reactor Protection System during the

week of November 10, 2003;

C

Scheduled surveillance testing for Emergency Diesel Generator 1-2 on

November 18-19, 2003; and

C

Emergent maintenance on Emergency Diesel Generator 1-1 on December 7-10,

2003.

b.

Findings

No findings of significance were identified.

Enclosure

8

1R14

Operator Performance During Non-Routine Evolutions and Events (71111.14)

a.

Inspection Scope

On November 8, 2003, the inspectors observed portions of main turbine governor and

stop valve testing to verify that the evolution was effectively controlled and conducted in

accordance with System Operating Procedure-8, Main Turbine and Generating

Systems.

The inspectors also reviewed the events and circumstances that resulted in the

unexpected trip of one nonsafety-related heater drain pump which occurred during

turbine valve testing. In addition, the inspectors reviewed the events and circumstances

which necessitated a downpower from 82 percent to 72 percent in response to an

imminent unplanned trip of the second heater drain pump after turbine valve testing

activities had been completed. The inspectors reviewed control room logs, annunciator

response procedures, and off-normal operating procedures to verify that the control

room operators responded as required.

The inspectors also assessed condition reports related to the turbine valve testing and

verified that the problems were entered into the corrective action program with the

appropriate significance characterization and that the licensees immediate corrective

actions were appropriate.

b.

Findings

No findings of significance were identified.

1R17

Permanent Plant Modifications (71111.17)

a.

Inspection Scope

The inspectors reviewed one permanent plant modification which provided an alternate

flowpath of borated water to the primary coolant system to safely shut down the plant to

cold shutdown following a seismic event. The modification included the following

Engineering Assistance Request (EAR) design documents:

EAR-2000-0345, Seismic Qualification Utility Group (SQUG) Outlier Resolution

for Safety Injection Refueling Water Tank T-58;

C

EAR-2002-017, for modifications to the service water system and spent fuel pool

cooling system; and

C

EAR-2002-0293, for modifications to the charging system header.

The inspectors reviewed the associated safety analyses and design change information

to verify that the design basis and performance capability of the spent fuel pool cooling

system and charging system was not degraded. The inspectors also verified that the

modification was installed in the plant as designed; the plant operating procedures and

plant drawings were revised appropriately; and the required lengths of fire hoses, tools

and connectors necessary to establish the alternate flowpath were pre-staged and

available for use if needed.

Enclosure

9

Further, the inspectors verified that identified problems associated with plant

modifications were entered into the licensees corrective action program with the

appropriate significance characterization, and that corrective actions were appropriate

and implemented as scheduled.

b.

Findings

No findings of significance were identified.

1R19

Post Maintenance Testing (71111.19)

a.

Inspection Scope

The inspectors observed portions of post maintenance testing and reviewed

documented testing activities to verify that the tests were adequately performed for the

following three activities:

C

Service Water Pump P-7C repack

C

Emergency Diesel Generator 1-2 maintenance outage

C

Low Pressure Safety Injection Pump P-67B breaker 152-111 replacement

The inspectors verified that applicable testing prerequisites were met prior to the start of

the tests and that the effect of testing on plant conditions was adequately addressed by

the control room operators.

The inspectors also reviewed post maintenance testing criteria to verify that the test

criteria and acceptance criteria were appropriate for the scope of work performed;

reviewed completed tests and associated procedures to verify that the tests adequately

verified system operability; and reviewed documented test data to verify that the data

was complete and that the equipment met the testing acceptance criteria.

Further, the inspectors reviewed condition reports to verify that post maintenance testing

problems were entered into the corrective action program with the appropriate

significance characterization.

b.

Findings

No findings of significance were identified.

1R22

Surveillance Testing (71111.22)

a.

Inspection Scope

The inspectors reviewed three surveillance testing activities conducted on the following

risk-significant plant equipment:

C

Safety Injection Initiation Circuitry

C

Control Room Heating, Ventilation and Air Conditioning System

C

Service Water Pump P-7A

Enclosure

10

The inspectors observed portions of the testing to verify that the testing was conducted

in accordance with prescribed procedures. The inspectors also reviewed the

documented test data for the Technical Specification Surveillance Test procedures and

the associated basis documents to verify that testing acceptance criteria were satisfied.

In addition, the inspectors reviewed applicable portions of Technical Specifications, the

Updated Final Safety Analysis Report, and design basis documents to verify that the

surveillance tests adequately demonstrated that system components could perform

required safety functions.

Further, the inspectors reviewed selected condition reports regarding surveillance

testing activities to verify that the identified problems were entered into the licensees

corrective action program with the appropriate significance characterization and that the

planned and completed corrective actions were appropriate.

b.

Findings

No findings of significance were identified.

1REP Equipment Availability, Reliability and Functional Capability (71111.EP)

.1

Quarterly Maintenance Effectiveness Reviews

a.

Inspection Scope

The inspectors conducted three maintenance effectiveness reviews for the following:

C

Containment Spray Pump P-54C

C

2400 Volt and 4160 Volt Station Power Systems

C

High Pressure Safety Injection Pump Subcooling Valve CV-3070

The inspectors reviewed the licensee's implementation of the maintenance rule

requirements to verify that component and equipment failures were identified and

appropriately dispositioned. The inspectors also verified that select systems and

components were properly categorized and classified as (a)(1) or (a)(2) in accordance

with 10 CFR 50.65.

The inspectors reviewed the licensees maintenance rule performance indicators to

verify that the system status had been appropriately categorized in accordance with the

maintenance rule program; reviewed work order histories and selected condition reports

written against the system over the last 2 years to verify that maintenance and identified

problems had been appropriately addressed; and reviewed completed work orders to

determine if there was an adverse trend in system performance that could be attributed

to inappropriate work practices and to determine if there were any common cause

issues that had not been addressed. Additionally, the inspectors reviewed the

licensees performance criteria to verify that the criteria adequately monitored equipment

performance.

Enclosure

11

In addition, the inspectors reviewed selected condition reports and associated

maintenance rule evaluations to verify that identified problems were appropriately

characterized and dispositioned in accordance with the licensees maintenance rule

program. The inspectors also verified that planned corrective actions were appropriate

and had been implemented as scheduled.

b.

Findings

1.

Containment Spray Pump P-54C

Introduction

The inspectors identified a finding of very low safety significance (Green) and an

associated Non-Cited Violation of 10 CFR 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, when the inboard motor bearing on Containment Spray

Pump P-54C failed on August 21, 2003.

Description

During a planned breaker replacement for Containment Spray Pump P-54C, licensee

personnel also replaced the inboard motor bearing oil. An operator performed the motor

bearing oil replacement in accordance with the applicable work instruction on August 21,

2003. After the oil was replaced, the operator noticed that the drain plug to the bearing

housing was set too far into the housing. Therefore, the operator requested and

obtained permission to replace the drain plug. After the new drain plug was installed,

the operator added oil to the bearing housing through the inboard motor bearing oiler to

replace the oil that was drained when the drain plug was removed.

However, during post maintenance testing following Containment Spray Pump P-54C

breaker replacement, operators observed smoke from the inboard motor bearing area

and heard abnormal metallic noises. Therefore, the operators secured Containment

Spray Pump P-54C to investigate a potentially failed motor bearing. During the

investigation, licensee personnel determined that the oil level in the motor bearing

housing was below the slinger ring and that the inboard motor bearing had failed due to

a lack of lubrication. After further review, licensee personnel identified that the vent hole

on the oiler for the inboard motor bearing on Containment Spray Pump P-54C was

covered with paint. Licensee personnel subsequently determined that the motor for

Containment Spray Pump P-54C was painted in June 2002 under a general work order

for miscellaneous painting.

Through the root cause evaluation, licensee personnel determined that the plugged vent

caused the oiler to become air bound and unable to adequately add oil to the bearing

housing when the level decreased. Licensee personnel also determined that when the

drain plug was replaced, enough oil was lost to uncover the bearing; however, the

plugged vent on the oiler resulted in an erroneous level indication in the oiler for the

bearing housing. Consequently, the operator did not add enough oil through the oiler to

the bearing housing after the drain plug was replaced. As a result, the inboard motor

bearing was inadequately lubricated which caused the bearing to fail when Containment

Spray Pump P-54C was started.

Enclosure

12

Analysis

The inspectors determined that painting over the vent hole on the Containment Spray

Pump P-54C inboard motor bearing oiler was a licensee performance deficiency which

warranted a significance evaluation. The inspectors did not identify any examples of

minor issues in Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection

Reports, Appendix E, Examples of Minor Issues that appropriately described this

finding.

The inspectors determined that the finding was more than minor in accordance with

IMC 0612, Appendix B, Issue Disposition Screening because if left uncorrected, the

issue could become a more significant safety concern. Specifically, the painted vent

hole on the bearing oiler resulted in erroneous oil level indication and prevented the oiler

from adding oil to the bearing housing when the level decreased. Consequently, an

inadequately lubricated bearing would not be detected until the bearing failed.

The inspectors also determined that the finding could be evaluated using IMC 0609,

Significance Determination Process, (SDP) because the finding was associated with

the integrity of reactor containment. Using IMC 0609, Appendix A, SDP Phase 1

Screening Worksheet for IE [Initiating Events], MS [Mitigating Systems], and B [Barrier

Integrity] Cornerstones, the inspectors determined that the Barrier Integrity cornerstone

was the only affected area.

Using the Barrier Integrity column on the SDP Phase 1 worksheet, the inspectors

determined that since the finding did not represent a degradation of the radiological

barrier function provided for the control room, or auxiliary building, or spent fuel pool; did

not represent a degradation of the barrier function of the control room against smoke or

a toxic atmosphere; and did not represent an actual open pathway in the physical

integrity of reactor containment or an actual reduction of the atmospheric pressure

control function of the reactor containment, the finding screened as Green and was

considered to be of very low safety significance.

Enforcement

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings states, in

part, that activities affecting quality shall be prescribed by documented instructions of a

type appropriate to the circumstances and shall be accomplished in accordance with

these instructions. Contrary to this requirement, painting of Containment Spray Pump

P-54C in June 2002, an activity affecting quality, did not have written instructions

appropriate to the circumstances. Consequently, the vent hole on the oiler was plugged

with paint which caused an erroneous oil level indication and the subsequent motor

bearing failure due to an inadequately lubricated bearing on August 21, 2003. However,

because this violation was associated with a finding of very low safety significance and

because the finding was entered into the licensees corrective action program, this

violation is being treated as a Non-Cited Violation, consistent with Section VI.A of the

NRC Enforcement Policy (NCV 05000255/2003008-01). This issue was entered into the

licensees corrective action program as CAP037180.

Enclosure

13

As part of the licensees corrective actions, licensee personnel cleared the vent hole on

the inboard motor bearing oiler for Containment Spray Pump P-54C and verified the

oiler vent holes on other safety-related pump motors were not painted over. In addition,

the inboard motor bearing on Containment Spray Pump P-54C was replaced, and the

pump was subsequently tested satisfactorily.

2.

High Pressure Safety Injection Pump P-66B Subcooling Valve CV-3070

Introduction

The inspectors identified a finding of very low safety significance (Green) and an

associated Non-Cited Violation of 10 CFR 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, when High Pressure Safety Injection Pump P-66B

Subcooling Valve CV-3070 failed to stroke open during surveillance testing.

Description

On August 10, 2003, during surveillance testing, air operated High Pressure Safety

Injection Pump P-66B Subcooling Control Valve CV-3070 failed to stroke open with the

control switch held in the open position. Control Valve CV-3070 was required to open in

less than 2 seconds and had a safety-related support function for High Pressure Safety

Injection Pump P-66B during long term core cooling.

During troubleshooting activities on August 11, 2003, licensee personnel discovered that

a flow control valve in the operating air system was installed backwards which caused

CV-3070 to close faster than intended. The faster closing rate provided higher than

intended seating forces when the valve was closed. After further investigation, licensee

personnel concluded that the flow control valve was most likely installed backwards

when the valve actuator was rebuilt in July 1995 through Work Order 24412938. This

conclusion was based on: (1) there were no additional work orders for the valve

actuator since the flow control valve was initially installed in January 1986; (2) the

closing time for CV-3070 after the flow control valve was initially installed in 1986 was

20 seconds; (3) one-time stem thrust data taken in February 1998 indicated that

CV-3070 closed in 0.8 seconds; and (4) the as-found closing time on August 11 for

CV-3070 was 1.2 seconds. Because CV-3070 did not have a safety function to close,

the valve was not timed in the closed direction during quarterly testing. Therefore, no

additional closing time data was available.

Consequently, licensee personnel concluded that the seating force on the valve disc

from the faster than intended closing rate prevented the valve from opening during the

surveillance test. However, licensee personnel determined that the faster closing rate

was not conclusively the cause since the valve stroked open successfully each time it

had been tested since the flow control valve was installed backwards in 1995. Also,

there were no work activities performed on CV-3070 after the last successful

surveillance test in May 2003. In addition, on August 11, 2003, licensee personnel were

able to open CV-3070 using minor mechanical agitation during troubleshooting activities

and the valve was then stroked open successfully several times after the valve was

closed with the same fast closing rate.

Enclosure

14

Licensee personnel subsequently repositioned the flow control valve in the proper

direction and the as-left closing time for CV-3070 was 5.0 seconds. On August 12,

2003, CV-3070 opened within 2 seconds when tested and was declared operable.

However, because licensee personnel could not definitively conclude that the short

closing time caused CV-3070 to not open on August 10, Work Order 24323139 was

generated to disassemble and inspect CV-3070 at the earliest opportunity. In addition,

to provide confidence that CV-3070 could open as required, a mid-surveillance cycle

stroke test was performed on September 9, 2003, successfully.

Analysis

The inspectors determined that the incorrect installation of the flow control valve in 1995

was a licensee performance deficiency warranting a significance evaluation in

accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue

Disposition Screening. The inspectors did not identify any examples of minor issues in

IMC 0612, Appendix E, Examples of Minor Issues, that appropriately described this

finding.

The inspectors concluded that the finding was more than minor because it was

associated with the Procedure Quality attribute of the Mitigating Systems cornerstone

and affected the cornerstone objective of ensuring the availability, reliability, and

capability of a system that responds to an initiating event to prevent undesirable

consequences.

The inspectors determined that the finding could be evaluated using IMC 0609,

Significance Determination Process, (SDP) because the finding was associated with

the availability of a mitigating system. Using IMC 0609, Appendix A, SDP Phase 1

Screening Worksheet for IE [Initiating Events], MS [Mitigating Systems], and B [Barrier

Integrity] Cornerstones, the inspectors determined that the Mitigating Systems

cornerstone was the only affected area.

Using the Mitigating Systems column on the SDP Phase 1 worksheet, the inspectors

determined that since the failure of CV-3070 to open during surveillance testing was not

a design or qualification deficiency; did not represent an actual loss of safety function for

a system or for a single train for greater than the Technical Specification allowed outage

time; and did not screen as potentially risk significant due to a seismic, fire, flooding, or

severe weather initiating event, the finding screened out as Green and was considered

to be of very low safety significance.

Enforcement

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires,

in part, that activities affecting quality shall be prescribed by documented instructions of

a type appropriate to the circumstances and shall be accomplished in accordance with

those instructions. Contrary to this requirement, the work instructions for the

maintenance performed in July 1995 to rebuild the actuator for CV-3070, an activity

affecting quality, were not of a type appropriate to the circumstances. Specifically, the

work instructions did not contain adequate guidance to ensure that the flow control valve

Enclosure

15

was installed with the correct orientation in the operating air system for the valve

actuator.

Consequently, the flow control valve was installed backwards which resulted in faster

than intended closing times which contributed to valve CV-3070 failing to stroke open as

required on August 10, 2003. However, because this violation was associated with a

finding of very low safety significance and because the finding was entered into the

licensees corrective action program, this violation is being treated as a Non-Cited

Violation, consistent with Section VI.A of the NRC Enforcement Policy

(NCV 05000255/2003008-02). This issue was entered into the licensees corrective

action program as CAP037030.

Corrective actions to address the finding included reinstalling the flow control valve in

the proper position, testing CV-3070 during a mid-surveillance cycle stroke test, and

generating a work order to inspect the valve internals at the earliest opportunity.

.2

Biennial Assessment of Maintenance Rule Periodic Evaluations

a.

Inspection Scope

The inspectors reviewed the Maintenance Rule Periodic Refueling Assessment Report

for the period of August 1, 2000, to July 31, 2002. The inspectors verified that: (1) the

periodic evaluation had been completed as required by 10 CFR 50.65(a)(3);

(2) maintenance rule (a)(1) goals and (a)(2) performance criteria were reviewed by the

licensee; (3) industry operating experience was taken into account when appropriate;

(4) balancing of availability and reliability was reviewed; and (5) appropriate adjustments

were made as a result of the periodic evaluation.

The inspectors also reviewed the following four systems to assess how performance

problems were addressed within the maintenance rule program:

C

Concentrated Boric Acid System

C

Control Room Heating, Ventilation, and Air Conditioning (HVAC) System

C

High Pressure Air System

C

Fire Protection System

As applicable to the four systems, the inspectors verified that: (1) maintenance rule

(a)(1) goals and activities were reviewed and adjusted as necessary; (2) corrective

actions for (a)(1) activities were appropriate; (3) maintenance rule (a)(2) performance

criteria was appropriate and met; (4) evaluations for placing the system in maintenance

rule (a)(1) were completed when performance criteria was not met; (5) equipment

failures were evaluated and appropriately dispositioned as functional failures,

maintenance preventable functional failures or repeat maintenance preventable

functional failures; and (6) preventive maintenance activities were adjusted as

necessary.

The inspectors also reviewed a sample of condition reports to verify that the significance

of identified problems was appropriately characterized. For select condition reports, the

Enclosure

16

inspectors verified that the corrective actions were appropriate and implemented in a

timely manner commensurate with the significance of the problem.

b.

Findings

No findings of significance were identified.

.3

Operability Evaluations

a.

Inspection Scope

The inspectors reviewed three operability assessments as documented in the

associated condition reports for the following risk significant plant equipment:

C

Emergency Core Cooling System

C

Steam Generator Low Pressure Bypass signal

C

High Pressure Safety Injection Pump P-66B Subcooling Valve CV-3070

The inspectors interviewed the cognizant engineers and reviewed the supporting

documents to assess the adequacy of the operability assessments for the current plant

mode. The inspectors also reviewed the applicable sections of the Technical

Specifications, Updated Final Safety Analysis Report, and design basis documents to

verify that the operability assessments were technically adequate and that the

components remained available, such that no unrecognized increase in plant risk had

occurred.

In addition, the inspectors reviewed selected condition reports regarding operability

determinations to verify that the identified problems were entered into the licensees

corrective action program with the appropriate significance characterization and that

planned and completed corrective actions were commensurate with the significance.

b.

Findings

No findings of significance were identified.

.4

Operator Workarounds (OWAs)

a.

Inspection Scope

The Inspectors reviewed the following three risk significant operator workarounds:

Control Room Indicator Light Failure

Warm Water Recirculation Pump P-5 Vacuum Piping System

Start-up Transformer 1-2 Load

The inspectors evaluated whether the workarounds would adversely affect the operators

ability to implement abnormal and emergency operating procedures. The inspectors

reviewed the planned actions to correct the workarounds to verify that the priority to

Enclosure

17

resolve the deficiencies was reasonable when considering the potential impact on plant

risk and safety.

The inspectors also completed an aggregate assessment of the operator workarounds,

operator challenges, and control room deficiencies that were previously identified by

licensee personnel. The inspectors verified that the cumulative effects did not create

significant adverse consequences regarding the reliability, availability and operation of

risk significant systems. The inspectors also verified that the cumulative effects did not

adversely impact the operators ability to implement abnormal and emergency response

procedures in a timely manner when responding to plant transients and accidents.

b.

Findings

No findings of significance were identified.

.5

Temporary Plant Modifications

.a

Inspection Scope

The inspectors reviewed the modification documentation and the associated

10 CFR 50.59 evaluation for temporary modification TM-2000-024. This temporary

modification was developed to provide an alternate water supply that could be used, if

necessary, to backwash the service water traveling screens. The inspectors verified

that the temporary modification would not adversely impact other safety-related

equipment and that testing activities for the temporary modification were adequate to

ensure that the modification would function as intended.

The inspectors also verified that System Operating Procedure - 15, Attachment 11,

Alternate Water Supply To Clean Traveling Screens, provided adequate guidance to

the operators for using the alternate water supply.

b.

Findings

No findings of significance were identified.

1EP4

Emergency Action Level and Emergency Plan Changes (71114.04)

a.

Inspection Scope

The inspectors reviewed Revisions 6, 7, and 8 of the Palisades Nuclear Plant Site

Emergency Plan to determine if changes identified in these revisions reduced the plans

effectiveness, pending on-site inspection of the implementation of these changes.

b.

Findings

The inspectors identified that the licensee had incorporated NUMARC/NESP-007,

Methodology for Development of Emergency Action Levels, (NUMARC-007)

emergency action levels (EALs) into its approved standardized classification scheme

which were based on NUREG-0654/FEMA-REP-1, Criteria for Preparation and

Enclosure

18

Evaluation of Radiological Emergency Response Plans and Preparedness in Support of

Nuclear Power Plants, (NUREG-0654). This was identified as an Unresolved Item

(URI) pending determination whether any violation of NRC requirements occurred, and a

determination as to the significance, if any violation is determined to have occurred.

During the in-office review of the licensees emergency plan changes, it was identified

that the revisions to the emergency plan deleted EALs and replaced certain of the

deleted EALs with NUMARC-007 EALs. Additional information provided by the licensee

indicated these changes resulted from a condition report initiated when the licensees

shift supervisors were making different classification decisions for the same incident

presented on the simulator. To make the classification implementing procedure more

user friendly the licensee incorporated certain NUMARC EALs. The licensee indicated

in certain cases the incorporation of specific NUMARC-007 EALs allowed elimination of

NUREG-0654 EALs because the same information was covered in other parts of the

classification procedure.

A brief listing of examples of emergency plan EALs that had been deleted and

NUMARC-007 EALs added, included the following:

Revision 6 of the emergency plan:

Table 4-2, page 36, Engineered Safety Features, the Unusual

Event EAL for reactor protection system (RPS) failure was deleted and

inability to reach a required mode within Technical Specification limits

(NUMARC-007 #SU2) was added.

Table 4-2, page 36, Engineered Safety Features, the Alert EAL for

complete loss of auxiliary feedwater system was deleted.

Table 4-2, page 36, Engineered Safety Features, the Site Area

Emergency EAL for transient requiring operation of shutdown

systems with failure to trip was deleted and failure of the RPS

instrumentation to complete or initiate an automatic reactor scram

and a RPS setpoint has been exceeded and a manual scram was

not successful (NUMARC-007 #SS2) was added.

Table 4-2, page 36, Engineered Safety Features, the General

Emergency EAL for transient requiring operation of shutdown system

with failure to trip which results in core damage or additional failure of

core cooling and makeup systems (NUREG 0654 #G-5.c) was deleted

and failure of the RPS to complete an automatic scram and manual

scram was not successful and there is indication of an extreme challenge

to the ability to cool the core (NUMARC-007 #SG2) was added.

Table 4-2, page 36, Engineered Safety Features, the General

Emergency EAL for transient initiated by loss of feedwater and

condensate system followed by failure of auxiliary feedwater system for

an extended period (NUREG 0654 #G-5.b) was deleted.

Enclosure

19

The inspectors identified that the intermingling of classification schemes deviated from

Regulatory Guide 1.101, Revision 3, which states, in part, that licensees may use either

NUREG-0654 or NUMARC-007 in their EAL scheme, but may not use portions of both

methodologies. Regulatory Guide 1.101 also states that licensees who propose to

revise their currently approved EAL classification scheme using the NUMARC-007

method adhere to the requirements in Section IV.B of Appendix E to 10 CFR Part 50

which states, in part, that these emergency action levels shall be discussed and agreed

on by the applicant and State and local government authorities and approved by the

NRC.

This issue is considered an URI pending further review by the NRC. In accordance with

NRC Inspection Procedure 71114.04, Emergency Action Level and Emergency Plan

Changes, these changes potentially result in a reduction of emergency plan

effectiveness and will be referred to the Office of Nuclear Reactor Regulation for further

review. Pending completion of these activities, the issue is considered an URI

(URI 05000255/2003008-03). The licensee has entered this issue into their corrective

action program as CAP 039195.

1EP6

Emergency Plan Drill Evaluation (71114.06)

a.

Inspection Scope

The inspectors observed a simulator training session for one crew of licensed operators

on December 17, 2003, in which the Shift Manager was required to implement the

emergency plan in response to simulated plant conditions. Licensee Emergency

Preparedness personnel had pre-designated that the opportunities for the Shift Manager

to classify the event and make required notifications would be evaluated and included in

the Drill and Exercise Performance performance indicator data.

The inspectors verified that the Shift Manager classified the emergency condition and

completed the required notifications to State and Local Police authorities in an accurate

and timely manner as required by the emergency plan implementing procedures. The

inspectors also reviewed the Emergency Preparedness Evaluators summary report to

verify that the data included in the Drill and Exercise Performance performance indicator

was accurate.

b.

Findings

No findings of significance were identified.

Enclosure

20

2.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

.1

Self-Contained Breathing Apparatus (SCBA) Maintenance

a.

Inspection Scope

The inspectors reviewed the vital component maintenance records over the past 5 years

for three SCBA units currently designated as ready for service. The inspectors also

ensured that the required, periodic air cylinder hydrostatic testing was documented and

up-to-date, and that the Department of Transportation required retest air cylinder

markings were in place for these three units: OCR-42 (located in the Ops Conference

Room by the Control Room Viewing Gallery); T625-47 (located along the east wall of the

Turbine Deck); and RPO-11 (located on the 611 foot elevation near the Radiation

Protection Offices). As the licensee did not itself conduct maintenance of vital

components of SCBA units, the inspectors reviewed licensee and vendor maintenance

procedures, including those for the low-pressure alarm and pressure-demand air

regulator, and the SCBA manufacturers recommended practices to determine if there

were inconsistencies between them.

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS1

Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems

(71122.01)

.1

Inspection Planning

a.

Inspection Scope

The inspectors reviewed the calendar years 2001 and 2002 Radiological Effluent

Release Reports to verify that the program was implemented as described in

Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual

(ODCM) and to determine if ODCM changes were made in accordance with Regulatory

Guide 1.109 and NUREG-0133. The inspectors reviewed the Radiological Effluent

Release Reports and ODCM, to determine if any changes to the design and/or

operation of the radioactive waste systems changed the dose consequence to the

public. The inspectors also reviewed technical and/or 10 CFR 50.59 evaluations

performed, when required, for any such modifications and determined whether

radioactive liquid and gaseous effluent radiation monitor setpoint calculation

Enclosure

21

methodology changed since completion of the modifications. The inspectors

determined if anomalous results reported in the current Radiological Effluent Release

Report were adequately resolved.

The inspectors reviewed RETS/ODCM to identify the effluent radiation monitoring

systems and its flow measurement devices, effluent radiological occurrence

performance indicator incidents in preparation for onsite follow-up, and the Final Safety

Analysis Report (FSAR) description of all radioactive waste systems.

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

.2

Onsite Inspection - Walk-down of Effluent Control Systems, System/Program

Modifications, Air Cleaning System Surveillances, and Instrument Calibrations

a.

Inspection Scope

The inspectors walked down the major components of the gaseous and liquid release

systems (e.g., radiation and flow monitors, demineralizers and filters, tanks, and

vessels) to observe current system configuration with respect to the description in the

FSAR, ongoing activities, and equipment material condition.

The inspectors reviewed the licensees technical justification for changes made by the

licensee to the ODCM, as well as to the liquid or gaseous radioactive waste system design,

procedures, or operation since the last inspection to determine whether the changes

affected the licensees ability to maintain effluents as-low-as-reasonably-achievable and

whether changes made to monitoring instrumentation resulted in a non-representative

monitoring of effluents.

The inspectors reviewed air cleaning system surveillance test results to ensure that the

system was operating within the licensees acceptance criteria. Specifically, the

inspectors reviewed the most recent results of the Ventilation Filter Testing Program for

the Control Room Ventilation System to verify that test methodology, frequency and test

results met Technical Specification requirements. The inspectors reviewed and

discussed the test results of in-place high efficiency particulate air (HEPA) and charcoal

absorber penetration tests, laboratory tests of charcoal absorber methyl iodide

penetration, and in-place combined HEPA filter and charcoal absorber train pressure

drop tests for the systems with system engineering staff.

The inspectors reviewed records of instrument calibrations performed since the last

inspection for each point of discharge effluent radiation monitor and flow measurement

device and reviewed any completed system modifications and the current effluent radiation

monitor alarm setpoint value for conformance with RETS/ODCM requirements. The

inspectors also reviewed calibration records of radiation measurement (i.e., counting room)

instrumentation associated with effluent monitoring and release activities and the quality

control records for the radiation measurement instruments.

Enclosure

22

These reviews represented four inspection samples: one for the walk down of the

effluent control systems, one for the program/system modification reviews, one for the

air cleaning system surveillance review, and one for the review of instrument calibration

records.

b.

Findings

During a walk down of the Radioactive Gaseous Effluent Monitoring (RGEM) system,

the inspectors identified that the as installed configuration of the sample piping

running from the isokinetic sampling head within the stations stack leading to the

RGEM radiological monitors contained at least four piping bends (i.e., elbows) of

approximately 90 degrees each. This was identified as an Unresolved Item (URI)

pending determination whether any violation of NRC requirements occurred, and a

determination as to the significance, if any violation is determined to have occurred.

Upon this observation, the inspectors inquired of the licensee as to what assurances

there were that the piping configuration did not promote plate-out of iodines and

particulates from the effluent stream and that the system was obtaining a representative

sample of the stations gaseous effluents. Prior to the end of the on-site portion of the

inspection, the licensee provided the inspectors a copy of the RGEM system design

documentation (circa 1982), which indicated that the system was designed and installed

such that it receives a representative isokinetic sample of plant gaseous effluent and

that the sample piping from the stack to the RGEM system is heat traced and insulated

to prevent condensation and plating out of the effluent sample. The inspectors

walked-down the sample piping to verify that it was insulated and the heat tracing

was operable.

During in-office review of the design documentation, the inspectors identified that the

RGEM Design Criteria (Section 3.0) for the system included ANSI N13.1-1969, Guide

to Sampling Airborne Radioactive Materials in Nuclear Facilities. Section B5 of

Appendix B of ANSI N13.1-1969 indicates that elbows in sampling lines should be

avoided if at all possible, but when they are required, the bend radius of the elbow

should be as long as practicable, and design flow rates through any line containing an

elbow should be kept low. The inspectors also noted that the ANSI standard did not

address the use of piping insulation or heat tracing as methods to mitigate iodine and

particulate plate-out.

Therefore, the inspectors preliminarily determined that the as installed configuration of

the RGEM sampling piping did not appear to meet the design criteria of the ANSI

standard. However, the inspectors were unable to determine if the as installed

configuration of the RGEM system prevented the collection of representative gaseous

effluent samples, and the significance the plate-out had, if any, on the public dose

consequences from the stations gaseous effluents. The licensee captured this issue in

its corrective action program as CAP 039097. Pending the completion of the licensees

evaluation of this issue and the NRCs review of the licensees evaluation, this issue is

considered a URI (URI 05000255/2003008-04).

Enclosure

23

.3

Onsite Inspection - Effluent Release Packages, Abnormal Releases, Dose Calculations,

and Laboratory Quality Control and Assurance

a.

Inspection Scope

As there were no routine radioactive liquid releases conducted during the on-site

inspection, the inspectors reviewed several radioactive liquid waste release permits,

including the projected doses to members of the public, to verify that appropriate

treatment equipment was used and that radioactive liquid waste was processed and

released in accordance with RETS/ODCM and procedure requirements. The inspectors

observed the routine processing (including sample collection and analysis) of radioactive

gaseous effluent from Waste Gas Decay Tank T-101A, and reviewed several other

radioactive gaseous effluent release permits, to verify that appropriate treatment

equipment was used and that the radioactive gaseous effluent was processed and

released in accordance with RETS/ODCM and procedure requirements.

The inspectors reviewed the records of abnormal releases, or releases made with

inoperable effluent radiation monitors, and reviewed the licensees actions for these

releases to ensure an adequate defense-in-depth was maintained against an

unmonitored, unanticipated release of radioactive material to the environment.

The inspectors reviewed a selection of monthly, quarterly, and annual dose calculations

to ensure that the licensee properly calculated the offsite dose from radiological effluent

releases and to determine if any annual RETS/ODCM (i.e., Appendix I to 10 CFR Part 50 values) limits were exceeded.

The inspectors reviewed the results of the interlaboratory comparison program to verify

the quality of radioactive effluent sample analyses performed by the licensee. The

inspectors reviewed the licensees quality control evaluation of the interlaboratory

comparison test and associated corrective actions for any deficiencies identified. The

inspectors reviewed the licensees assessment of any identified bias in the sample

analysis results and the overall effect on calculated projected doses to members of the

public. In addition, the inspectors reviewed the results from the licensees Quality

Assurance audits to determine whether the licensee met the requirements of the

RETS/ODCM.

These reviews represented four inspection samples: one for the review of effluent

release packages, one for the abnormal release reviews, one for the dose calculation

reviews, and one for the review of laboratory quality control and assurance.

b.

Findings

No findings of significance were identified.

Enclosure

24

.4

Identification and Resolution of Problems

a.

Inspection Scope

The inspectors reviewed licensee self-assessments, audits, and Special Reports related

to the radioactive effluent treatment and monitoring program since the last inspection to

determine if identified problems were entered into the corrective action program for

resolution. The inspectors also verified that the licensee's self-assessment program

was capable of identifying repetitive deficiencies or significant individual deficiencies in

problem identification and resolution.

The inspectors also reviewed corrective action reports from the radioactive effluent

treatment and monitoring program since the previous inspection, interviewed staff, and

reviewed documents to determine if the following activities were being conducted in an

effective and timely manner commensurate with their importance to safety and risk:

1.

Initial problem identification, characterization, and tracking;

2.

Disposition of operability/reportability issues;

3.

Evaluation of safety significance/risk and priority for resolution;

4.

Identification of repetitive problems;

5.

Identification of contributing causes;

6.

Identification and implementation of effective corrective actions;

7.

Resolution of Non-Cited Violations (NCVs) tracked in the corrective action system;

and

8.

Implementation/consideration of risk significant operational experience feedback.

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

2PS3

Radiological Environmental Monitoring Program (REMP) and Radioactive Material

Control Program (71122.03)

.1

Inspection Planning

a.

Inspection Scope

The inspectors reviewed the most current Annual Radiological Environmental Operating

Report (for calendar year 2002) and licensee assessment results to verify that the

REMP was implemented as required by Technical Specifications and the Offsite Dose

Calculation Manual (ODCM). The inspectors reviewed the report for changes to the

ODCM with respect to environmental monitoring, commitments in terms of sampling

locations, monitoring and measurement frequencies, land use census, interlaboratory

comparison program, and analysis of data. The inspectors reviewed the Updated Final

Safety Analysis Report (UFSAR) for information regarding the environmental monitoring

Enclosure

25

program and meteorological monitoring instrumentation. The inspectors reviewed the

scope of the licensees audit program to verify that it met the requirements of

10 CFR 20.1101(c).

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

.2

Onsite Inspection

a.

Inspection Scope

The inspectors walked down 75 percent of the air sampling stations and approximately

23 percent of the thermoluminescence dosimeter (TLD) monitoring stations to determine

whether they were located as described in the ODCM and to assess the sampling

capability and material condition of the equipment.

The inspectors observed the collection and preparation of selected environmental

samples (e.g., ground and surface water, milk, vegetation, sediment, and soil) to verify

that environmental sampling was representative of the release pathways as specified in

the ODCM and that sampling techniques were conducted in accordance with licensee

procedures.

The inspectors reviewed the operation of the stations meteorological instruments,

including data readout and recording instrumentation at the tower and in the control

room, to verify that they were as described, operable, calibrated, and maintained in

accordance with guidance contained in the UFSAR, NRC Safety Guide 23, and licensee

procedures. The inspectors compared real-time data collected at the meteorological

tower, such as wind speed, wind direction, and differential temperature, to the time-

average data transmitted to the control room to verify data integrity.

The inspectors reviewed each event documented in the 2002 Annual Radiological

Environmental Operating Report which involved a missed sample, inoperable sampler,

lost TLD, or anomalous measurement for the cause and corrective actions, and

conducted a review of the licensees assessment of any positive sample results

(i.e., licensed radioactive material detected above the lower limits of detection (LLDs)).

The inspectors reviewed the associated radioactive effluent release data that was the

likely source of the released material identified by the REMP sample.

The inspectors reviewed significant changes, if any, made by the licensee to the ODCM

as the result of changes to the land census or sampler station modifications since the

last inspection. In particular, the inspectors reviewed technical justifications for the

recently changed sampling locations for two outer-ring TLD stations. The inspectors

assessed the licensees ODCM change evaluations to verify that the changes did not

adversely affect the licensees ability to monitor the impacts of radioactive effluent

releases on the environment.

Enclosure

26

The inspectors reviewed the calibration and maintenance records for all twelve air

samplers and focused on the air flow meter and particulate filter/charcoal cartridge

components of the samplers. Because the licensee did not conduct analyses of REMP

samples on-site, the inspectors were not able to review licensee calibration records for

environmental sample radiation measurement instrumentation (i.e., count room

equipment), or review quality control charts for count room instrumentation.

However, the inspectors reviewed the results of the REMP sample vendors quality

control program, including the vendors interlaboratory comparison program results, to

verify the adequacy of the vendors program and corrective actions taken for any

identified deficiencies. The inspectors reviewed the detection sensitivities utilized by the

REMP sample vendor for counting samples to verify that the samples met the

TS/ODCM required LLDs. The inspectors reviewed audits and technical evaluations the

licensee performed on the vendors program. The inspectors reviewed quality

assurance audit results of the program to determine whether the licensee met Technical

Specification and ODCM requirements.

These reviews represented six inspection samples.

b.

Findings

No findings of significance were identified.

.3

Unrestricted Release of Material from the Radiologically Controlled Area (RCA)

a.

Inspection Scope

The inspectors observed several locations where the licensee monitored potentially

contaminated material leaving the RCA, and inspected the methods used for control,

survey, and release from these areas. The inspectors observed the performance of

personnel surveying and releasing material for unrestricted use to verify that the work

was performed in accordance with plant procedures.

The inspectors assessed the radiation monitoring instrumentation utilized for the

unrestricted release of material from the RCA to verify that it was appropriate for the

radiation types present and was calibrated with the requisite radiation sources. The

inspectors reviewed the licensees criteria for the survey and release of potentially

contaminated material and verified that there was guidance on how to respond to

indications of the presence of licensed radioactive material. The inspectors reviewed

the licensees equipment to ensure the radiation detection sensitivities were consistent

with the NRC guidance contained in IE Circular 81-07 and IE Information Notice 85-92

for surface contamination and HPPOS-221 for volumetrically contaminated material.

The inspectors reviewed the licensees program to determine if it adequately identified

the potential for difficult-to-detect radionuclides (i.e., radionuclides that decay via

electron capture) and accounted for those radionuclides during routine unrestricted

release surveys. Finally, the inspectors reviewed the licensees procedures and records

to verify that the radiation detection instrumentation was used at its typical sensitivity

level based on appropriate counting parameters (i.e., counting times and background

radiation levels), and that the licensee had not established a release limit by altering

Enclosure

27

instrumentation typical sensitivities through such methods as raising the energy

discriminator level or locating the instrument in a high radiation background area.

These reviews represented two inspection samples.

b.

Findings

No findings of significance were identified.

.4

Identification and Resolution of Problems

a.

Inspection Scope

The inspectors reviewed the licensees self-assessments, audits, Licensee Event

Reports, and Special Reports, as available, related to the Radiological Environmental

Monitoring Program since the last inspection to determine if identified problems were

entered into the corrective action program for resolution. The inspectors also reviewed

the licensee's self-assessment program to determine if it was capable of identifying

repetitive deficiencies or significant individual deficiencies in problem identification and

resolution.

The inspectors also reviewed corrective action reports related to the REMP and

radioactive material control program since the previous inspection, interviewed staff, and

reviewed documents to determine if the following activities were being conducted in an

effective and timely manner commensurate with their importance to safety and risk:

1.

Initial problem identification, characterization, and tracking.

2.

Disposition of operability and reportability issues.

3.

Evaluation of safety significance, risk, and priority for resolution.

4.

Identification of repetitive problems.

5.

Identification of contributing causes.

6.

Identification and implementation of effective corrective actions.

7.

Resolution of Non-Cited Violations tracked in the corrective action system.

8.

Implementation and consideration of risk significant operational experience

feedback.

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

Enclosure

28

4.

OTHER ACTIVITIES (OA)

4OA1 Performance Indicator Verification (71151)

.1

Reactor Safety Performance Indicators

a.

Inspection Scope

The inspectors used definitions and guidance contained in Revision 2 of Nuclear Energy

Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, to

verify the accuracy of the data submitted for the following three performance indicators:

Unplanned Power Changes Per 7,000 Critical Hours

Reactor Coolant System (RCS) Specific Activity

RCS Leakage

The inspectors reviewed the data submitted by licensee personnel for October 2002

through September 2003 to verify that the Unplanned Power Changes per 7,000 Critical

Hours and Reactor Coolant System Leakage Performance Indicators were reported

accurately. The inspectors also reviewed samples of records regarding primary coolant

system leakage calculations, control room logs and monthly operating data reports.

The inspectors reviewed the licensees assessment of its performance indicator for RCS

specific activity by reviewing Chemistry Department records and selected isotopic

analyses (July 2002 through March 2003) to verify that the greatest Dose Equivalent

Iodine (DEI) value obtained during those months corresponded with the value reported

to the NRC. The inspectors also reviewed selected DEI calculations to verify that the

appropriate conversion factors were used in the assessment as required by Technical

Specifications. Additionally, on October 22, 2003, the inspectors observed a chemistry

technician obtain and analyze a reactor coolant sample for DEI to verify adherence with

licensee procedures for the collection and analysis of reactor coolant system samples.

Further, the inspectors reviewed condition reports regarding problems with performance

indicator data to verify that the issue was entered into the corrective action program with

the appropriate significance level. The inspectors also verified that planned corrective

actions were appropriate and implemented as scheduled.

b.

Findings

No findings of significance were identified.

.2

Radiation Protection Strategic Area

a.

Inspection Scope

The inspectors sampled the licensees submittals for performance indicators (PIs) and

periods listed below. The inspectors used PI definitions and guidance contained in

Revision 2 of Nuclear Energy Institute Document 99-02, Regulatory Assessment

Enclosure

29

Performance Indicator Guideline, to verify the accuracy of the PI data. The following PI

was reviewed:

RETS/ODCM Radiological Effluent Occurrence

Since no reportable occurrences were identified by the licensee for 3rd Quarter 2002

through 3rd Quarter 2003, the inspectors compared the licensees data and reviewed

corrective action documents generated during the time period to identify any potential

occurrences such as unmonitored, uncontrolled or improperly calculated effluent

releases that may have impacted offsite dose. Also, the inspectors evaluated the

licensees methods for determining offsite dose and selectively verified that liquid and

gaseous effluent release data and associated offsite dose calculations performed since

this indicator was last reviewed were accurate.

b.

Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152)

a.

Inspection Scope

On August 10, 2003, during scheduled quarterly surveillance testing, High Pressure

Safety Injection Pump Subcooling Valve CV-3070 failed to stroke open as required.

Consequently, High Pressure Safety Injection Pump P-66B was declared inoperable and

Technical Specification 3.5.2.B.1 action was entered which required the pump to be

restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The inspectors reviewed the apparent cause evaluation for Condition Report

CAP037030, Subcooling Valve CV-3070 Failed to Open During QO-5 Valve Test

Procedure, to verify that: (1) the problem was accurately identified; (2) the apparent

cause was adequately justified; (2) extent of condition and generic implications were

appropriately addressed; and (3) corrective actions were appropriately focused to

address the problem and implemented commensurate with the safety significance of the

issue.

b.

Findings

No findings of significance were identified. However, the inspectors noted one

weakness regarding the evaluation and resultant corrective actions.

Licensee personnel concluded that the apparent cause for CV-3070 to not open was a

flow control valve in the operating air system which had been installed backwards in

1995. Licensee personnel also concluded that human error was the cause of the flow

control valve being installed incorrectly. However, the evaluation did not identify that the

work order and work instructions utilized in 1995 during the maintenance activity to

disassemble and then rebuild the actuator to CV-3070 did not provide any guidance to

maintenance personnel regarding proper orientation for the flow control valve.

Enclosure

30

Consequently, there was no corrective action developed to revise the work instruction to

ensure adequate guidance was provided to the maintenance personnel during any

subsequent CV-3070 actuator maintenance activities. However, this issue was of minor

significance since maintenance on the valve actuators had not been performed since

the evaluation was completed. Therefore, the failure to develop a corrective action to

review and revise the work instructions had not resulted in any actual adverse

consequences.

.2

Routine Review of Identification and Resolution of Problems

a.

Inspection Scope

As discussed in previous sections of this report, the inspectors routinely reviewed issues

during baseline inspection activities and plant status reviews to verify that condition

reports were being generated and entered into the corrective action program with the

appropriate significance characterization. For select condition reports, the inspectors

also verified that identified corrective actions were appropriate, and had been

implemented or were scheduled to be implemented in a manner commensurate with the

significance of the identified problem.

b.

Findings

No findings of significance were identified.

4OA3 Event Follow-up (71153)

The inspectors reviewed two Licensee Event Reports to verify that the events were

accurately described, to determine if any violations of NRC requirements occurred, and

to assess the appropriateness of identified corrective actions.

.1

(Closed) Licensee Event Report (LER) 50-255/03-005: Emergency Diesel Generators

Start on Low Voltage Condition.

On August 14, 2003, with the plant operating at 100 percent power, an electrical power

grid disturbance occurred that momentarily lowered voltage on 2400 volt safety-related

Buses 1C and 1D which caused both Emergency Diesel Generators to start. However,

Buses 1C and 1D remained energized from offsite power throughout the event as

designed. Local grid conditions stabilized within 5 minutes and both Emergency Diesel

Generators were subsequently secured. The inspectors did not identify any issues of

significance. This LER is closed.

.2

(Closed) LER 03-004: Inoperable Train of Containment Cooling - Condition Prohibited

by Technical Specifications.

This issue was previously documented in NRC Integrated Inspection Report 05000255/2003006, Section 1R15, as a self-revealed finding of very low safety

significance (Green) with an associated Non-Cited Violation for exceeding the

completion time for required actions in Technical Specification 3.6.6, Containment

Enclosure

31

Cooling Systems. The inspectors did not identify any new information of significance.

This LER is closed.

4OA6 Meetings

.1

Exit Meeting

The inspectors presented the inspection results to Mr. D. J. Malone and other members

of licensee management on January 9, 2004. Licensee personnel acknowledged the

findings presented. The inspectors asked licensee personnel whether any materials

examined during the inspection should be considered proprietary. No proprietary

information was identified.

.2

Interim Exit Meetings

The following Interim Exit Meetings were conducted:

Radiation Protection (RETS/ODCM) inspection with Mr. R. Remus on

December 19, 2003. A telephonic re-exit was conducted with Messrs. J. Beer

and D. G. Malone on December 31, 2003, to discuss the establishment of the

URI related to the RGEM system (see Section 2PS1.2).

Radiation Protection (REMP and Radioactive Material Control) inspection with

Mr. M. Carlson on October 24, 2003.

Biennial Heat Sink inspection with Mr. D. Cooper on November 21, 2003.

Emergency Preparedness inspection with Mr. T. Blake on December 22, 2003.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Attachment

1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Cooper, Senior Vice President Group Operations

D. Malone, Site Vice President

P. Harden, Site Director

R. Remus, Plant Manager

M. Carlson, Engineering Director

T. Blake, Emergency Preparedness Supervisor

L. Lahti, Licensing Manager

G. Hettel, Manager, Maintenance and Construction

G. Packard, Operations Manager

D. Williams, Chemistry and Radiation Safety Manager

Nuclear Regulatory Commission

D. Hood, Project Manager, NRR

S. Klementowicz, NRR, Public Radiation Safety Cornerstone Lead Health Physicist

Attachment

2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000255/2003008-01

NCV

Failure of Containment Spray Pump P-54C Inboard Motor

Bearing

05000255/2003008-02

NCV

Failure of High Pressure Safety Injection Pump P-66B

Subcooling Valve CV-3070 to Open

05000255/2003008-03

URI

Emergency Action Level and Emergency Plan Changes05000255/2003008-04

URI

RGEM System Configuration May Not Obtain a

Representative Gaseous Effluent Sample

Closed

05000255/2003008-01

NCV

Failure of Containment Spray Pump P-54C Inboard Motor

Bearing

05000255/2003008-02

NCV

Failure of High Pressure Safety Injection Pump P-66B

Subcooling Valve CV-3070 to Open

50-255/03-004

LER

Inoperable Train of Containment Cooling - Condition

Prohibited by Technical Specifications

50-255/03-005

LER

Emergency Diesel Generators Start on Low Voltage

Condition

Attachment

3

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety but rather that

selected sections of portions of the documents ere evaluated as part of the overall inspection

effort. Inclusion of a documents on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

1R01

Adverse Weather Protection

Off-Normal Procedure-12; Acts of Nature; Revision 18 Murray and Trettel Storm

Warning, November 12, 2003

Alarm Response Procedure-7; Auxiliary Systems Scheme EK-11 (C-13); Windows 24,

29, 32, 38 and 44; Revision 65

System Operating Procedure-16, Attachment 10; Frazil Ice - Information / Prevention /

Mitigation; Revision 31

System Operating Procedure-23, Attachment 8; Cold weather Checklist; Revision 17

System Operating Procedure-23, Attachment 9; Cold weather Checklist-Electrical;

Revision 17

Condition Reports Reviewed to Assess Significance Characterization of Identified Problems

CAP038280; Evaluate Whether MV-ES3243, SIRW Tank Level Transmitter Isolation,

Cold Weather Protection is Adequate

CAP038315; Work Week 2344: Cold Weather Checklist Not Completed in a Timely

Manner

Condition Reports Reviewed To Assess Corrective Actions

CAP033427; Received ED-1129 Service Water Bay Low Level Alarm

CAP038281; LT-0331, SIRW Tank Level Transmitter, Not Checked in SOP-23,

Attachment 8, Cold Weather Checklist

CAP038000; Intake Structure Ventilation Operation Contrary to Updated Final Safety

Analysis Report Described Operation

1R04

Equipment Alignment

Plant Procedures and Miscellaneous Documents

SOP-19; Instrument and Service Air System Checklist; Revision 29

SOP-24 Ventilation and Air Conditioning System; Revision 37

WO24323843; Clean All Blockages on P-66A Bearing Housing Caps

M218; Piping and Instrument Diagram for the Control Room Heating, Ventilation and Air

Conditioning

Attachment

4

Condition Reports Reviewed to Assess Corrective Actions

CAP037656; Potential Loss of High Pressure Safety Injection Pump Bearing Housing

Vent Path

CAP037659; P-67A Low Pressure Safety Injection Pump Bearing Housing Vent

Inspection

Condition Reports Reviewed to Assess Significance Characterization of Identified Problems

CAP038709; East Mechanical Equipment Room Deficiencies Noted by NRC

1R05

Fire Protection

Plant Procedures

ONP25.2; Off-Normal Procedure - Fire Which Threatens Safety-Related Equipment Fire

Areas 12, 10, 30, 31; Revision 12

FPSP-SI-1; Data Sheet for Alarm Bells and Ionization Smoke Detectors for Fire Areas

12, 10, 30, 31, Revision 3

FPSP-RP-11; Fire Barrier Penetration Seal/Conduit Seal Inspection Form for Fire Areas

12, 10 30, 31; Revision 5

FPSP-RM-5; Palisades Fire Damper Sheet for Fire Areas 12; Revision 2

FPSP-SO-2; Safety-Related Fire Door Data Sheet for Fire Areas 12, 10, 30, 31;

Revision 0

FPSP-WP-1; Safety-Related Fire Door Data Sheet Fire Areas 12, 10, 30, 31; Revision 1

Condition Reports Reviewed to Assess Corrective Actions

CAP029787; Containment Fire Detection does Not Meet Code of Record

CAP029676; Technical Inaccuracies In the Fire protection Program Report

Condition Reports Reviewed to Assess Significance Characterization of Identified Problems

CAP038727; Emergency Lighting Unit ELU-67 is Directed Slightly Upward (Above

Horizontal)

CAP039240; "Fire Detectors Not Installed as Outlined in the Modification Package"

Miscellaneous Documents

FSAR; Section 9.6, Fire Protection; Revision 23

FSAR; Section 9, Fire Detection Instrumentation; Revision 24

Fire Hazards Analysis Report; Revision 4

Palisades Plant Post Fire Safe Shut-down Summary Report; September 1, 1978

Fire Protection Safety Evaluation Report by the Office of NRR in the Matter of

Consumers Power Company Palisades Plant Docket 50-255; September 1, 1978

Attachment

5

1R06

Flood Protection

Final Safety Analysis Report; Table 5.4-1; Safety Related Equipment That Requires

Protection From Flooding Due to Failures of Nonclass 1 Systems; Revision 21

Final Safety Analysis Report; Section 5.4.2; Flooding and Wetting From Plant Sources;

Revision 24

Condition Reports Reviewed to Assess Corrective Actions

CAP035933; Expansion Joint Inspection Fails to Identify Known Deficiency

CAP034759; Water Tight Door #58 Failed Inspection (Doghouse Door)

CAP034720; Water Tight Door #51 Failed Inspection Criteria

Work Orders

WO24321400; Door 58, East Engineered Safeguards Doghouse Door

WO24321399; Door 51, Engineering Safeguards Entrance

1R07

Heat Sink Performance

CH 1.11; MIC Control Program Inspection Report - VC-10; dated April 18, 2001,

October 24, 2002, and February 24, 2003

CH 1.11; MIC Control Program Inspection Report - VC-10 Service Water Piping; dated

October 24, 2002

CH 1.11; MIC Control Program Inspection Report - VC-11; dated October 1, 2001, and

July 29, 2003

CH 1.11; MIC Control Program Inspection Report - VC-11 Service Water Piping; dated

December 4, 2001

CH 1.11; MIC Control Program Inspection Report - VC-11 Service Water Valve

MV-SW281; dated December 4, 2001

CH 1.11; MIC Control Program Inspection Report - VHX-2; dated April 12, 2001

CH 1.11; MIC Control Program Inspection Report - VHX-3; dated March 30, 2003

CH 1.11; Biofouling and MIC Control Program; Revision 1

DBD-1.06; Control Room HVAC System; Revision 7

DBD-2.08; Containment Air Coolers; Revision 2

EA-D-PAL-93-272E-02; Control Room HVAC Refrigeration Unit Performance at

85 Degrees Fahrenheit Entering Service Water Temperature; Revision 0

EA-LOCA-2001-01; Containment Response to a LOCA Using CONTEMPT-LT/28;

Revision 1

EA-LTP-99-01; Methodology for Capacity Testing and Analysis of the Control Room

HVAC System; Revision 0

EA-VC10/11-2000; Uncertainty Analysis for the Control Room HVAC System

Surveillance Procedure; Revision 1

EM-09-15; Raw Water Corrosion Program; Revision 4

EM-09-16; Heat Exchanger Condition Assessment Program; Revision 3

EM-09-16; Heat Exchanger Visual Testing Checklist - VC-11; completed July 29, 2003

RO-216; Service Water Flow Verification; Revision 2; completed April 4, 2003

RT-202, Basis Document; Control Room Heat Removal Capability; Revision 1

Attachment

6

RT-202; Control Room Heat Removal Capability (Train A); Revision 2; completed

August 19, 2003

RT-202; Control Room Heat Removal Capability (Train B); Revision 2; completed

August 19, 2003

Palisades 2001 Refuel Outage Report by Underwater Construction Corporation; dated

May 15, 2001

Palisades 2003 Refuel Outage Report by Underwater Construction Corporation; dated

April 5, 2003

Raw Water Corrosion Program Report Operational Cycle 15 and 2001 Refueling Outage

Report; dated August 13, 2001

Raw Water Corrosion Program Report Operational Cycle 16 and 2003 Refueling Outage

Report; dated July 22, 2003

NMC Letter to NRC; Resolution of Generic Letter 96-06 Waterhammer Issues; dated

February 28, 2003

NMC Letter to NRC; Resolution of Generic Letter 96-06 Two-Phase Flow Issues; dated

July 24, 2003

M123; Heating & Ventilation Reactor Containment Building Coolers-Unit V-3; Revision 0

M124; Heating & Ventilation Reactor Containment Building Coolers-Unit V-1 and

Unit V-2; Revision 6

M218; HTG. Vent. & Air Cond. Control Room; Revision 9

VEN-M-60A, Sheet 1; Type R Coil 36 Tube Face, 4'-11 1/2 NTL, 12 Row, 4 Pass;

Revision 1

VEN-M-60A, Sheet 2; Type R Coil 36 Tube Face, 4'-11 1/2 NTL, 12 Row, 4 Pass;

Revision 0

VEN-M-60A, Sheet 7; Containment Air Coolers VHX-1, VHX-2, and VHX-3 Cooling Coil

Tube Map; Revision 0

C-PAL-00-3205; Apparent Tube Blockage on Containment Air Cooler Coil VHX-3; dated

October 26, 2000

C-PAL-00-3664; Thermography Scanning Finds More Containment Air Cooler Tubing

Plugged; dated December 20, 2000

1R11

Licensed Operator Requalification

Simulator Performance Exercise - 42; Licensed Operator Requalification; Course

N00320; Revision 0

Simulator Performance Evaluation; Crew 1; December 3, 2003

1R13

Maintenance Risk Assessments and Emergent Work Evaluation

Miscellaneous Documents

Operators Risk Reports; September 29 through October 3, November 10-13 and 18-19,

and December 7-10

Daily Maintenance Work Schedules; September 29 through October 3, November 10-13

and 18-19, and December 7-10

Operations Log entries; September 29 through October 3, November 10-13 and 18-19,

and December 7-10

Attachment

7

1R14

Non-Routine Plant Evolutions and Events

Plant Procedures

Alarm Response Procedure - 1; Turbine Condenser and Feedwater Scheme EK-01;

Window 60; Feedwater Pumps Lo Suction; Revision 52

Alarm Response Procedure - 1;Turbine Condenser and Feedwater Scheme EK-01;

Window 72; Moisture Separator Drain Tank Hi-Lo Level; Revision 52

Off Normal Procedure - 3; Loss of Main Feedwater; Revision 19

Off Normal Procedure - 26; Rapid Power Reduction; Revision 1

System Operation Procedure - 8, Attachment 2; Main Turbine and Generating Systems,

System Testing; Revision 65

Condition Reports Reviewed to Assess Significance Characterization for Identified Problems

CAP038519; Unanticipated Trip of A Heater Drain Pump During Turbine Valve Testing

CAP038508; Unexpected Alarm EK-0172 Moisture Separator Drain Tank Hi-Lo Level

CAP038512; E-9A MSR Reheat Stop Valve CV-0537 Failed to Close During Turbine

Valve Testing

CAP038514; Heater Drain Pump P-10A Discharge Check Valve Stuck Open

CAP038511; E-9B MSR Intercept Valve CV-0535 Failed to Reopen During Turbine

Valve Testing

CAP038509; Received Alarm EK-0105, Turbine High Vibration, Unexpectedly

CAP038513; Plant Challenges Due to Closure of MSR E-9A Reheat Sop Valve CV-0537

1R17

Permanent Plant Modifications

Engineering Assistance Requests

EAR-2000-0345; Seismic Qualification Utility Group Outlier Resolution for Safety

Injection Refueling Water Tank, T-58; June 18, 2003

EAR-2000-017; Alternate Safe-Shutdown Pathway for Cold-Shutdown Using Service

Water; May 30, 2003

EAR-2002-0293; Piping Modifications to Charging Pump Suction Piping to Facilitate

Crosstie Via Fire Hose from the Spent Fuel Pool Piping for Alternate Safe-Shutdown

Pathway for Hot-Shutdown; May 9, 2003

Plant Procedures

PCSO-5; Special Operating Procedure, Alternate Source for Charging to PCS;

Revision 0

COP-27; Chemistry Operating Procedure, Spent Fuel Pool System Chemistry;

Revision 17

PPAC X-OPSADM02; Preventive Maintenance Work Order - Alternate Safe Shutdown

Pathway Inspect

Attachment

8

Condition Reports Reviewed to Assess Significance Characterization of Identified Problems

CAP038236; Spent Fuel Pool Boron Administrative Limit Not Timely Incorporated in

Chemistry Procedures

CAP036336; Closeout Item EAR-2000-0345 - SFP Boron Concentration During

Maintenance

CAP036337; Closeout Items EAR-2000-0345 - Q-List Interpretations

CAP038956; Inadequate Documentation of Justification for Design Change

Piping and Instrument Diagrams

M-202; Sheet 1B; Chemical and Volume Control System; Revision 50

M-208; Sheet 1A; Service Water System; Revision 52

M-221; Sheet 2; Spent Fuel Pool Cooling System; Revision 50

1R19

Post Maintenance Testing

Work Orders

WO24322197; Service Water Pump P-7C; October 29, 2003

WO24323161; EDG 1-2 K-6B Starting Air Pressure Control; September 29, 2003

WO24321782; EDG Air Starting Motor (ASM-2B); September 29, 2003

WO24213350; Replace SV-1452 (K-6B/Fuel Oil); September 29, 2003

WO24323928; Wire 1B on Terminal Block TC Pinched; September 30, 2003

WO24112283; EDG 1-2 to Bus 1D; September 30, 2003

WO24213073; EDG 1-2 Air Start Motor ASM-2A Isolation; September 29, 2003

WO24113680 Attachment B; functional Test of Breaker 152-111

Plant Procedures

SWS-M-12; Service Water Pumps P-7A, P-7B and P-7C Repack; Revision 1

MO7A2; Emergency Diesel Generator 1-2; Revision 56

SOP-22; Emergency Diesel Generators; Revision 35

QO-20B; Inservice Test: Low Pressure Safety Injection Pumps; Revision 12

Miscellaneous Documents

Final Safety Analysis Report, Section 6.1; Safety Injection System; Revision 23

Technical Specifications 3.5.2; Emergency Core Cooling System

Technical Specifications Bases 3.5.2; Emergency Core Cooling System

Condition Reports Reviewed to Assess Significance Characterization of Identified Problems

CAP038299; Siemens Breaker S/N R-300511A-8 Failed to Close During Testing

CAP038302; Insufficient Cooling for Packing on Service Water P-7C After Repack

CAP038317; Service Water Pump Repacked With Larger Than Required Packing

CAP038320; Maintenance Violated the Procedural Step Requirement in Step 5.3.2 in

SWS-M-12

Attachment

9

1R22

Surveillance Testing

Completed Surveillance Test Procedures

QO-1; Safety Injection System; Revision 49

MO-33; Control Room Ventilation Emergency Operation; Revision 9

QO-14; Inservice Test Procedure - Service Water Pumps; Revision 21

Miscellaneous Documents

FSAR 7.3; Engineered Safeguards Controls; Revision 23

Reg Guide 1.52; Design, Inspection and Testing Criteria for Air Filtration and Adsorption

Units of Post-Accident ESF Atmosphere Cleanup System in Light Water-Cooled

Nuclear Power Plants; Revision 3

NUREG/CR-496; Control Room Habitability Survey of Licensed Commercial Nuclear

Power Generating Stations

Condition Reports Reviewed to Assess Significance Characterization of Identified Problems

CAP038044; Unexpected Containment Air Cooler Service Water System Leak Alarm

Received During QO-1 SIS Testing

CAP038110; Missed Sign Off for AC&O Sheet in Body of Procedure

Condition Reports Reviewed to Assess Corrective Actions

CAP037153; Palisades Control Room Habitability Not in Complete Conformance With

NRC Guidance

1REP Equipment Availability and Functional Capability

Maintenance Effectiveness

Plant Procedures

WI-ESS-O-02; Containment Spray Pump/Motor Oil Sample and Change; Revision 0

ESS-E-36; Component Cooling and Containment Spray Motor Maintenance; Revision 6

VTD-0322-0005; Louis-Allis Co. Instruction Manual for Large Motors

EGAD-EP-10; Maintenance Rule Scoping Document for 2400V AC Power and 4160V

AC Power Systems; Revision 2

Miscellaneous Documents

Containment Spray Pump Motor Oil Change Out History

Daily Checklists for Painting Floors/Walls/Equipment

Palisades Maintenance Rule Performance Indicators for 2400V AC Power and 4160V

AC Power Systems

Palisades Maintenance Rule Performance Monitoring Results for 2400V AC Power and

4160V AC Power Systems

Attachment

10

Health and Status Report for 2400V AC Power and 4160V AC Power Systems

FSAR; Chapter 8, Electrical Systems; Revision 23

Work Orders

PPAC X-OPS310; EEQ Required P-54A, B, C Motor Oil Change and Containment

Spray Pump Motor Oil Change P-54A, B, C

WO24320008; Miscellaneous Mechanical System Work

Condition Reports Reviewed to Assess Maintenance Rule Evaluations and Corrective Actions

CAP037180; Smoke Observed Coming From Containment Spray Pump P-54C Inboard

Motor Bearing

CAP034584; Undervoltage Relays on F and G Busses Failed to Reset

CAP031363; Breaker 152-306 Failed to Close From Control Room

Biennial Assessment of Maintenance Rule Periodic Evaluations

Miscellaneous Documents

EGAD-EP-10, Attachment 2; Maintenance Rule Scoping Document For Concentrated

Boric Acid System, Control Room HVAC System, High Pressure Air System and the

Fire Protection System; Revision 2

Health and Status Reports for Concentrated Boric Acid System, Control Room HVAC

System, High Pressure Air System and the Fire Protection System

Palisades Plant - Maintenance Rule Periodic Refueling Assessment; August 21, 2000 to

July 31, 2002

Condition Reports Reviewed to Assess Maintenance Rule Evaluations and Corrective Actions

CAP036655; Received EK-0726 Boric Acid Pumps P-56A and P-56B Overload

Unexpectedly

Condition Reports Reviewed to Assess Corrective Actions

CAP036114; Boric Acid Availability Does Not Meet Maintenance Rule Criteria

CAP03583; Maintenance Rule Performance Criteria Exceeded for Control Room HVAC

System

CAP015712; Unusual Noise and Smoke Coming from VC-11, Control Room HVAC

condensing unit

CAP031618; Door 16 Mechanical Equipment Room Results in TS3.7.10 A/B Entry

CAP032834; Inoperable B Train Control Room Ventilation Cooling

CAP034899; Control Room Cooling Train (VC-11) Inoperable

CAP031633; High Pressure Air Compressor C-6A Inoperable Due to Failed Oil Level

Switch

CAP037303; Oil Cap Unsecure On High Pressure Air Compressor C-6C

CPAL990984; Maintenance Rule Category (a)(1) Performance Improvement of the High

Pressure Air System

CAP031907; Evaluate Returning P-9B to Maintenance Rule Category (a)(2)

Attachment

11

CAP029995; Fire Pump P-9B Unavailability Exceeds Maintenance Rule Performance

Indicators

CPAL0200457; Fire Protection Maintenance Preventable Functional Failure of Electric

Fire Pump P-9A Exceeds Performance Criteria

CPAL0200497; Electric Fire Pump P-9A Fails to Meet Maintenance rule Availability

Requirements

CPAL0200059; Fire Pump P-9A Tripped After Running For Approximately 3 Minutes

CAP032600; Fire Protection System Exceeds Maintenance Rule Reliability Performance

Criteria

CAP033278; Compressor Related System Performance Issues

CAP032927; Weakness in Timely Resolution of Maintenance Rule (a)(1) Issues

CAP033280; Maintenance Rule Availability Performance Criteria Limitations in the

Scheduling Process

Operability Evaluations

Plant Procedures

EM-18-02; Interim Operability Criteria Evaluation For Palisades Plant Safety-Related

Piping Systems; Revision 1

Condition Reports Associated with Operabililty Determinations

CAP038087; Change the Source CAP for the Operable But Degraded Piping Feeding

CVCS [Chemical Volume Control System]

CAP032550; Steam Generator Low Pressure Bypass Not Calibrated in Appropriate

Direction

CAP037030; Subcooling CV-3070 Failed to Open During QO-5 Valve Test Procedure

Miscellaneous Documents

Final Safety Analysis Report; Section 5.10.1.4; Interim Operability Criteria; Revision 21

Technical Specifications 3.3.3; Engineered Safety Features Instrumentation

Final Safety Analysis Report; Section 7.2.3.8; Low Steam Generator Pressure;

Revision 23

Condition Reports Reviewed to Assess Corrective Actions

CAP030037; Incorrect Operability Determinations

Operator Workarounds

Plant Procedures

Admin Proc No 4.12; Operator Work-Around Program; Revision 1

Attachment

12

Miscellaneous Documents

Palisades Operator Workarounds List; as of October 29, 2003

Operations Concerns List; as of October 29, 2003

Control Room Deficiencies List; as of October 29, 2003

Palisades Operations Concerns List; as of October 29, 2003

Aggregate Assessment Factor; as of June 30, July 24, August 15, September 19 and

October 27, 2003

Temporary Plant Modifications

Plant Procedures

SOP-15, Attachment 11; Alternate Water Supply to Clean Traveling Screens;

Revision 32

Modification Documents

EDC-TM-2000-024-03; Engineering Design Change for TM-2000-024; 50.59 Screen;

November 13, 2003

TM-2000-024; Temporary Modification, Alternate Supply of Water to Traveling Screens;

November 11, 2003

1EP4

Emergency Action Level and Emergency Plan Changes

Palisades Nuclear Plant Site Emergency Plan; Revisions 5, 6, 7, and 8

1EP6

Emergency Preparedness Drill Evaluation

Plant Procedures

EI-3, Attachment 1; Palisades Event Notification Form; Revision 19

EI-1; Emergency Classifications and Actions; Revision 42

EI-3; Communications and Notifications; Revision 19

Condition Reports Reviewed to Assess Significance Characterization of Identified Problems

CAP039186; Investigate Potential Missed Drill / Exercise Performance Opportunity

2OS3 Radiation Monitoring Instrumentation and Protective Equipment

SurvivAir SCBA Maintenance Record File for OCR-42 (including cylinder hydrostatic test

data); dated through August 6, 2003

SurvivAir SCBA Maintenance Record File for RPO-11 (including cylinder hydrostatic test

data); dated through August 4, 2003

SurvivAir SCBA Maintenance Record File for T625-47 (including cylinder hydrostatic test

data); dated through August 6, 2003

Attachment

13

HP 7.5; Self-Contained Breathing Apparatus (SCBA) SurvivAir Mark-2 Model 9842;

Revision 4

HP 7.6; Inspection and Testing of SurvivAir (SCBA) Breathing Air Cylinders ; Revision 4

2PS1

Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

2001 Annual Radioactive Effluent and Waste Disposal Report; dated March 26, 2002

2002 Annual Radioactive Effluent and Waste Disposal Report; dated March 24, 2003

Calibration File for High Purity Germanium Detector #1 (S/N 6983983); dated January 9,

1999

Calibration File for High Purity Germanium Detector #2 (S/N 1924); dated May 13, 1999

Calibration File for High Purity Germanium Detector #3 (S/N 1221); dated January 9,

1999

Palisades Final Safety Analysis Report (FSAR), Chapter 11; Radioactive Waste

Management and Radiation Protection; Revision 24

Quarterly Liquid and Gaseous Release Calculations (LADTAP and GASPAR Results)

for 3rd Quarter 2001, 2nd and 4th Quarter 2002, and 1st through 3rd Quarter 2003;

dated October 3, 2001, July 2, 2002, and January 9, April 5, July 3, September 26,

2003

Results of Radiochemistry Cross Check Program (Analytics), Consumers Power

Company, Palisades Nuclear Plant, 2nd Quarter 2003; dated November 10, 2003

Results of Radiochemistry Cross Check Program (Analytics), Consumers Power

Company, Palisades Nuclear Plant, 3rd Quarter 2003; dated November 10, 2003

Special Report of Inoperability of One Channel of Stack Gas Effluent System; dated

September 4, 2003

Special Report of Inoperability of One Channel of Stack Gas Effluent System - Hi Range

Noble Gas Monitor RIA-2327; dated September 20, 2002

ANSI N13.1-1969; Guide to Sampling Airborne Radioactive Materials in Nuclear

Facilities; dated February 19, 1969

CAP 033600/ACE 002935; Higher than Expected Noble Gas Activity During Breach of

Waste Gas System; dated February 26, 2003

CAP 036988/MRE 000158; Radioactive Gas Effluent Monitoring System Tripped; dated

August 6 and 11, 2003

CAP 037027; Counting Geometry Unavailable; dated August 10, 2003

CAP 037574; Clarification/Enhancement Needed for ODCM Compensatory Measures;

dated September 15, 2003

CAP 039097; Question Concerning Plant Stack Sample Line; dated December 17, 2003

CAP 039128; Evaluate Sampling/Handling of the Weekly Plant Stack Effluent Sample

Media; dated December 18, 2003 [NRC-Identified Issue]

CH 4.39; Gamma Ray Spectroscopy System; Revision 14

CE 005907; I-131 Release During 2003 Re-Fueling Outage Higher Than 2001

Re-Fueling Outage; dated June 9, 2003

DWR-10; Stack Effluent Sampling, Calculations, and Records; Revision 22

Gaseous Release Batch 03-052ST; Week 52 of CY2003 Stack Release Calculations;

dated December 17, 2003

Gaseous Release Batch 03-052-G; Waste Gas Decay Tank T-101A Release

Calculations; dated December 18, 2003

Gilbert/Commonwealth System Design No. 771; Post-Accident Monitoring - Palisades

Plant, Radioactive Gaseous Effluent Monitoring; dated September 8, 1982

Attachment

14

HP 6.4; Radioactive Liquid Calculation and Release Authorization; Revision 23

HP 6.5; Sampling Waste Gas Decay Tank; Revision 12

HP 6.6; Evaluation and Release of Waste Gas Decay Tank; Revision 16

Liquid Release Batch 02-024-R; T-90 Tank Release; dated October 21, 2002

Liquid Release Batch 03-001-R; T-91 Tank Release; dated January 14, 2003

Liquid Release Batch 03-011-R; T-91 Tank Release; dated April 17, 2003

Nuclear Oversight Observation Report No. 2003-001-8-013; Radiological Environmental

Monitoring Program: Process Monitor Function Checks, Milk Sample Collection, Waste

Gas Decay Tank, and Stack Gas Analysis; dated March 18, 2003

Nuclear Oversight Observation Report No. 2003-001-8-067; Review of the Radiological

Environmental Monitoring Program and Radiological Environmental Technical

Specifications; dated April 23, 2003

ODCM; Palisades Nuclear Plant Offsite Dose Calculation Manual; Revisions 17 and 18

RR-9B; Radwaste Discharge Monitor (RIA-1049) Calibration; dated July 28, 2003

RR-84A; Radioactive Gaseous Iodine/Part Effluent Monitor RIA-2325 Calibration; dated

August 6, 2002

RR-84B; Radioactive Noble Gas Effluent Monitor RIA-2326 Calibration; dated

August 19, 2002

RR-84C; High Range Noble Gas Effluent Monitor (RIA-2327) Calibration; dated

December 10, 2002

Self-Assessment Report I03-33; Radiological Effluent Monitoring - Pre NRC

Assessment; dated October 21, 2003

2PS3

Radiological Environmental Monitoring and Radioactive Material Control Programs

Environmental Department Meteorological Equipment Temperature / Delta-T Calibration

Form, T/TD-1 (60M); dated September 10, 2003

Environmental Department Meteorological Equipment Wind Speed Calibration Form,

WS-1 (10A); dated September 10, 2003

Environmental Department Meteorological Equipment Wind Direction Calibration Form,

WD-1 (10A); dated September 10, 2003

Environmental Department Meteorological Equipment Wind Speed Calibration Form,

WS-1 (10B); dated September 8, 2003

Environmental Department Meteorological Equipment Wind Direction Calibration Form,

WD-1 (10B); dated September 8, 2003

Environmental Department Meteorological Equipment Wind Speed Calibration Form,

WS-1 (60M); dated September 10, 2003

Environmental Department Meteorological Equipment Wind Direction Calibration Form,

WD-1 (60M); dated September 10, 2003

Palisades Nuclear Plant 2002 Annual Radiological Environmental Operating Report;

dated May 12, 2003

Palisades Nuclear Plant Offsite Dose Calculation Manual; Revision 17

Palisades Nuclear Plant Offsite Dose Calculation Manual, Appendix A, Relocated

Technical Specifications per NRC Generic Letter 89-01 (TAC No. 75060); Revision 10

Palisades Part 61 Isotopic Analysis Results Evaluated for Hard-to-Detect Nuclides;

dated November 13, 2002

Palisades Personnel Contamination Monitor (PCM-2) Commissioning Study; dated

February 17, 2003

Palisades Personnel Contamination Monitor (PCM-2) Sum Zone Setup and Operation;

Attachment

15

dated March 6, 2003

Radiological Environmental Monitoring Program - Pre NRC Assessment; dated

October 21, 2003

AP 7.15; Contamination Control; Revision 9

EA-JBB-99-001; Plant Radionuclide Mixture and Calibration Sources; dated

March 10, 1999

Form 116; Gas Meter Test and Repair (for Air Sampling Stations 1 - 12); dated

November 22, 2002 through September 19, 2003

HP 9.80; Operation and Calibration of the SAM9; Revision 1

HP 10.1; Radiological Environmental Monitoring Program Surveillance; Revision 8

MM-121; Meteorological Monitoring Project Plan; dated June 8, 1998

Nuclear Oversight Observation Report No. 2003-001-8-013; Radiological Environmental

Monitoring Program: Process Monitor Function Checks, Milk Sample Collection, Waste

Gas Decay Tank, and Stack Gas Analysis; dated March 18, 2003

Nuclear Oversight Observation Report No. 2003-001-8-067; Review of the Radiological

Environmental Monitoring Program and Radiological Environmental Technical

Specifications; dated April 23, 2003

SR-2001-341; Nuclear Utilities Procurement Issues Committee (NUPIC) Joint Quality

Assurance Program Audit Report (of Environmental, Incorporated); dated

July 27, 2001

Updated/Final Safety Analysis Report Chapter 2; Section 2.5.2, Meteorological

Program History; Revision 22

WI-RSD-H-010; Release of Items; Revision 6

4OA1 Performance Indicator Verification

DWO-1, Attachment 8; Primary Coolant System Inventory Form; October 2002 through

September 2003

Licensee Report of Monthly Operating Data; Palisades Nuclear Plant; October 2002

through September 2003

NEI 99-02; Regulatory Assessment Performance Indicator Guideline; Revision 2

Chemistry Department Analyses Database for DEI-131 versus Reactor Power; dated

July 1, 2002 through June 30, 2003

COP-1; Primary Coolant System Chemistry, Attachment 19; Revision 52

DWC-2; PCS Radiochemistry Analysis; Revision 18

NRC Indicator RETS/ODCM Radiological Effluent Occurrence (PR-01); dated 3rd

Quarter 2002, January 9, April 5, July 3, and September 26, 2003

Condition Reports Reviewed to Assess Significance Characterization of Problems

CAP038667; NRC PI Database Not Corrected With Revised Data

Condition Reports Reviewed to Assess Corrective Actions

CAP031806; Incorrect Data Reported on May 2002 NRC Performance Indicator BI-02

4OA2 Identification and Resolution of Problems

ACE003132; Apparent Cause Evaluation; Subcooling Valve CV-3070 Failed to Open

During QO-5 Valve Test Procedure

Attachment

16

WO24412938; Work Order, High Pressure Safety Injection P-66B Subcooling;

July 11, 1995

ESS-M-40; Permanent Maintenance Procedure; Maintenance of Miller Operators for

High Pressure Safety Injection Subcooling Valves CV-3070 and CV-3071

4OA3 Event Follow-up

CAP038019, Re-assess Timing of CRS Fan V-4A Inoperability with Regard to

Reportability

Attachment

17

LIST OF ACRONYMS USED

AA

Access Authorization

ARM

Area Radiation Monitor

CAM

Continuous Air Monitor

CAP

Corrective Action Program

CFR

Code of Federal Regulations

CR

Condition Report

DEI

Dose Equivalent Iodine

DRP

Division of Reactor Projects

DRS

Division of Reactor Safety

EAL

Emergency Action Level

EAR

Engineering Assistance Request

LER

Licensee Event Report

LLD

Lower Limit of Detection

NCV

Non-Cited Violation

NMC

Nuclear Management Company

NRC

Nuclear Regulatory Commission

ODCM

Offsite Dose Calculation Manual

RCA

Radiologically Controlled Area

RCS

Reactor Coolant System

REMP

Radiological Environmental Monitoring Program

RETS

Radiological Effluent Technical Specifications

RGEM

Radiological Gaseous Effluent Monitoring

RPS

Reactor Protection System

SCBA

Self-Contained Breathing Apparatus

SDP

Significance Determination Process

SM&CS

System Maintenance and Construction Services

SQUG

Seismic Qualification Utility Group

TLD

Thermoluminescent Dosimeter

UFSAR

Updated Final Safety Analysis Report

URI

Unresolved Item