IR 05000461/1986005
| ML20214T571 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/28/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214T560 | List: |
| References | |
| 50-461-86-05, 50-461-86-5, NUDOCS 8612080633 | |
| Download: ML20214T571 (39) | |
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SALP 6 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-461/86005 Inspection-Report No.
Illinois Power Company Name of Licensee Clinton Power Station
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l Name of Facility
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September 1, 1985 - August 31, 1986 Assessment Period
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SALP 6 CLINTON POWER STATION SUMMARY OF RESULTS Overall, the licensee's performance was found to be acceptable. The licensee was found to have a high level of performance in the Preoperational Testing assessment area. The areas of Quality Assurance and Administrative Controls Affecting Quality, and Maintenance were found to need increased licensee management attention due to multiple weaknesses identified in controlling the turnover of systems from construction to testing and operations, following procedures, identifying and correcting problems, and in the area of maintenance of equipment.
All other assessment areas were found to be adequate and represented a licensee management team that was sufficiently staffed and appropriately involved and concerned with nuclear safety.
Increased management attention will be required as Clinton moves from construction and preoperational testing to low power testing and eventual full power operation. Management involvement in assuring safe operation must continue to be present throughout the implementation of the operational program.
Rating Last Rating This Functional Area Period Period A.
Construction #
NR
B.
Quality Programs and
3 Administrative Controls Affecting Quality C.
Preoperational Testing
1 D.
Maintenance NR
E.
Radiological Controls
2 F.
Fire Protection NR
G.
Security
2 H.
Operational Readiness
2 1.
J.
Licensing Activities
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- Construction during this assessment period, includes the functional areas of Containment and Other Safety-Related Structures (1)*, Piping Systems and Supports (1), Support Systems (2), Instrumentation and Control Systems (2),
and Overinspection (2). The licensee was not generally rated in construction during the last rating period.
- Numbers in ( ) denote last assessment ratings.
NR - Not rated because of insufficient activity in the area during the assessment period.
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IV. ' PERFORMANCE ANALYSIS--
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A.
. Construction 1.
Analysis Construction work at the Clinton Power Station was essentially completed. prior to this SALP period; therefore, inspection activities were limited. -This section is a consolidation of several areas that were addressed separately in previous SALP reports.. Examination of construction was based on the results
.~of 15 inspections by region based inspectors. Areas examined included:
(1) geotechnical records; (2) as-built walkdowns and selected review of records of the residual heat removal
and low pressure core spray systems; (3) verification of overinspection activities by observation of completed work involved with structural steel, heating, ventilating, and air conditioning (HVAC) systems, and electrical hangers; (4)
Overinspection Program termination requests; (5) licensee action on IE Bulletins and Circulars, previous inspection findings, 10 CFR 50.55(e) and 21 reports; and (6) allegations brought to the attention of the NRC.
During this assessment period two violations were identified in this assessment area, one Severity Level IV and one Severity Level V.
The licensee's written response and corrective action were acceptable for the violations. Neither violation represented a recurrence of noncompliance identified during the previous assessment period nor were there generic or programmatic implications.
During the previous assessment period, NRC review had not been completed for a violation that involved failure to model and analyze two snubbers in accordance.with commitments.
During this assessment period, the NRC determined that the matter was satisfactorily resolved.
An overinspection of completed construction work was necessary at the Clinton Power Station because the licensee could not assure Region III in 1982, that the installed structures and components were free of critical defects which could adversely affect the operation of safety related systems. The licensee submitted an Overinspection Program Plan to Region III in November'1982, and after an initial delay resumed inspection actisities according to the plan in September 1983. A detailed description of the Overinspection Program is included in Inspection Report 50-461/83016.
During this assessment period the licensee provided Region III with criteria for termination of the Overinspection Program for electrical raceways and supports, HVAC duct and supports,
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cable, and cable terminations. A review by Region III indicated that the licensee had not supplied sufficient data
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and analysis to support its conclusion. The request for terminating overinspection of the components was initially denied. Subsequent to the licensee's request, the licensee submitted additional data and Region III conducted onsite inspection of as-built conditions.
In addition, Region III reviewed the engineering evaluations made by the architect engineer of problems identified during overinspection. Based on this review, Region III concurred in the licensee's proposal to suspend overinspection activities of electrical raceways and supports, HVAC duct and supports, cable, and cable terminations in November 1985.
During the previous assessment period a concern was identified that approximately one third of the accessible category 1 structural steel beams were not included in the Overinspection Program. During this assessment period Region III determined that the justification was satisfactory for (1) discontinuing further structural steel inspections, and (2) conducting future inspections of the beams if modifications were made to them.
It was also noted during the previous assessment period, that due to the termination of the Overinspection Program in some areas, the adequacy of several QC inspector's work would not
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be determined.
Inspection during this assessment period by the NRC of licensee actions to assure the adequacy of the QC inspector's work was completed and found to be acceptable.
Based on Region III's reviews of the licensee's overinspection data and engineering evaluations, and Region III's independent inspection, review, and evaulation, Region III concluded that the Overinspection Program was conducted in accordance with
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approved plans and procedures, and that none of the discrepant attributes identified during the overinspection had significant safety implications. Region III's review of the Overinspection Program was completed and the results were acceptable.
Concerns expressed in 17 allegations were reviewed including:
i pressure to close nonconformance reports (NCRs) without proper review; improper NCR dispositions; requirements for inspector
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productivity that may have affected quality; possible reluctance to write NCRs; inadequate vendor quality assurance program; lack of experience for quality control inspectors; mislocation of electrical hangers; frequent changes to procedures; cheating on examinations; inadequate training;
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and deficient pipe hanger location practices.
Review of the concerns was completed. One concern involving a failure to perform a required seismic design evaluation /
review was substantiated and resulted in a violation, but
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did not have generic or programmatic implications. A concern,
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dealing with NCR dispositions, was partially substantiated; however, no violations were identified and procedural and design requirements were ultimately complied with. Another concern involving frequent changes to procedures was also substantiated; however, no violations were identified because it was determined that procedure changes were necessary to meet the changing requirements of the quality program.
During the previous assessment period, an allegation involving discrimination remained open pending review by the Department of Labor. The Order for Dismissal of the discrimination charge was signed by an Administrative Law Judge on November 4, 1985.
Since construction was essentially completed, licensee performance was generically evaluated.
It was determined that the licensee's involvement and control systems were adequate for dealing with the areas examined, especially with overinspection and dealing with employee concerns. Discussions with licensee and contractor personnel indicated that they were knowledgeable of their job duties. Observations indicated that personnel had an adequate understanding of work practices and adhered to procedures.
In addition, records were available, complete, and well maintained.
The licensee's responsiveness to IE Bulletins, construction deficiency reports, and previous NRC inspection findings was found to be timely, thorough, and technically sound.
Licensee management was very responsive to concerns expressed by the NRC.
2.
Conclusion Licensee performance during this assessment period was rated Category 2.
The licensee was not rated in " Construction" during the previous assessment period, but rather in individual construction areas as follows:
Category 1 in the areas of Containment and Other Safety-Related Structures, and Piping Systems and Supports; and Category 2 in the areas of Overinspection, Support Systems, and Instrumentation and Control Systems.
3.
Board Recommendations None B.
Quality Programs and Administrative Controls Affecting Quality 1.
Analysis Examination of this functional area was based on the results of 5 inspections by region based inspectors and considerable portions of 10 inspections by resident inspectors, several NRC contractor assisted inspections, and 2 special inspections.
Areas examined included:
(1) program for surveillance testing
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andcalibrationcontrol;(2) pre-operational:testrecords;(3)-
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Records Verification Program; (4) QA program for. records 'and storage; (5) development and staffing of the plant operating organization; (6) development and implementation of administrative procedures and Technical Specifications required for plant operations; (7) independent review programs; (8) control'ofthemaintenancecontractor'sorganization;
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(9) plant-housekeeping and cleanliness controls; (10) develop.-
ment and implementation of the-licensee's p(rogram for
tracking and resolution of NRC items; and 11) control of plant modifications.
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Seven violations and one deviation were identified in this functional area, as follows:
a.
Severity. Level V - failure to follow procedures for document control (50-461/85063).
b.
Severity Level IV - failure to follow procedures for.
making temporary changes to station administrative procedures (50-461/86017).
c.
Severity Level IV - untimely and incomplete corrective actions in response to an audit finding concerning
j-training and significant changes to plant procedures (50-461/86055).
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Severity Level IV - inadequate housekeeping in the fuel
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building and emergency diesel generator rooms j
(50-461/86041).
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e.
Severity Level IV - inadequate management control of the jurisdictional identification requirements resulting in an unauthorized change in the program (50-461/85061).
I f.
Severity Level V - inadequate documentation of an
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engineering evaluation to disposition an identified
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problem (valve stem hardness) during preoperational j
testing (50-461/86052),
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Severity Level IV - two examples of failure to keep adequate records and control activities concerning the
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containment liner in preparation and performance of
the containment integrated leak rate test (CILRT)
(50-461/85060).
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Deviation - procedures for control of instrument air
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quality did not meet the licensee's commitments and applicable national standards (50-461/86018).
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Violation a involved implementation of document control procedures resulting from inspection of an allegation. The violation was of minor significance and was isolated to performance by one individual.
Corrective actions were prompt-and effective to' preclude recurrence.
Violation b involved failure to follow procedures for making temporary procedure changes resulting from personnel making changes to a top tier plant administrative procedure without adequate review.- Corrective actions taken by the licensee,
. which involved required reading of the Notice of Violation by all personnel authorized to approve a temporary procedure change, were appropriate to the specific violation, but were not implemented in a timely manner.
NRC followup inspection of the licensee's corrective actions indicated that only about half the personnel who required training to resolve the violation had received the required training prior to presentation of the item to the NRC inspector for closure.
Subsequent NRC. followup inspection indicated that all applicable personnel had read the Notice of Violation.
Violation c involved corrective actions taken on audit findings identified by the licensee's quality assurance audit group. The violation resulted from the failure of plant staff personnel to develop and implement appropriate corrective measures in a timely fashion. The audit finding resulted from a programmatic deficiency in the administrative controls'for plant operations. The licensee's original response to the audit finding was very narrow and did not acknowledge the finding or provide generic corrective measures. The licensee's implementation of corrective measures, once they were appropriately determined, was initially ineffective resulting in the violation.
Subsequent licensee actions appear to have brought about effective measures to assure that plant staff personnel were appropriately trained for significant changes to plant procedures. A similar set of circumstances concerning an audit finding that identified deficiencies in the licensee's program for post maintenance testing resulted in a violation shortly after the SALP assessment period ended (Inspection Report 50-461/86060). These findings indicate a continuing problem in achieving an effective self-identification and corrective action program.
Violation d involved failure to adequately control conditions in the fuel and diesel generator buildings.
For example, in the fuel building a test hose was supported by small diameter instrument sensing lines, and in the diesel generator rooms equipment was stored in energized panels, instruments were left without covers, and oily rags were allowed to accumulate.
The licensee was responsive to NRC housekeeping and cleanliness control concerns; a major cleaning effort was undertaken.
Corrective actions were required in the plant suppression pool
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and drywell weir wall area due to an NRC concern. However, as the control of plant areas changed fully to plant staff jurisdiction and the operational organization gained " pride of ownership", plant cleanliness and housekeeping substantially improved. The staff's Licensing Project Manager (LPM) has toured the plant five times during this rating period. On each occasion the LPM has observed improved cleanliness.
Violations e and f had common threads that included insufficient management and supervisory involvement to assure quality and/or failure by management to recognize, address, and correct inadequate programs, procedures or conditions.
These common threads were also evident in the licensee's approach to correct an NRC identified weakness in the licensee's program to transfer jurisdictional control and turnover of systems from Startup to Plant Staff further described in Section C of this report.
The turnover program was initially controlled by a station administrative procedure which did not include any minimum quality requirements or criteria for accepting and maintaining systems in a condition that would not invalidate the completed preoperational tests. Weaknesses in the system turnover process were identified by the NRC in February 1986. The licensee developed a program in mid-1986 to assure operability of all systems required by Technical Specifications. The program addressed previously identified weaknesses in the turnover process and was implemented in July 1986.
Violation g indicated a weakness in the licensee's management involvement and control in assuring quality. The licensee performed the CILRT on January 1986. The licensee had been informed of the potential for invalidating the CIIRT both before and after the performance of the test; however, the licensee chose to administrative 1y ensure containment integrity by controlling the processing and implementation of containment liner work after the test. Management decisions relating to scheduling the CILRT and controlling containment liner work after the test were inadequate in that even though administra-tive controls were in place to control liner work, a large number of modifications to the liner were made, and uncontrolled work still took place. The large work effort on and inside the containment liner after the test, coupled with violation e and suggestion from NRC, resulted in the licensee committing to reconfirm the Type A CILRT after fuel load.
(The retest, conducted subsequent to this assessment period, was successful).
The deviation identified during the assessment period involved the licensee's lack of adherence to their comitments and industry standards for instrument air quality. The licensee's response to the deviation and their corrective actions were well thought out, implemented effectively, and
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in a timely fashion. The corrective actions tak'en for this deviation have the potential to result in improved plant reliability and availability.
One' additional item was identified during this assessment period involving failure of the licensee's quality assurance program to identify and correct significant design deficiencies
- in the Clinton Power Station (CPS) Screenhouse (that is, inability of the structure to provide a floodproof enclosure for engineered safety features equipment) both before-and during the area / commodity turnover process - NRC inspection of the licensee's turnover program during the early part of 1986 had identified programmatic weaknesses which were not promptly corrected by the licensee. The specific hardware deficiencies which resulted in this violation existed at the time the CPS Screenhouse was accepted by the licensee from the constructor in December 1985. An enforcement conference was held with the licensee concerning.this violation on August 29, 1986. The licensee exhibited a good understanding of the violation and had analyzed the violation for root causes.
Escalated enforcement action on this violation remained pending at the conclusion of this assessment period.
Inspection details were documented in Inspection Report No. 50-461/86048.
The preoperational test records program and Records Verification Program (RVP) were detennined to be acceptable.
The RVP was a result of two independent licensee audits conducted in 1982 that necessitated a 100% reinspection of construction related documents. The RVP was extensive and involved approximately 350 reviewers who reviewed and authenticated construction, fabrication, and installation documents for legibility, completeness, accuracy, and traceability. The RVP was accomplished in a manner that met licensee objectives and the requirements of ANSI N45.2.9.
Administrative control procedures for plant operations were identified during the previous assessment period as requiring additional licensee action to assure compliance to national standards, Technical Specifications, and regulatory require-ments. The licensee was slow to take actions to upgrade the affected procedures and assure effectiveness of the operational quality program. At the conclusion of this assessment period, the licensee's administrative control procedures were determined to meet minimum regulatory requirements. Licensee
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management acknowledged that the procedures would be subject
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to extensive revision to achieve a more efficient operational
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quality program, a
l NRC review of the final draft CPS Technical Specifications and a comparison of the Technical Specifications to the as
j built plant indicated that the licensee had developed a high j
quality product. A small number of minor discrepancies were i
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identified during detailed reviews and a special inspection conducted in this area. A high degree of consistency was determined to exist between the as built plant, the Final Safety Analysis Report (FSAR), and the final draft Technical Specifications.
NRC review of a plant modification to the diesel generator air start system indicated that the licensee's engineering staff had difficulty establishing the quality of the modified air start system on the basis of available objective evidence.
In addition, critical self-assessment by the licensee indicated a need for stronger management control in this area.
An organizational change replaced the Manager -
Nuclear Station Engineering with the former Manager - Startup.
This move was seen as a positive step toward strengthening management in the engineering department and resolving the NRC concern.
The licensee has developed a fitness for duty program that meets all the industry guidelines for such programs.
Implementation of the licensee's fitness for duty program began early in the assessment period and, with'the exception of a few implementation deficiencies, has been effective in identifying and resolving fitness for duty concerns.
At the conclusion of the Overinspection Program (See Section A),
the licensee was requested to respond to NRC about the QA
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" lessons learned" from the overinspection experience. The licensee's response did not indicate that there was any perceived benefit from the experience such as how to preclude future quality program related problems. As documented in this and other sections of this report, such as, licensing, preoperational testing, and maintenance, the licensee has had and continues to experience quality program related problems, some of which may result in escalated enforcement actions. A violation described in the area of maintenance, which occurred at a time when the licensee was under significant schedule pressure to complete the construction project, was symptomatic of a larger problem with lack of control over the maintenance contractor.
The immediate corrective actions taken by the licensee were narrow in scope and provided the minimum level of craft training required to achieve closure of the specific violation. The potential consequences of the violation were significant since several of the craftsmen who had not been trained had never worked on a nuclear plant. The lack of adequate craft training may have contributed to later NRC inspection findings concerning the adequacy of maintenance work performed on plant motor operated valves.
This violation was particularly significant to the licensee's quality program since corrective actions taken to resolve violations identified by the NRC in 1981-1982 should have precluded the violation. Additional NRC i
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inspections conducted late in the assessment period indicate
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that, through both organizational and procedural changes, the licensee has been more effective in controlling actions
.of the maintenance contractor.
As the focus of activity at-the plant shifted from construction to plant operations, top licensee management became more involved in operational quality programs and administrative controls affecting quality. The effectiveness of top management has been limited in the plant operations area due at least in part to the lack of effectiveness of middle and lower levels of. management and supervision. -Constant licensee management attention over the last third of the assessment period has been apparent and has resulted in some improvements in personnel performance and in plant staff's responsiveness to NRC initiatives. Technical issues have generally been appropriately addressed although some resolutions were not well thought out in advance. Additional experience and continuing top management oversight is needed to achieve a more effective quality program for plant operations.
The licensee has maintained three allegation processing programs throughout the assessment period. NRC inspection of the Clinton Safeteam identified a number of programmatic problems but no deficiencies that affected plant hardware.
Additional reviews of the licensee's other allegation processing programs (the IPQA " HOTLINE" and the Quality Report Program) have resulted through NRC inspection of allegations.
Those programs have been generally effective in resolving both hardware and construction program concerns. The licensee intends to discontinue the Safeteam in the near-future but intends to retain their other allegation processing programs.
During portions of three inspections, three allegations were reviewed in this functional area including auditor ~
certifications, destruction of inspection records, and documentation control. As described in violation a above,.
one allegation was identified with document control. As stated above, the allegation and subsequent violation had little safety significance and the ifcensee's corrective action was prompt and effective. None of the other allegations were substantiated.
During the previous assessment period, NRC review had not been completed for two violations that involved bolting materials and documenting nonconformance. During this assessment period NRC determined that both matters were satisfactorily resolved.
2.
Conclusion Licensee performance is rated Category 3 in this area because of the licensee's failure to identify and adequately correct
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numerous significant weaknesses and problems. The licensee-was rated Category 2 in this area during the previous assessment period.
3.
Board Recommendations-
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The Board recommends that the licensee review the weaknesses identified in this section and in Section D, determine why the NRC findings were not disclosed by internal quality' programs,
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analyze the actions that are required to correct these weaknesses, and prepare a corrective action plan which addresses these matters both for current plant conditions and future full power operations including testing and maintenance.
The Board recommends that the NRC' staff perform in-depth inspections of the licensee's administrative controls for at least the first six months of operation. These inspections
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should focus on procedural adherence, system control during testing, prompt identification of problems and analysis of their root catise, and the promptness and completeness.of corrective actions.
C.
Preoperational Testing 1.
Analysis Examination of this functional area was based on the results of nine inspections by region based. inspectors and portions of several resident inspections. This assessment period reflected an increased inspection effort in response to increased preoperational testing activities. Areas examined included:
(1) indepth reviews of preoperational test procedures; (2) witnessing of test performance; (3) reviews of test results; (4) reviews of administrative controls and implementing procedures; (5) observations of corrective actions; (6) observation of the turnover process from preoperational to operational controls; and (7) containment integrated leak rate testing (CILRT).
During the NRC review of preoperationai testing, two violations, one Severity Level IV and one Severity' Level V, and two deviations were identified. These violations and deviations were identified in the areas of testing methodology and CILRT, had some safety significance, but were not indicative of generic or programmatic weakness. Corrective actions taken by the licensee mitigated the significance of some deficiencies and adequately resolved NRC concerns.
The programmatic problem identified with weakness in the jurisdictional trant fer and turnover of systems from Startup to Plant Staff (previously discussed in Section B, Quality
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Programs and Administrative Controls Affecting Quality)
impacted the readiness of systems previously tested such that uncertainties in the results of tests had to be re-evaluated to determine their validity. However, these problems did not have an adverse effect on preoperational tests because of the Test Results Review Group (TRRG). The TRRG was effective in assessing the completeness of preoperational tests and determining the impact on test results by activities such as other testing, maintenance, and plant modifications.
Subsequent to this assessment period, the TRRG was also effective in determining and resolving the potential impact upon preoperational testing results caused by modifications made after testing was completed.
In addition, the overall effectiveness of the licensee's Startup Staff was demonstrated when NRC completed 95% of its review of preoperational test results without finding any significant deficiencies. Over the course of this assessment period, when compared to other nuclear power plants conducting preoperational tests, regulatory performance has been outstanding in terms of the types and minimum number of violations.
Within the specific areas of preoperational testing and startup test procedure preparation, Startup department management involvement in assuring quality was evident through the establishment and control of such groups as TRRG, the completeness of test result packages, and the prompt and thorough corrective actions taken for problems found in this area.
It is noted that the turnover and maintenance problems discussed in other sections of this report overlap somewhat into the testing area and the corrective actions for these areas were not viewed as prompt or thorough. However, in the specific areas where the licensee's Startup organization had sole responsibility, management was perceived to be quite responsive to NRC concerns.
Staffing was also perceived as a strength in this area in terms of adequate number of people who were knowledgeable in their discipline and who demonstrated a desire to complete the testing correctly and safely. Since many of these people were contractors whose contract has subsequently ended, the positive aspects of the testing staff cannot be assumed to carryover into the Startup testing and operational phases.
During portions of four inspections, three allegations in this functional area were reviewed including test tagging, system test documentation, and test procedures. None of the allegations were substantiated.
2.
Conclusions
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Licensee performance is rated Category 1 in this area. The licensee was rated Category 2 in this area during the previous assessment period.
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Board Recommendations None D.
Maintenance 1.
Analysis Examination of this functional area was based on the results of five inspections by region based inspectors, portions of several inspections by the resident inspectors, and a team inspection completed after the end of the assessment period.
The inspection effort increased at the end of the assessment period in response to maintenance activities in preparation for fuel loading and NRC concerns for adequate conduct of maintenance. Areas inspected included:
(1)reviewsof documentation of completed maintenance activities; (2)
procedures; (3) work in progress; and (4) allegations associated with maintenance activities.
Nine violations were identified in this functional area as follows:
a.
Severity Level V - inadequate procedure resulting in plant staff not maintaining the safety-related station batteries as required by the preoperational test program
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and the Standards (50-461/85061).
b.
Severity Level IV - inadequate and slow corrective actions to correct Plant Procedures for maintaining the safety related station batteries (50-461/86013).
c.
Severity Level IV - inadequate maintenance activities resulting in potential degradation of safety-related equipment (50-461/86013).
d.
Severity Level IV - failure to follow maintenance work request procedures, four examples (50-461/86023).
e.
Severity Level IV - failure to follow station adminis-trative procedures for maintenance activities resulting in inadequate closure and documentation of maintenance activities (50-461/86041).
f.
Severity Level IV - failure to complete work prior to closing a maintenance work request (50-461/86048).
g.
Severity Level V - failure to follow the station administrative procedure for documenting maintenance activities (50-461/86052).
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h.
Severity Level IV - inadequate corrective actions for licensee identified problems with closure of maintenance activities (50-461/86052).
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Severity Level IV - failure to assure that personnel performing activities affecting quality were properly trained prior to performance of safety related maintenance (50-461/86008).
Violation a concerning an inadequate maintenance procedure, appeared to be isolated at the time, but subsequent inspection activity showed this was not the case as indicated below.
Violations b and h were significant in that they pertained to the licensee's failure to correct identified adverse conditions:
In violation b, the NRC identified inadequacies with maintenance procedures for the safety-related batteries.
These inadequacies were not promptly corrected and during subsequent inspections, NRC findings showed the need for additional corrective maintenance and engineering evaluations to validate battery readiness.
Violation h resulted because the corrective actions taken in response to an identified adverse condition did not prevent recurrence.
Violation c is significant because plant staff took jurisdic-tional control of the batteries before verifying that the maintenance staff was prepared to maintain the batteries without invalidating the preoperational tests.
Routine and corrective maintenance activities concerning the safety-related batteries resulted in the potential to degrade the batteries and prevent them from performing their intended safe shutdown function because of poor training of the maintenance staff, inadequacies in maintenance and surveillance procedures, and insufficient involvement of management to assure quality.
It should be noted that the batteries never were degraded to the point which would have precluded performance of safe shutdown functions.
Violations d, e, f, and g involved failure to follow procedures and are related. Violation d involved incomplete maintenance, failure to perform QA review and sign-off of work packages, performance of unauthorized work, and inadequate technical review. Violation f, involved a second violation concerning completion of maintenance work for the same work activity involved in violation d.
Violations e and g, involved failure of the licensee's staff to follow station administrative procedures for controlling performance and documentation of maintenance activities.
Violation i concerned lack of training for Stone and Webster (the licensee's maintenance contractor) crafts including failure of the contractor to train a significant percentage
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of the craft work force to applicable quality program requirements, and failure of the licensee's quality assurance program to detect and correct the violation. The relevance of this violation to plant quality is discussed in Section B of this report.
The above violations indicated an overall problem with management control of maintenance activities. Major weaknesses in maintenance were not corrected by the licensee during the evaluation period. Although the licensee identified deficiencies, corrective actions were poorly thought out, and in many cases, only addressed the specific problem.
In most cases the licensee did not evaluate deficiencies to determine root causes so that effective corrective actions could be implemented to prevent recurrence. Toward the end of the assessment period, a task force was established by the licensee to identify root causes of the problems which had occurred with motor-operated valves.
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Prior to the end of this assessment period, the licensee created a new position called Assistant Plant Manager, Maintenance which was filled with an experienced and competent individual.
The NRC views this change as a positive move to strengthen the site maintenance organization.
During followup of allegations, the NRC found that 70% of a sample of maintenance activities demonstrated inadequate closure and completeness of maintenance activities (violation e,above).
In addition, three other allegations were reviewed, including improper mixing of grease, improper cleaning of an electrical penetration, and improper closure of maintenance work requests. Although two of these allegations were partially substantiated, no additional violations or deviations were identified.
Subsequent to this assessment period, other potential violations were identified during the team inspection of maintenance for which escalated enforcement action is being considered. These violations were identified in the following areas:
(1) improper or inadequate procedures; (2) failure to follow procedures; (3) inadequate corrective actions; and (4)
untimely corrective actions.
Examples of these violations were as follows:
failure to provide an adequate valve lubrication procedure, and failure to follow procedures, or correct them when determined to be inadequate; failure to identify environmentally unqualified wire; inappropriate modification of valve operator motor wiring; failure to take adequate corrective action to correct the problem after destroying a valve operator motor; inadequate maintenance activities which led to the miswiring and ultimate i
destruction of 17 valve operatar motors; failure to evaluate
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the cause of equipment failures identified during maintenance; and failure to control material accountability and bolt torquing.
Failure to follow procedures was compoundad by several levels of maintenance supervision who also failed to follow procedures because they lacked knowledge of what the procedures required.
Subsequent to this assessment period, a management meeting was held on September 19, 1986.
During the meeting, the licensee-described corrective actions to improve the maintenance program. A commitment was made by the licensee to implement the corrective actions prior to the scheduled date for operation above 5% of rated power. These measures included:
(1) improving performance in the areas of maintenance work request (MWR) planning, execution, review, and scheduling; (2) restructuring of the Maintenance Department to split out the planning responsibility from the execution of work; (3)
expanding the management of the Maintenance Department; (4)
consolidating all maintenance planning; (5) improving communications within the Maintenance Department; (6) ensuring that prior to vaulting, the MWR will be a stand-alone document containing all pertinent data; (7) developing generic lists for pre-approved expendable maintenance items; (8) conducting a " top down" procedure review to assure that lower tiered documents fully implement upper tier documents; and (9)
expanding the field engineering group within the MWR planning organization to ensure that MWRs receive an adequate review prior to performance of work.
Because of the corrective actions committed to be completed prior to exceeding 5% power, correction of identified hardware problems during the team inspection, and controls to insure that additional hardware problems would be identified during completion of the post-maintenance testing and startup testing, a license to load fuel was issued.
2.
Conclusions The licensee is rated Category 3 in this functional area.
This is based on the significance and number of violations found during this assessement period and the failure to identify root causes of problems so that corrective actions to prevent recurrence could be initiated.
Licensee performance was not rated during the previous assessment period.
3.
Board Recommendations The Board recommends that the licensee diligently pursue implementation of its corrective action plan in this area.
The Board recommends that the NRC staff followup on the licensee's corrective actions and provide increased inspection coverage of this area during the first full year of operation.
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E.
Radiological Controls 1.
Analysis ExaminaYion of this functional area was based an the results of nine inspections by region specialists and'several s
inspections by the resident staff. This assessment period reflects an increased inspection effort in response to recommendation:, of the previous SALP Board. Areas examined included:
(1) radiation protection; (2) radwaste; (3)
chemistry / radiochemistry; (4) quality assurance / quality control (QA/QC) of analytical measurements; (5) confirmatory measurements; (6) water chemistry control; (7) radiological environmental monitoring; and (8) allegations brought to the attention of.the NRC.
Noviolationsordev{ationswereidentified.
Organization, staffir,g, and training met or exceeded FSAR requirements, including appointment of a new Chemistry Supervisor to strengthen weaknesses in that area. Staff complement and qualifications were adequate to proceed with fuel" load, startup, and provide coverage on all shifts.
Although Rad-Chem technician (RCT) experience in nonradio-logical chemistry was good, their nuclear power plant radiochemistry experience is limited. All radiation protection technicians have received operational experience at other pl'nts. All radwaste technicians completed a qualification a
program to operate the radwaste system; however, most of the radwaste workers lack actual radwaste operating en erience.
In response to NRC concerns, the licensee retained a qualified chemistry / radiochemistry consultant to assist the Chemistry Supervisor and to strengthen support in radiochemistry during the preoperational and early plant operational period.s Two additional chemistry consultants, two training coordinators, and eight contract technicians augmented the chemistry group to allow the 14 RCTs to complete their on-the-job-training (0JT) for their qualification cards and training program before the five percent power license was issued. A training program was designed and initiated to give radiation workers OJT, including demonstrations of good radiation protection practices while working on simulated radioactive systems. Contractor radiation protection technicians were hired to support fuel load. There appears to be adequate technical staff expertise in radiological engineering.
Management involvement was evident during this assessment period. The radiation incident report system was strengthened and implemented. Also, a radiological assessment audit program involving the participation of the Corporate Health Physicist was initiated. Weaknesses identified during a licensee audit of the liquid radwaste processing system received appropriate
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licensee attention. ' Management was generally on top of resolving problems once identified. However, the licensee was slow to correct some weaknesses, such as a water spillage problem around the Feedwater Sample Danel and plugged sample lines. Also, the licensee's investigation of a radiographic exposure incident should have included a more extensive reenactment of the incident.
The licensee demonstrated responsiveness to NRC concerns by establishing a satisfactory QA/QC program for nonradiological chemical parameters. This includes maintaining a control chart on each chemical instrument to assure its reliability.
In addition, a program for providing blind samples to test the proficiency of the RCTs was recently initiated. Pre-liminary results of a first set of samples for pH, conductivity, and boron were acceptable. The licensee plans to extend the program to include all RCTs. tiowever, a weakness is evident in.the program because only those chemicals with Technical Specifications limits (chloride, pH, conductivity, and boron)
are analyzed; not included are sulfate, fluoride, silica, and copper, which are important for chemical control and recommended by the Boiling Water Reactor (BWR) Owners Group.
The licensee appeared willing tu consider improvements in the program and plans to expand this program at a later time.
The licensee was also responsive to NRC suggestions that the RCTs improve their use of log books and log sheets to properly document plant data.
The licensee's approach to resolution of radiological technical issues was generally conservative and sound. The RCTs demonstrated satisfactory capability for collecting samples I
and analyzing them for key chemical parameters. The licensee established an adequate water chemistry control program that satisfactorily addressed the major elements in the BWR Owners Group guidelines including provisions for monitoring and trending important chemical parameters and for suitable administrative controls.
This program is expected to be fully implemented once the plant is operational. The licensee's plan for a QA/QC program for radiological samples appeared adequate. Confirmatory measurements of spiked gamma emitters have been satisfactory but a second Sr-89/Sr-90 sample for beta analysis had to be provided to the licensee before acceptable results were attained. The licensee also completed the preoperational requirements for the Radiological Environmental Monitoring Program (REMP) and demonstrated adequate capability in collecting and analyzing the environmental samples.
Facilities and equipment for health physics and chemistry were generally satisfactory, including adequate ventilation in the laboratories to permit radiochemical operations.
Sufficient health physics instrumentation, whole body count instrumentation, respiratory equipment, and portal monitors were available.
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Laboratory and counting room instruments were of good quality, j
well maintained and adequate to perform the required analyses, l
and were calibrated in accordance with approved procedures.
,'.All procedures for chemical / radiochemical operations were in place.and approved. Major r.evisions were made during this
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assessment to upgrade the radiological control procedures.
During a review of allegations scme weaknesses were identified concerning worker adherence to radiological procedures and
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controls; the licensee is continuing to emphasize the need f
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for procedural adherence.
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2.
Conclusion
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, Licensee performance is rated Category 2 in this area. The licensee was rated Category 2 during the previous assessment
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period.
3.
Board Recommendation s
None F.
Fire Protection 1.
Analysis s.
Examination of this functional area was based on the results of three inspections by region based inspectors and their contractors. Areas exa.nined included: (1) licensee's
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progress in implementing the requirements of 10 CFR 50, Appendix R; (2) review of the fire protection construction and pre-operational test program; (3) review of allegations received by the NRC; and (4) NRR Fire Protection Audit.
Two violations were identified in this functional area as follows:
a.
Severity Level IV - failure to calibrate hose station pressure reducing devices, and not adequately following the portable fire extinguisher surveillance procedure (50-461/85047).
b.
Severity Level IV - failure to install a solid stream nozzle on a fire hose attached to a standpipe station as required by the Special Nuclear Materials License (50-461/86028).
In addition to the specific deficiencies identified, the licensee was requested to address the underlying cause of the programmatic breakdown in not ensuring that proper fire protection features were installed as required by their Special Nuclear Materials License. The licensee's response
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to the violations and above concerns was determined to be satisfactory. During a followup inspection the NRC determined that fire protection features were installed as required.
During this assessment period the licensee made satisfactory progress in the fire protection area by resolving several issues identified during the Appendix R inspection. The licensee adequately resolved all previous NRC concerns except fire protection administrative controls that had not been fully implemented. Those controls will be implemented prior to exceeding five percent power.
Three allegations were reviewed relative to pressure barrier seals. The allegations were not substantiated based on supporting test data, field inspections of the installed configurations, and other supporting documentation.
Management was sufficiently involved in this functional area as evident by the licensee's responsiveness in addressing the inspectors' concerns. Staffing appeared to be adequate and personnel were knowledgeable and well trained.
2.
Conclusion Licensee performance is rated Category 2 in this area. The licensee was not rated in this area during the previous assessment period.
3.
Board Recommendations None G.
Security 1.
Analysis Examination of this functional area was based on the results of seven security inspections by region inspectors.
This assessment perind reflects an increased inspection effort in response to recommendations of the previous SALP Board.
Operational security, security of new fuel, and the physical protection of safeguards information were included in the scope of the inspections. The resident inspectors routinely observed security activities. Although the licensee implemented the security system in June 1986, the security plan requirements did not become effective until the operating license was issued.
Four violations were identified in this functional area as follows:
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a.
Severity Level IV - Documents containing safeguards information were not adequately protected or controlled (50-461/86006).
b.
Severity Level IV - Documents containing safeguards information were stored in an inadequate container (50-461/86020).
c.
Severity Level IV - Security doors leading to the fuel floor were not locked as required (50-461/86036).
d.
Severity Level IV - Personnel access to the fuel floor was not adequately controlled on three occasions (50-461/86056).
The first two violations involved requirements for the protection of safeguards information and the remair.ing two violations involved fuel security plan requirements.
The failure to properly control and protect safeguards information, violations a and b, resulted from a lack of training and the inadequate administration of the safeguards'
information protection program. When identified, actions were taken that resulted in a strong program which combined a centrally managed effort with good employee training.
Some of the causes of the fuel floor security violations, violation c and d, involvea inattentiveness to detail as demonstrated by failing to follow established procedures.
In some instances, the violations also involved elements of inadequate supervisory response. Licensee attention to detail and security supervisory effectiveness continued to be NRC concerns in assuring quality in the Special Nuclear Material security program.
This concern continuas to warrant licensee management attention after issuance of the operating license.
Although the licensee implemented their security program earlier than required, in June 1986, implementation required several exceptions and compensatory security measures to accommodate the on-going operational activity necessary to prepare the plant for operating license issuance. This resulted in numerous compensatory measures being needed during the " lock down" period, and led to excessive guard force overtime and poor working conditions.
Although there has been evidence of prior planning, licensee actions involving changes to the Physical Protection Plan for Special Nuclear Material (SNM) indicate that planning was not always sufficiently thorough or timely. On one occasion, the licensee re-designated security doors and this change required notification of the NRC within two months of the change. The licensee would not have made the notification within the
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required time frame had they not been prompted by the senior resident inspector.
Senior management's awareness and support for security issues has been good. Security exit meetings were routinely attended by the vice president and executive vice president. Security issues identified during those exit meetings were normally resolved in a very timely and effective manner. As a result of management's attention, for example, the contractor security force's facilities were recently upgraded. The existing facilities are now among the best within Region III.
In certain circumstances, the licensee did not resolve security issues in a thorough and timely manner. On March 1,
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1986, for example, there was a loss of power experienced for several key pieces of security equipment. Once power was restored, very little was done to determine the cause of the power failure. Only after being questioned by NRC inspectors, did the licensee identify several hardware problems associated with the system.
The licensee was normally very responsive to NRC initiatives.
However, IE Bulletin No. 77-08 dealing with the safety / security interface required repeated submittals before the license's response was considered adequate. Several open items were presented to the NRC as complete, such as security keying procedures, yet followup effort by NRC determined that the procedures were not being followed. The open items that required more licensee action were indicative of the occasional inattentiveness to detail.
Security modifications identified as critical to security operations received appropriate high priorities and were completed in a timely manner. This resulted in no incomplete security modifications that could impact on fuel load.
Additionally, no compensatory measures for incomplete security modifications were required as of the close of the assessment period. This represents a noteworthy achievement by the licensee's organization.
The licensee's ad hoc working committee approach to major program elements, such as equipment procurement, installation and testing, and resolution of major security computer problems, has been extremely effective. Coordination with and use of vendors was very positive.
The licensee is required to report only certain security events because of the plant's pre-uperational status.
Region III
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determined that potential equipment tampering events were of NRC interest and, therefore, requested that these events be reported. The licensee did not take a conservative approach to security event analysis initially; however, improvements
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were made in event reportability.
Plant employee awareness has been heightened so that potential security events can be better recognized. Although not required by NRC regulation, the licensee took the initiative and reported security events prior to operating license issuance to develop and improve their reporting capability. This resulted in administrative deficiencies being identified and corrected.
The security organization has identified positions with corresponding authority and responsibility. The security force has been expanded based on the operational data that was obtained-from the June 1986, security lock-down. The security orgarization's manning levels are ample to satisfy security plan commitments.
Effective first line supervision was lacking on occasion, and contributed to the inattention to detail and communication problems within the security organization.
The licensee's security training and qualification program is a significant program strength. The training is based on security plan commitments and security procedures.
When security procedures are changed, the new procedures are added to training lesson plans. The program also incorporates immediate feedbeck on analyzed security deficiencies into the training to enhance its effectiveness.
One allegation regarding fitness for duty was reviewed in this functional area. The allegation was not substantiated.
2.
Conclusion Licensee performance is rated Category 2 in this area. The licensee was rated Category 2 in this area during the previous assessment period.
3.
Board Comments None H.
Operational Readiness 1.
Analysis-Examination of this functional area was based on the results of portions of eight inspections by resident inspectors.
Areas examined included:
(1) normal operating procedures; (2) annunciator response procedures; (3) off-normal operating procedures; (4) surveillance procedures; (5) system status control; (6) operating logs and records; (7) and training.
A special inspection by a Senior Resident Inspector from an operating plant in Region III included an extended observation of control room activities late in the assessment period.
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One violation and one deviation were identified in this functional area, as follows:
a.
Severity Level IV - surveillance procedures lacked detailed procedure steps and appropriate acceptance criteria (Inspection peport 50-461/86037).
b.
Deviation - independent verification of system lineups was not consistent with licensee commitments (50-461/86048).
The violation involved adequacy of operational surveillance procedures after the completion of licensee technical reviews intended to assure the technical adequacy of the surveillance procedures. Corrective actions taken by the licensee to date have been effective in resolving identified problems.
In addition, the licensee's trial use surveillance procedure development program has been an important tool in assuring a viable system of surveillance procedures.
The deviation, identified late in the assessment period, involved an apparent failure to meet commitments contained in
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the CPS FSAR for independent verification of system lineups in the plant operating procedures.
The licensee promptly acted to determine the significance of the deviation and corresponded appropriately with other NRC offices. Their response to the deviation indicated that the current criteria for independent verification of system lineups were acceptable and that the FSAR would be updated to reflect those criteria.
NRC inspection (Inspection Report 50-461/86060) subsequent to the assessment period identified that, although the criteria were appropriate, they were not appropriately applied in all cases. The licensee's review of the deviation should have identified this.
Implementation of the licensee's program for declaring plant systems operable under the CPS Technical Specifications in preparation for plant licensing was reviewed extensively during the assessment period.
Preplanning of this activity was poor, as reflected in Section B concerning system turnover. Although some problems were encountered during development of the appropriate administrative control procedure, implementation of the procedure was well controlled with appropriate involvement by management and supervision.
Operations department personnel established a baseline for each system by a thorough walkdown and document review process; established a prioritized listing of work requirements to support system operability; tracked each item through completion, demanding that important activities be completed prior to the required milestone; and were very receptive and responsive to NRC concerns and initiatives.
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NRC observation of control room and simulator operations indicated the need for improvement in several aspects of plant operations. The licensee responded by changing the control room arrangement, increasing the frequency of management visits to the control room, and increasing the frequency of audits /surveillances. Additional operator training in plant emergency procedures was also provided.
Subsequent NRC observation of operator actions during simulator demonstrations of plant response to operational transients indicated improved performance.
Extended observation of control room conduct and verification of operational readiness activities in the main control room indicated substantial improvements were made during the latter portion of the assessment period. Adherence to administrative controls for maintaining system status, performance of shift duties, maintenance of logs and records, and use of system operating procedures all improved substantially. No significant discrepancies were identified.
Plant operators appeared to be knowledgeable of plant systems and operations in progress; responded to alarms and indications in a timely manner; and conducted themselves in a businesslike manner.
NRC observation of control room activities indicated that the level of activity in the main control room was relatively high. Considering the demands of the startup test program, additional " deferred" testing activities, and the normal routine demands on the plant operators, the NRC remained concerned that the high level of activity could result in increased operator error rates and reduced safety performance. This matter was reviewed in detail with licensee management who provided special management controls to minimize the impact of deferred testing activities on plant operations. Subsequent to the assessment period (Inspection Report 50-461/86060), the licensee committed to perform two special, independent assessments of the effectiveness of the special management controls to provide additional assurance that plant operations will not be adversely affected by concurrent performance of deferred test activities.
Operations department management and supervision exhibited a clear understanding of the high level of performance that must be achieved and maintained in this functional area.
Operations department rescurces were strained by the workload involved in preparing the plant for licensing, as evidenced by the substantial use of overtime. However, only a small number of violations resulted from intensive NRC inspections of operational readiness activities. Notwithstanding the identified violations and concern regarding the level of activity in the main control room, the conduct of day-to-day activities during the latter portion of the assessment period
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was generally found to be adequately controlled by knowledge-able personnel and in accordance with technically adequate procedures.
During the assessment period, examinations were administrated to senior reactor operator candidates and reactor operator candidates. Twenty-five of 34 senior reactor operator candidates and 11 of 14 reactor operator candidates passed the examinations. Based upon these results, the Clinton
. license training program is considered satisfactory.
Two allegations were reviewed in this functional area. The allegations included 11 concerns with preparation, review, control, or content of preoperational test and surveillance procedures. Two concerns about surveillance procedure content were substantiated. However, there was no significance to safety; therefore, no violations were identified.
2.
Conclusions Licensee performance is rated Category 2 in this area. The licensee was rated Category 2 in this functional area during the previous SALP period.
3.
Board Recommendations None I.
Analysis Examination of this functional area was based on the results of four inspections by region based inspectors. Areas examined included:
(1) the emergency preparedness implementation appraisal (EPIA) in November 1985; (2) observation of the annual emergency preparedness exercise in December 1985; (3) a followup inspection to the EPIA in March 1986, to assess the progress in addressing NRC concerns raised as a result of the EPIA; (4) and an inspection in September 1986, to review Open Items.
No violations or deviations were identified.
The EPIA result.:d in forty-seven open items and thirty-two improvement items. Although there were more open items than identified on any other EPIA at a Region III facility, the licensee has since made good progress in closing out EPIA items after their identification by the NRC. No additional NRC concerns were raised during the followup inspections to the EPIA.
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The scenario for the 1985 emergency exercise was considered challenging and difficult, and adequately exercised all aspects of the Emergency Plan. While six exercise weaknesses were identified as a result of this exercise, the items were not
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considered indicative of major programmatic problems, and I
overall the licensee's performance was adequate.
The licensee has been generally responsive to NRC concerns by providing viable, sound and thorough responses. When resolving weaknesses from a safety standpoint, the licensee has demonstrated a good understanding of the issues involved.
For example, the followup to the EPIA resulted in closing 40 of the 47 open items in addition to the licensee adequately addressing 27 of the 32 improvement items.
Management involvement in emergency preparedness has been good, as evidenced by their participation in the exit meetings following each inspection, and the adequacy with which NRC concerns are addressed.
Staffing of key emergency response positions has been adequate, with the authorities and responsibilities of personnel well identified.
Knowledge and capability of personnel to carry out their assigned emergency response duties and responsibilities were demonstrated during the annual emergency preparedness exercise, as well as during walk-throughs with key emergency response personnel dering the followup to the EPIA. The licensee's performance is indicative of a training program that has adequately prepared personnel to carry out their emergency response assignments.
In sumary, the licensee initially had a difficult time in preparing for implementation of the emergency response program, and a large number of open items were identified. Once id'entified, the licensee expended efforts to adequately close ou-NRC identified items and resolve outstanding issues.
2.
Co;.clusion Licensee performance is rated Category 2 in this area. This functional area was not rated during previous SALP period.
3.
Board Recommendations None J.
Licensing Activities 1.
Analysis Examination of licensee performance in the area of licensing activities was based primarily on four attributes:
(1)
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management involvement and control in assuring safety; (2)
approach to resolution of technical issues from a safety standpoint; (3) responsiveness to NRC initiatives; and (4)
staffing.
During this review period, the licensee's management has demonstrated a thorough working knowledge of the-technical issues involved in licensing activities; provided active participation in the resolution of key issues; and has kept abreast of current and anticipated NRR licensing issues.
The licensee's management has oeen effective in directing its staff to ensure consistency between and among the as-built facility, regulatory requirements, the SER, the FSAR and Technical Specifications. The licensee's management has displayed a strong commitment to resolution of both generic and plant specific issues such as those associated with the Mark III containment design, that is, the hydrogen control and Humphrey issues, by providing active participation in the BWR owners and review groups.
In the previous SALP rating period, the licensee's management was actively involved and instrumental in the resolution of many key issues associated with the licensing of Clinton.
During this rating period there were only a few issues that required significant management involvement. Pump and valve operability and seismic qualification of equipment were two issues that, although there was significant licensee management involvement, required almost a full year and an excessive number of audits, meetings, and conference calls to achieve resolution.
The difficulties in resolving these two issues were probably due to a combination of the following: mis-understandings between the staff and licensee; a different approach used by the licensee to resolve certain aspects of these issues; and reliance on the Architect-Engineer to resolve these issues for both the nuclear steam supply system components and the balance of plant components.
The licensee's management involvement for the remaining issues that required management attention has for the most part been effective in obtaining resolution in a timely manner.
The licensee's entire nuclear organization through the vice president in charge of nuclear, is located at the site, which should make it easier to obtain approvals and process correspondence between the licensee and the NRC staff.
Unfortunately, it has been taking an excessively long period of time for the licensee's management to concur on corre-spondence that is required for closure on issues that are under NRC staff review.
However, since the licensee's fuel load date has slipped, the neceri y for a fast turnaround of correspondence has been averted in most instances. Nevertheless, it should be noted
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since the plant is licensed, it is essential for the licensee to have the capability for promptly docketing information that is needed to support licensing actions.
In addition, proposed changes to the technical specifications that are required to support fuel load, emergencies, or exigencies will require submittal of correspondence in a more timely manner.
The licensee's management and staff have continued to demonstrate a good understanding of the technical issues based on the evaluations obtained from the NRC technical reviewers.
Responses to NRC inquiries have been generally viable with technically sound, conservative and thorough approaches in most cases. The-licensee has performed additional studies, as necessary, to resolve technical issues.
While the licensee has been aggressive in resolving many safety issues the staff believes that it has relied excessively on its Architect-Engineer for technical responses to many issues.
Pump and Valve Operability Review Team (PVORT) and Seismic Qualification Review Team (SQRT) are two particular issues where this has been the case.
The licensee has provided the information needed to adequately resolve licensing issues, however, some of the initial submittals continue to be not as complete as required, necessitating followup information and clarifications.
The licensee's tracking system has been very useful in tracking and resolving all the remaining licensing issues.
The licensee indicated that use of the system will be continued after issuance of the operating license.
Open and effective communications continue to exist between the NRC and the licensee's licensing staff.
In most instances effective dialogue between both staffs promotes prompt and technically sound responses to NRC initiatives. The licensee usually meets established commitment dates or provides written or verbal responses explaining the circumstances associated with delays and, in most instances, establishes new firm dates.
Conference calls with the staff are promptly established and include appropriate engineering, plant, and or contractor personnel. The licensee's Washington contact has been effective in resolving issues resulting from the substantive FSAR amendment changes that have been submitted during this rating period and in expediting the exchange of information in an accurate and concise manner.
The licensee's staff has always been prepared to meet with the NRC staff whenever necessary to resolve issues or to brief the staff on new significant issues that require staff review.
During these meetings the licensee has usually demonstrated a thorough understanding of the technical issues.
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The licensee's management organization was modified during this rating period to reflect the transition from construction to an operational mode. This has resulted in the addition of several departments and groups.
In addition, several management changes have occurred as a result of the reorgani-zation, replacement of management, and attrition. The previous Director of Nuclear Licensing was promoted to Manager, Licensing and Safety. A new Director of Nuclear Licensing has been hired who has operating reactor licensing experience.
In the area of licensing the utility appears to be well staffed and to have adequate experience to perform acceptably during the transition to the operational mode.
From the onset of licensed operations, the licensee plans to use five operating shift crews for normal operation. The licensee's plant operating organization was found acceptable for the licensing of Clinton in Supplement 5 to the SER.
2.
Conclusions An overall performance rating of Category 2 has been assigned
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for the functional area of licensing activities. The licensee was rated Category 1 during the previous assessment period.
The licensee's decline from a Category 1 to a Category 2 was primarily due to performance in resolving the PV0RT and SQRT issues and timeliness of responses to NRC inquires.
3.
Board Recommendations None
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V.
Supporting Data and Summaries A.
Licensee Activities Construction of the Clinton Power Station at the close of this assessment period was essentially 100% complete.
Major Facility Milestones October 1985 Fuel receipt completed.
November 1985 System turnovers completed for transfer from constructor to licensee.
April 1986 ASME N-5 certification program completed.
May 1986 Containment isolation test and integrated ECCS-loss of offsite power test performed.
June 1986 Security system activated.
July 1986 All subcontract work transferred to Stone
& Webster.
July 1986 Preoperational tests for fuel load completed.
B.
Inspection Activities During the assessment period of September 1, 1989, through August 31, 1986, there were 63 NRC inspection reports written pertaining to matters at the Clinton Power Station. NRC's inf.pection sumary of activities is as follows: 46 routine inspections; 13 resident inspections; and 3 special inspections including overinspection, SAFETEAM, and Technical Specifications - Final Safety Analysis Report comparison.
(See Item 2 below)
1.
Inspection Data Facility Name: Clinton Power Station Unit 1 Docket No.:
50-461 SALP 6 includes Inspection Reports No. 50-461/85-043 through 85-065,86-001 through 86-004,86-006 through 86-014,86-016 through 86-021,86-023 through 86-026,86-028 through 86-045,86-047 through 86-052, and 86-055. Report 50-461/86056 was initiated prior to the end of this assessment period and completed after the assessment period. Results of that inspection were included in this report.
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During the previous assessment period,.which was for 18 months, 17 violations were issued. During this assessment period, which was for 12 months, 27 violations were issued.
The increase in violations was attributed to increased levels of work in certain areas, increased inspection activities by the NRC in these areas, and management problems in controlling changes in the plant status.
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TABLE 1 Inspection Activity and Enforcement No. of Violations in Each Severity Level
Functional ~ Areas I
II III IV V
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Construction
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Quality Programs and
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Administrative Controls Affecting. Quality *
C.
Preoperational Testing
1
D.
Maintenance
2 E.
Radiological Controls F.
Fire Protection
G.
Security
H.
Operational Readiness
1 I.
Emergency Preparedness J. - Licensing Activities
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Totals =
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- There was one violation identified in this area pending escalated enforcement action which is not included in this table.
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2.
Special Inspection Summary a.
August & September 1985 - Special NRC inspections of the Clinton Overinspection Program.
b.
January 1986 - Special NRC team inspection of the SAFETEAM.
c.
March 1986 - Special NRC team inspection of consistency and comparability between Technical Specifications, FSAR, plant as-built configuration, and associated surveillance requirements.
d.
June 1986 - Special inspection of fire protection,
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Appendix R.
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C.
Investigations and Allegations Review There were 40 allegation files opened, 32 were closed, and 14 remained open during this assessment period. None of the findings
involved significant safety issues.
In addition to the inspection of. allegations identified throughout this report, inspections of non-functional areas were also conducted. Those areas include intimidation, discrimination, environmental control, vandalism, and illicit drug use. At the end of this assessment period one matter about discrimination was pending escalated enforcement action.
(See D below)
D.
Escalated Enforcement Actions
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Two escalated enforcement cases were initiated during this assessment period. These escalated enforcement actions are pending:
An enforcement conference was held on August 15, 1986. -The citation involved a finding by the Department of Labor that a contractor employee was improperly fired after bringing quality concerns to
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his management in 1984. This matter remains under review by the i
NRC staff. The licensee has informed the NRC that the decision by the Department of Labor will be appealed.
An enforcement conference was held on August 29, 1986. This issue dealt with shutdown service water pump cubicles not being properly floodproofed. This matter remains under review by NRC staff.
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Violations in the area of plant maintenance and modifications are also under review by the NRC staff.
Inspection started during this assessment period and extended to September 19,1986(50-461/86053).
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E.
Licensee Conferences Held During Appraisal Period
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September 23, 1985, conference with licensee to discuss items
"important to safety".
December 12, 1985, conference with licensee to discuss SALP 5.
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January 27, 1986, conference with licensee to discuss readiness for fuel loading.
February 21, 1986, conference with licensee to discuss readiness for fuel loading.
April 1,1986, conference with licensee to discuss readiness for fuel loading.
May 1,1986, conference with licensee to discuss readiness for fuel loading.
June 10, 1986, conference with licensee to discuss readiness
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for fuel loading.
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.o July 10,1986, conference with licensee to discuss readiness for fuel loading.
August 7, 1986, conference with licensee to discuss concerns related to licensee performance, Clinton readiness for fuel loading, and the status of activities required for for fuel loading.
F.
Confirmatory Action Letters (CALs)
There were no CALs issued by the NRC during this assessment period.
G.
Review of Construction Deficiency Reports and Vendor Defect Reports Submitted by the Licensee 1.
Per the requirements of 10 CFR 50.55(e) the licensee notified the NRC of 14 con.truction deficiencies during the this assessment period. Of the 14, three were withdrawn or determined by the licensee to be not reportable. Corrective actions were initiated by the licensee for all deficiencies.
Twenty-seven 50.55(e) deficiency reports were reviewed and l
documented closed in NRC inspection reports, included in these close outs were outstanding items, as old as 1984.
The number of construction deficiencies reported during this assessment period was the same as the number reported during-the previous assessment period. A review of the nature and
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details of the items reported and the timeliness of reporting indicates that the licensee maintains a proper reporting threshold and is responsive to the reporting requirements of 10 CFR 50.55(e). The quality of written reports and the associated analysis reflects favorably on licensee management and staff.
2.
NRC was notified by the licensee of seven reportable defects per the requirements of 10 CFR 21.
The number of vendor defect reports made during this assessment decreased slightly from the number made during the previous assessment period.
H.
Licensing Activities NRR/ Licensee Meetings September 1985 PVORT program plan October 1985 PVORT recovery program November 1985 Hydrogen control November 1985 Fire protection December 1985 Power ascension program acceleration
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January 1986 Fire protection, licensing status, new NRR organization, PVORT, and SQRT audit at Sargent and Lundy February 1986 Safe shutdown analyses March 1986 Readiness to load fuel June 1986 SQRT documentation July 1986 Readiness to load-fuel NRR Site Visits and Audits l
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September 1985 Fire Protection audit November 1985
- DCRDR audit October 1985 Power Systems Branch audit November 1985-Second PVORT audit December'1985 Reviewer observed Emergency Preparedness Drill December 1985 SALP & discussion ~of licensing issues May 1986 Readiness to load fuel meeting with Region III
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June 1986 Security Confirmatory Site Visit (NMSS)
June 1986 Site visit to assess fuel load readiness July 1986 NRR management site visit July 1986 Control. room HVAC air balancing August 1986 Walkdown of plant systems Commission Briefings May 1986 Informal briefing of Commissioner Zech by NRR prior to his site visit Safety' Evaluation Supplements January 1986 Supplement No. 5 July 1986 Supplement No. 6 Exemptions Authorized in Low Power License September 1986 Nine schedular exemptions from-preoperational tests until after issuance of a low power license (July 1986 - SSER6)
September 1986 Two exemptions from the requirements of Appendix J (July 1986 - SSER6)
Licensee Amendment Issues None NRR/ Licensee Conferences
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March 1986 Licensee management meeting with the Director of NRR I
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