IR 05000461/1986023
| ML20211E819 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/05/1986 |
| From: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211E811 | List: |
| References | |
| TASK-2.B.4, TASK-TM 50-461-86-23, NUDOCS 8606160274 | |
| Download: ML20211E819 (38) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-461/8E023(DRP)
Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 l
Facility Name: Clinton Power Station l
Inspcction At: Clinton Site, Clinton, IL Inspection Conducted: April 8 through May 12, 1986 Inspectors: T. P. Gwynn P. L. Hiland D. L. Summers RFLd w"h W Approved By: R. C. Knop, Chief Projects Section IB kTf5 Date Inspection Summary Inspection on April 8 through Pay 12, 1986 (Report No. 50-461/86023(DRP))
hreas Inspected: Routir,e safety inspection by two resident inspectors and one E6&G Idaho contract inspector of preoperational testing and operational preparedness activities including applicant action cn previous inspection findings; IE Circular followup; review of construction deficiency report; applicant action on Three Mile Island Action Plan Requirements; employee concerns; review of allegations; functional or program areas (including site surveillance tours, operating prccedures review, and safety committee activity); independent inspection effort (including plant maintenance contractor impleuentation of IPQA program, review of diesel generator modification, Part 21 reporting - Baldwin Associates procured equipment, Safeteam processing of wrongdoing allegations, and review of IPQA audit results); and site activities of interest.
Results: Of the 15 areas inspected, one violation with four examples and two unresolved items were identificd. The violation (paragraphs 2.c. and 9.a.) related to the failure of IP maintenance personnel and Stone & Webster contract maintenance personnel to follow procedures and instructions in the performance of safety-related maintenance activities. No specific safety-significant deficiencies were identified durirg the course of this inspection resultir.g frcn the failure to follow procedures; hewever, the potential for a safety-significant problem to occur is increased when personnel do not follcu instructions, procedures, and drawing MG b I
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1. Personnel Contacted Illinois Power Ccmpany (IP)
- G. Bell, Special Assistant to the Manager - Scheduling and Outage Management
- J. Brownell, Licensing Specialist, Licensing and Safety
+*W. Connell, Manager - QA
+*W. Gerstner, Executive Vice President
+*J. Greene, Manager - Startup (SU)
- K. Graf, Director - Operational Monitoring
+*D. Hall, Vice President, Nuclear
+*H. Lane, Manager, Scheduling and Outage Management
- J. Loomis, Construction Manager
+*J. Perry, Manager - Project Control Center 4*R. Schaller, Director - Nuclear Training
+*D. Shelton, Manager - NSED
- J. Skov, Supervisor - Commitraents, Nuclear Planning and Support
+*F. Spangenberg, Manager - L&S
- J. Weaver, Director - Licensing
+*J. Wilson, Manager - CPS Soyland/Wipco
+*J. Greenwood, Manager - Pcwer Supply U.S. NRC Region III
+ B. Davis, Deputy Regional Administrator
+*T. Gwynn, Senior Resident Inspector - Operations
- P. Hiland, Resident Inspector
+ R. Knep, Chief, Projects Section IB
+ C. Norelius, Director, Division of Reactor Projects The inspectors also contacted and interviewed other staff and contractor personne * Denotes those attending the monthly exit meeting on May 12, 1986.
+ Denotes those attending the raanagement meeting on May 1,158 . @plicantActionOnPreviousInspectionFindines(92701/92702) (Closed) Open Item (461/85015-11): The inspector identified a discrepancy between the applicant's draft technical specifications and applicable standaros of the Institute of Electrical and Ehctronic Engineers (IEEE) concerning surveillance frequencies for the Clinton Power Station (CPS) safety-related batteries. This discrepancy was discussed between the inspector, the applicant, and the NRC Office of Nuclear Reactor Regulation (NRP) Licensing Project
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, w egy 3ym, ;,y mw n-Manager. The applicant agreed to revise the CPS Final Safety Analysis Report (FSAR) and comit to IEEE 450-1980 and IEEE 308-1980 s to maintain consistency between the CPS technical specifications and applicable standard The applicant presented this item to the inspector for closur This item was previously reviewed for closure in inspecticn report 50-461/06017, peragraph 2.i. The applicant's review of this item determined that a change to the technical specification bases to reference IEEE 450-1975 (the standard the applicant is committed to p meet in the CPS FSAR) was the best apprcach to resolution of the L discrepancy rather than their earlier plan to commit to 1980 standard In addition, the CPS FSAR was changed to take exception to the IEEE 450-1975 surveillance frequency for battery specific gravities and cell voltage readings. The change was included in amendment 37 of the CPS FSAR and verified by the applicant to be acceptable to NR I The inspector reviewed the change to the CPS technical specification bases and the change to the CPS FSAR to verify that the discrepancy had been resolved. This matter is closed. (Closed) Open Item (461/86008-04): Documentation of an evaluation (86RE01: Failure of Division I Diesel Generator to Meet Starting I Criteria) performed under 10 CFR 50.55(e) to determine the safety significance of diesel generator performance discrepancies did rot appear to meet the criteria of the regulation, as follows:
(1) The evaluation did not state whether or not the condition identified represented a deficiency in design and constructio (2) The evaluation appeared to be based in large part on the system response in the "as modified" condition. The regulaticn required that the condition be evaluated were it to have remained uncorrecte (3) The evaluation was based cn test results obtained in the system normal operating acde. The regulation required that the condition be evaluated in all allowable operating mcdes (i.e.,
at any time throughout the expected lifetime of the plant).
The applicant agreed that the documentation of the evaluation could cause confusion and agreed to have the evaluation rewritte The applicant provided a rewritten version of the deficiency referral evaluation (86RE01) to the inspector for review. The applicant's rewritten evaluation addressed the three criteria previously missing in their evaluation. Their evaluation concluded that the identified deviations frcm design requirements would not have resulted in a condition adverse to the safety of operations of the Clinten Pcwer Station had the deficiency gone uncorrected and that the matter was not reportable under 10 CFR 50.55(e). The
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l inspector concluded that the applicant's evaluation prcvided a reasonable basis for their determination of non-reportability. See paragraph 9.b. for additional details concerning the failure of the Division I diesel generator to meet starting criteria. This item is close c. (0 pen) Open Item (461/85005-41): Verify installation of loss of voltage alarms prior to fuel load (Safety Evaluation Report Supplcment 2, paragraph 7.4.3.2).
The applicant presented this item to the inspector for closur The applicant cornitted to provide loss of voltage alarms for five 120VAC instrument power supplies whose failure would necessitate reliance on emergency procedures to achieve cold shutdcwn (reference 1 IE Eulletin 79-27). Those instrument pcwer supplies were located l in the following switchgear:
(1) Control Buildir:g Motor Control Center (CBMCC) (2) CBMCC (3) CEMCC F (4) CBMCC E (5) Turbine Building hCC 1 The applicant providcd documentation which stated "The attached docun.entation provides verification that the field work to install and functionally test the alarm points and annunciator has been completed". Documentation referenced included the following:
- Memo Y-70692, dated December 20, 198 * NWR [ Maintenance Work Request] B2786 * SSER 2, Section 7.4. * STAF [Startup Test Authorization Form] 85-10 Review of the above documentation by the inspector revealed that testing to verify the functionality of the applicable annunciators had been conducted under STAF 85-102. The testing was not completed under that STAF due to twc deficiencies identified during the testing. The STAF stated "The two computer points that failed will be inspected, reworked, and tested by %k 004229". The two test deficiencies were doct.mented as f allows:
(1) L puter point 1AP-BC504 failed to actuat (2) Anriunciator window failed to actuate for CEMCC E .. _ _ _ _ _ _
l Review of MWR C04229, contained in the documentation package, revealed that the MWR was not applicable to STAF 85-102 and did not address the test deficiencie Review of FWR B27868, also contained in the documentation package, revealed that the MWR prcblen description addressed deficiency (1)
above (Computer point 1AP-BC504). However, the work performed under the MWR, as documented in the remcrks section of the EWR, did not address the problem described. In addition, post maintenance functional testing required by the khR jcb steps was not documented as having been perforned. CPS No. 1029.01, Preparation and Routing of Maintenance Work Requests, paragraph 8.2.15 states, " Repairman /
Technician Complete necessary maintenance"; paragraph 8.2.22 states in part " Repairman / Technician ..., notifies Maintenance Group Supervisor of completion of work and clearly describes all work performed on original MWR in encugh detail for machinery history";
paragraph 8.2.23 states in part * Foreman / Assistant Supervisor Review MWR for accuracy and completeness"; paragraph 8.2.24 states in part ' Maintenance Group Supervisor Evaluate the MWR for determination of root cause and adequacy of corrective action take Sign and date Block 62 shcwing ccapletion of the review and the requested maintenance". The tailure of the maintenance technician to follow the job steps and the failure of maintenance supervision to assure that the NKR was complete prior to closure is a violation of 10 CFR 50, Appendix B, Criterion V and the IP Operational Quality Assurance Manual, Chapter 5 (461/E6023-01A).
Based on the above results, the inspector concluded that the applicants' stctccent that "the attached documentation provides verification that the field work to install and functicrally test the alarn points and annunciator has been ccmpleted" was inaccurate in that there was no objective evidence in the documentation provided to demonstrate that the deficiencies identified under STAF C5-102 had been corrected and that the ccn.puter point and annunciator had been tested satisfactoril This motter was the subject of discussion between the inspector, Region III managcrent, and the applicant both during the course of the inspection and during a management meeting held at the Clinton Visitors Ccnter on May 1, 1986 (see paragraph 10.b. of this report).
The applicant indicated that actions were being taken to assure the integrity of information provided to the NRC as the basis for closure of NRC open, unresolved, and enforcement items. The applicant requested that Region III stop the review of information previously provided for closure of open, unresolved, and enforcement items pending conpletion of corrective actions. In addition, the applicant stated that a docketed letter addressing the adequacy of information provided for closure of these items would be provided
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by hay 15, 198 (0 pen) Open Item (461/84030-03): Final reports submitted by the applicant under 10 CFR 50.55(e) did not indicate that all corrective
M'M M WJd E actions were complete. The inspector was concerned that the applicant had provided no docketed basis for assurance that safety significant deficiencies reported under 10 CFR 50.55(e) had been correcte The inspector observed that a recent IPQA audit finding (Audit Report Q38-86-13, audit findings 10-1 through 10-4 dated February 11,1986) had identified a reportable deficiency (refer to construction deficiency report 55-80-10 (461/80010-EE), final report docketed by IP letter U-0192 dated October E4,1980) which had been closed on the docket by both the applicant and the NRC for which corrective actions were inccmplete. Because IP has not provided written information indicating that corrective actions have been ccrrpleted for a number of reportable deficiencies, the inspector discussed this matter with the applicant at length. The applicant proposed to perform a 25% sample of all reportable deficiencies in order to assure that corrective actions were complete. The results of that sarapie would provide the basis for determining if additional reviews were required. The inspector questioned the use of a sampling plan where a high degree of assurance is needed (i.e., safety significant deficiencies were involved in each case). This matter was under IP management review and will be reviewed further in a subsequent inspection.
e. (Closed) Violation (461/86008-01): Illinois Power Corrpany (IP)
failed to assure that Stone and Webster (S&W) (the IP maintenance contractor) personnel performing activities affecting quality were properly traine Corrective actions taken by the applicant in response to the subject violation were documented in Inspection Report No. 50-461/86017, paragraph 2.L. During this report period, the applicant 1ormally responded in a timely manner to the violation and stated that full compliance would be achieved by April 18, 198 The inspector revicwed the status of training with the S&W Training Coordinator and confirrred that essentially all of the S&W craft had completed rcquired training as committea in the applicants respons During the initial inspection effort, the inspector identified two S&W manual laborers (working outside the protected area) that had not received required training ano several non-manual S&W personnel that had not completed required reading assignments. Both of these minor deficiencies were corrected during the inspectio The inspector reviewed the qualification and training matrices developed to provide training status to S&W job supervisors for use in the selection of personnel for specific tasks. In addition, the inspector interviewed four S8W Jcb supervisors and confirmed their awareness of the training natrices and awareness of their responsibility to assure only qualified personnel are assigned specific task .__--m Additional inspection of SD? maintenance activities is docuntnted in paragraph 9.a. of this report. This item is closed, (Closed) Unresolved item (461/86008-02): During the conduct of a routine plant tour the inspector reviewed a Stone & Webster (S&W)
Maintenance Work Request (MWR) being used in the field to perform work. It was not obvious that the S&W liaintenance Engineer had provided adequate job steps for the work in progres During this report period, the inspector performed a detailed inspection of S&W Maintenance activities. The results of that inspection are documented in paragraph'9.a. below. Based on the results contained therein, the inspector confirmed S&W MWRs had been adequately job stepped. This item is close One violation was identified in paragraph 2.c. above (additional exemples appear in paragraph 9.a. below).
3. IE Circular Followup (92701)
(Closed) IE Circular 80-05 (461/80005-CC): Emergency Diesel Generator Lubricating Oil Addition and Onsite Supply. This circular addressed an event identified at an operating nuclear station in which improper lubricating oil addition to an operating emergency diesel generator (EDG)
resulted in loss of the EDG when it was needed to perform its safety function. The event brcught to light an additional problem wherein the facility did not have a sufficient onsite supply of lubricating oil to allow the EDG to meet it's technical specificaticn cperability requirement The inspector verified that the applicant had received the circular; reviewed the circular for cpplicability to CPS; and had determined and carried out required corrective action The inspector reviewed the .
applicant's actions taken to respond to the recommended actions of the circular and found the following: The applicant's procedures for lubricating oil addition to the EDG had been evaluated and found to be adequate to provide for lubricating oil addition to the EDG while it is in operation. The precedure was available in the maintenance shop, adjacent to the ECG facilit The applicant's personnel had been trained in the proper method for adding lubricating oil to the EDG. I!owever, the inspector determined that the applicant had not demenstrated the ability to add oil to an cperating EDG as recommended by the circular. The applicant stated that, since the procedure for lubricating oil addition was the same whether the EDG is static or operating, the training was adequate to meet the reconnended action of the circular. The inspector requested and the applicant demonstrated the ability of maintenance personnel to add lubricating oil to the EDG while the machine was operating in the presence of the inspector
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on May 8, 1986. After the derrenstration, the inspector agreed that the training was adequate to meet the reccrm. ended action of the circular, The inspector identified during walkdown of the EDG's that the point for addition of lubricating oil was marked on the Divisions I and II EDG's but not on the Division III EDG. Additional identification markings were also missing from the Division III EDG. The applicant prcmptly provided the reccr,cended identification markin All other actions reccrreended by the circular had been adequately addressed by the applican This circular is close No violations or deviations were identifie . Review of Ccnstruction Deficiency Report (92700)
(Closed) Construction Deficiency Report 55-84-13 (461/84013-EE): On June 7, ISE4, the applicant notified NRC, Region III by telephone of a potentially reportable deficiency involving the suppression pool (SPTM) system. The placement of resistance terrperaturedetectors temperature monitoring (RTDs) within the suppression pool was such that the safety-related RTDs used by plant operators to monitor the suppression pool bulk temperature could beccme uncovered during certain postulated accident scenarios, resulting in potentially erroneous indication of suppression pool bulk temperature. The concern was that operator actions to assure containment integrity could potentially be delayed resulting in damage to the containment structur The applicant's final report on this matter, dated April 15, 1985, conc uded on the basis of their investigation that even though the SPTM RTDs could becor:e uncovered during certain postulated accident scenarios, the integrity of the CPS containment would not be adversely d f fec te The inspector reviewed the results of the applicant's investigation and detailed calculations used to support the applicant's result The dssumptions used in the calculation and the calculational results provided a sound basis for the applicant's determination that this was not a safety significant deficiency. The calculations showed that, even if the SPTM RTDs were uncovered during the worst case accident scenario, the actions recuired of the control roon operators would be initiated on the basis of other considerations prior to the bulk temperature of the suppression prol exceeding its design basis for achieving cold shutdown of the reacto Notwithstanding the determination that this was not a safety significant deficiency, the tpplicant provided documentation which indicated that SPTM elements ITE-CN051, 052, 053, 054, 328, 329, 330, and 331 had been reworked to provide temperature monitoring in each suppression pool
quadrant at elevation 726'10" which is below the design minimum water level for the suppression pool. Operating and emergency precedures were revised to alert the operator to the need to monitor the lower temperature elements in the ever.t that suppression pool level falls belcw the level of the bulk temperature sensors. The inspector verified that the procedure changes had been acccuplished. This matter is close No violations or deviations were identifie . Applicant Action on Three Mile Island (TMI) Action Plan Requirements (25401)
The NRC Office of Inspection and Enforcement issued Temporary Instruction (TI) 2514/01, Revision 2, dateo Decen,ter 15,1980, to supplement the Inspection and Enforcement Manual. The 11 provides TMI-related inspection requirements for operating license applicants during the phase between pre-licensing and licensing for full power operatio It is divided into two parts. Part I lists requirements that must be closed prior to fuel load. Part 2 lists requirements that must be closed prior to full power operation. Part 1 of the TI was used as the basis for inspection of the following TMI item found in NUREG-0737,
" Clarification of TMI Action Plan Requirements."
(Closed) Iter.. II.B.4.1: "Trainirj for Mitigating Core Damage." The applicant was to develop a traini.19 program prior to fuel load. The completion of training was to be accomplished prior to full power operatio The inspector discussed the Mitigating Reactor Core Damage (MRCD)
training program with ccgnizant personnel in the applicants' training department. The inspector confirmed that the training program did exist as described in Section 13.2 of the Clinton FSAR. In addition, the inspector reviewed the training records for "liccr. sed operators" and confirmed that successful completion of the MRCD course was a prerequisite to their license applicatio The inspector confirmed that part 1 of this TMI action ittm was complet The only remaining action required prior to full power operation was completion of MRCD training for the Power Plant Panager and specific topical training for non-licensed technicians (II.B.4.E).
No violatiens or deviations were identifie . Employee Concerns (99014)
The inspectors reviewed concerns expressed by site personnel from tirie to time throughout the inspection period. Those concerns related to regulated activities were documented by the inspectors and submitted to Region II Four concerns were transnitted to the regicnal cffice during this report period.
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In additice to ti t i t. o r concerns trai13 rail.ted w f a c r r III. the inspector i
received a visit frem a O to er..p l uj ee on April 17, 196t, echttroing the ~
handlirt ti r e c . cac t i ve Ir,ater lai uns i te . II.t ir cis idt:el described a job :
he had perforrred c r / I r ' ., l'lt that resul tec in tra:isl er e t several - -
cra e .e a Ct . .) t r cn. a storage lutatiuo : n '.t.t [l rt te an installed i
location in the plir t . The job was per torir.ed under thc r..olu tenance work request rectrcn i t.t ir.cividual stateu thet, tutsrcuert to transfer of the material, he bad trccr( owore that the material inside ti t crctes was .
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identi'ico os Leir.9 raciuactive fauterial . l ht ir cividuel stated that he had not been provided ar) ric ction worker training prior to pei t trT ing ..
the + rci. i t r tc38 cnc hao not been wearig iadirtier exposure dosimetry ?!
at the time he perfere c e the tas The incividual statet that tt hcd apprm we J t if raciation protettion uepa '.rert erd reauested a whole .
body count to deterrrire +h rid.a iun exposure he receive If declined 1 to t r ' fc m , ;Le whute body coun '
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The insps + or r t served the installed equ rer r.t ci c r.c teo tha t the i
lijdteria ls lla c '.M d Consisted of a bottom entry dis rosal cask , a push -
'71 ca rt , arid a < <e' ' r < 'i.ted pieces of equiptrert . The tcsk was taggea . .l
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icent113 iq, it e re f erial as depleted urarit r c:ir > ic The tag further *
10en t111eu tha t ti; tie wic rc cetectable surface cont ar ir.ct itt: anc icent . ; m' 4 u ntact radiation dese rcte c' le ss than U.2 m1iilreir. per - -
hour (n.k/ nr ) except a t the u d '"r
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vticF read 1.0 mP/hr. The tee was - - -
outeo April 1b, 196 The 1- 4 e c * r. r well,rd the path taken during il e r,cter 1ol transter with ,
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- the inoivicua l ario eistttsed the need for whole body cctrtir g with hirn
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The .noisido rrrrested that the insped o res,tw the si tuation to determine the rec.c.io egosure he had received ir rct ing the trates ,
alld cui i) . The it.y t ( t cr acreed to respond tn the :nd.sicua lhe '
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inspettta interred the individual that a wtrlr bcdj tuunt woulo not be dble tu celect lits e/[( 't.rr tr irrizino radiation unlesi tu.tcil.lncllen ,
was involve Contar ira ticr was not involve The ir_>t<toi t,u t 1 L i t n e t the appiicarit t or.ct t r 4rr this iratte ..
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Discus 5 4 rnb 'h the '. ite Fresident - Nuciear incitered that the ^ r applicant was man ( the I, c t t e r , that a speciai grtu; c' *hrer .
r r r pa ce r epresentatives (cens ist;ry c f two special assistarts tc
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+tf Vice President and the ct rperu tt i t c i th phy s i c i s t ) hcd a i r n c:,
!(en ossigned tu i r depe nce n t i., rtsiew tho circumstances surrcurrir c -
't, irri srt; and that the incident v.st 1raclvea the transter u; une u n llTdd ld teo (r dr.s k t! s . I ' A hWe prnhe (IIP) detecto Ih I!I ceto < r r taired a cuaritity of specie' L t. t i t c r n ater 1a l teoricheu u r en 1oir.) tha t wa s e> ei. p i l i ti- *It
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- r,+er'e' ~1 The inspector #ol'uted the pr u3rc5s of the app ~iitant ir u [r r errt revirv +ea t h oughout the inspection perit it S conclusion of the 1
inspection. the app!i ta u; cttut tc : tiease their i t<[rrt rr tt< iri . cen ; h i s raa t te r 13 on opei , L ti ; e: di: , rergipt and review -
rf +tr aprlicant's re g et, revitt t1 ar y necessar j turr u, i <. *'sr<
're e stusslun ut the resulta ut the ir gtt* ion of thi s ria tter wi th t Fr
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One Open Item requiring additional NRC review was identifie . Review of Allegations (99014) (Closed) Allegation (RIII-85-A-0111; No. 151): The NRC Resident Inspector at CPS received a letter on June 24, 1985 from a forner IP startup test engineer (individual A) alleging employrrent favoritism and questioning the adequacy of Heating, Ventilating, and Air Conditioning (HVAC) testing at CPS. That letter was also sent to the applican Review of the subject letter revealed five items of concern. Those concerns and the results of hhc review thereof were as follows:
Concern No._1 Individucl A processed some 500 Construction Work Requests (CWRs),
Maintenance Work Requests (MWRs), and Field Problem Reports (FPRs)
without having been certified under the applicant's progra NRC Review Interview of individual A's forrer supervisor indicated that Individual A worked onsite for approximately two months in the IP Startup grcup as a HVAC test engineer. During that period, Ir.dividual A was assigned responsibility for the Laboratory Ventilation (VL) systen, a nonsafety-related HVAC syste Individual A did initiate a number of controlled docurrents related to work perfortred on the VL system. The supervisor stated that each document processed by Individual A required supervisory oversight. In addition, the CA program provided other measures to assure the correctness of work performed under the documents issued by Individual A. Finally, the VL system was turned over to an experienced liVAC startup engineer when Individual A was terminated. That engineer reviewed and, in many cases, repeated the work originally performed by Individual Interview of Individual A's former supervisor and several tonner cc-workers by the inspector and by the CPS Safeteam revealed that Individual A was a very kncwledgeable, corrpetent engineer who had very little experience in HVAC startup test programs and limited nuclear testing experience. Each of the individuals interviewed indicated that the problem IP experienced with Individual A was related to his inability to adjust to the need for procedural and program compliance during the performance of his work. The tcchnical and engineering capabilities of Individual A were never questione (Also, see Concern No. 2.)
Results This concern was substantiated; however,the work docunents initiated by Individual A were subject to supervisory oversight. The technical Cdpabilities of Individual A were not in question. In addition,
lERYN l the assigned system, which was not safety-related, was reassigned to a qualified, experienced startup test engineer who subsequently reviewed and, in some cases, repeated the work performed by Individual A. This concern is close _Ccncern No. 2 A startup test engineer who had been certified for six months
stated that Individual A " knew the procedures better than he did".
Individual A was subsequcntly terminated for failure to make j sufficient progress tcward certification. This indicated a potential for unc,ualified startup engineers.
i NRC Review E The specific startup test engineer referred to was not identifie The hRC had previously reviewed the IP Startup program for
[ qualification and certification of test personnel (reference NRC Inspection Report No. 50-461/E4020, paragraph 3) and found the progrum to be adequat Interview of Individual A's fonner supervisor revealed that Individual A had been given the necessary materials to qualify under the IP Startup program; that Irdividual A had completed all required reading signoff sheets and presented himself to the supervisor for certification in an unusually short period of time (approximately 2 days); that interviews of Individual A conducted by the supervisor prior to certification examinaticn cn three occasions indicated that Individual A had not achieved a detailed working knowledge of the IP Startup Program and procedures necessary
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for independent performance of work; and that the work performance of Individual A had been less than adequate. The. supervisor stated that the time required to achieve certification varied depending upon the level of capability of Individuals hire For an inexperienced engineer who had just graduated from college, a period of 1 to 2 years would be required to achieve certificatio For an experienced startup test engineer, the time required to achieve certification was normally six to eight weeks. Individual A was hired thrcugh a contract organization as an experienced startup test engineer. The supervisor admitted that Individual, A's resume indicated a lack of pertinent nuclear startup experience; the supervisor stated that Individual A was hired primarily on the basis of a personal reccurendation. The supervisor stated that Individual A did rot perform his work in accordance with startup procecures and that his performance was thercby unacceptabl The inspector intervicwed the startup engineer who was assigned responsibility for the VL system af ter Individual A was terminate That interview revealed that the VL system had not been properly scoped for Checkout and Initial Operation (C&IO) testing prior to his assuming system responsibility. The startup test engineer stated that the scoping package he received frcm Individual A
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package did l consisted not meet theofrequirements approximately sixapplicable of the pages; that the scoping (Startup procedure I Administrative Instruction (SAI) -6, Prerequisite Checkout and '
Initial Operation Testir.9); that it had taken him approximately one week to repeat the work under SAI-6; and that the final scoping package consisted of approximately 45 pages of test requirements.
The inspector questioned the startup test engineer concerning the work of Individual A. The startup test engineer stated that he had not known Individual A but, based on the status of the VL systera when he was assigned respcnsibility for it, the work perforn.ed by Individual A indicated a lack of knowledge of startup test program requirements.
kesults This concern was not substantiated. The inspector was not able to determine the identity of the test engineer who made the statement referred to by Individual Interview results indicated that Individual A was not kncwledgeable of startup test program procedarcs us evidenced by his work performance and the results of pre-certification oral examinations. This concern is closed.
Concern No. 3 Individual A questioned the adequacy of indoctrination training for new startup test engincers. Individual A was concerned that he had not been provided a tour of the systens he was to wcrk with or even an introductory talk as to what was going on. In addition, Individual A was concerned that he was never given a more experienced engineer to help hin learn the progra .
NRC Review Startup Administrative Procedure (SAP) - 7, Certification of Startup Personnel provided the requirements for the indoctrination, training, and certification of Startup Test Engineers and lechnicians. The inspector noted that the precedure required a minimum of two hours of docurented indoctrination training, including plant layout, arcanizction, udrainistration, and related job aspects for startup test technicians. That training was not required for startup test engineers.
The inspector interviewed Individual A's fourer supervisor and a startup test engineer regarding this concern. The interviews revealed that inexperienced startup test engineers werk under the direction of certified test personnel during their training period but that experienced startup test engineers are expected to utilize drewings, specifications, and their cwn experience to familiarize themselves with the requircments of the job. Generally speaking, experienced certified test engineers are available to answer questions and assist during the initial indoctrination period for I
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newly hired experienced startup test engineers. The startup test
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engineer intcrviewed indicated that he was not provided a tour of
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the facility or briefed on the organization, administration, and status of systems assigned to him when he was hired; he learned the program throagh self-study and by interf acing with other certificd
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personnel and his supervisor. The engineer indicated that he used applicable drawings, specificetions, and personal walkdown of assigned systems to familierize himself with the job requircments prior to certification. The engineer indicated that it required approximately six to eight weeks to complete his training prior to certification, lie indicated that it would be physically impossible to complete all required reading and to achieve an understanding of the IP Startup Progran in two day Results The NRC inspectur determined the adequacy of the indoctrination training of new startup test engineers was dependent on the new individual since it is self-study on-the-job training. The IP Startup Program for qualification of startup test personnel had previously been reviewed and accepted by the hRC. The requirements applicable to startup test engineers did not include specific indoctrination training or a plant tour prior to certification; that portion of the certification process was to be performed on a self-study basis. Individual A completed that process in an abnormally short time frame (two days as conpared to the normal self-study time of six to eight weeks) and was rot able to successfully complete a pre-certification oral examination given by his supervisor on thiee separate occasions.. This concern is close Concern No. 4 Lack of programmatically specified test requirements for checkout of heating, ventilating, and air cer.ditioning (HVAC) systems equipmen hRC Review The IP Startup Manual, SAI-6, Prerequisite Checkout and Initial Operation Testing, provided the requirements for checkout of HVAC system equipment prior to the performance of preoperational/
acceptance testin The inspector interviewed the startup engineer who was assigned responsibility for the VL system after Individual A was terminate That interview revealed that the VL system had not been properly scoped for checkout and initial operation (CLIO) testing prior to his assuming system responsibility. The startup test engineer stated that the scoping package he received from Individual A consisted of approximately six pages; that the scoping package did not meet the requirements of SAI-6; that it had taken him approximately one week to repeat T.he work required under SAI-6; and that the final scoping package for the VL system consisted of approximately 45 pages of test requi remen ts. The inspector questioned the startup test engineer concerning the work of Individual A. The startup test engineer i stated that he had not kncwn individual A but, based on the
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status of the VL system when he was assigned responsibility for it, the work performed by Individual A indicated a lack of kncwledge of startup test program requirement _Resul ts This concern was not substantiated. The IP Startup Program provided requirements for checkout of HVAC system equipment prior to preoperational/ acceptance testing. Individual A apparently had not corplied with the program requirements during initial scoping of the VL system, indicating a lack of knowledge of program requirements. This concern is close Concern No. 5 Individual A was concerned that another individual who worked for his former supervisor had not been properly treated. Individual A implied that both Individual B and he had not been treated fairly by supervision because they both worked for the same contract ccrrpan NRC Review Interview of the supervisor revealed that Individual B left his employment at CPS of his own volition. The supervisor denied any
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" favoritism" toward any particular contract company. In particular, the supervisor stated that he had found it necessary to terminate Individual A due to failure to certify in the allotted time frame; the supervisor also indicated that Individual A had limited nuclear startup testing experience, did not appreciate the need to follow approved procedures, and as a result provided a product that was not'always acceptable. The supervisor indicated that several well qualified people from the same contract company were still working in the startup HVAC group under his supervisio Results This concern was not substantiated. There was no indication of any direct or indirect ccnnection between the resignation of Individual B and the termination of Individual A. In additicn, the supervisor still employs several contract personnel including individuals employed by the same company that employed Individual This concern is closed. (Closed) Allegation (RIII-86-A-0030; No. 182): On February 21, 1986, a former contracter employee alleged that Baldwin Associates (BA), the CPS construction contractor, was destroying original quality control inspection documents. The individual provided pieces of three complete pages from two original BA Technical Services (TS)
inspection report The Clinton resident inspector promptly contacted the IP Manager -
Quality Assurance and requested that IP determine if documents were being improperly destroye _ _ __
NRC Review _
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Since this matter had been brcught to the attention of IPQA by the resident inspector, IP had prepared an investigation file related to this allegation. A similar concern involving six additional examples of torn up original quality documents had been brought to the attention of the CPS Safeteam at about the scme time as this allegation. The inspector reviewed the IP (allegation file No. 650)
and Safeteam (concern No. 12663) investigation reports. Those reports determined that the dccuments found in the trash had been destroyed by EA TS personnel at the direction of the Manager - T Each of the documents presented to the Safeteam had been verified
, to have a true and correct copy in the CPS records vault or were not rcquired to be retained since the components had been removed from the plant (rip outs).
The inspector interviewed the BA Manager - TS who stated that approximately two file drawers of original documents had accumulated in the BA TS area during the course of construction. These documents (primarily reports of nondestructive examination (NDE) results) had either been misplaced, misfiled, or otherwise had not been imediately available when final record packages were sent through the review and approval process to the records storage facilit In many cases, a copy of the original document had been substituted for the original since it was not available. Since construction Wds essentially CCDplete and original documents still existed in the i TS files, the Mar,ager - TS assigned two of his senior technicians (an associate welding engineer and an NDE examiner) to review the
- documents and provide a disposition. The activity was carried cut in accordance with verbal instructions from the Manager - TS since written site procedures did not address the situation. The specific instructions used in this process were reviewed by the inspector and
were determined to be adequate to assure that either the original docurrent was transraitted to the records storage facility or a true and correct copy of original QA records was retained in the CPS
- records storage facility prior to destruction of the original document; that appropriate action had been taken on any deficiencies identified during the process; and that records persorr.el were cognizant of the TS action The inspector immediately interviewed the associate welding engineer to verify the accuracy of information presented. The inspector found that the instructions provided by management had been understood and carried cut during the review and destructicn proces .
The inspector verified that a true and correct copy of each of the documents provided by the alleger was available for revicw in the CPS records storage facility. The inspector noted that the documents were for nonsafety-related construction.
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On liarch 6,1986, the IP Manager - QA issued a memorandum to all site managers cn the subject of Quality Assurance Records. That memorandum drew management attention to the subject of decurent destruction, requesting that documents be discarded properly, and cautioned all personnel to assure that required records are properly vaultcd. In addition, the IP Supervisor - Nuclear Records initiated a change to CPS Records Management Stenaard 2.04, Records Turnover /
Transfer to provide documented instructions concerning the proper raethod for destruction of original doct.nentatio Results The concern was substantiated in that original QA documentation was being desteroyed. Hcwever, the destruction was centrolled in accordance with verbal instructions that provided assurance that the documents had been properly dispositioned prior to destructio Interviews of personnel and independent verification by the Safeteam and this inspector indicated that the process was adequately controlled. Instructions were prcmulgated to control future document destructio No violations or deviations were identifie (Closed) Allegation (RIII-85-A-0196; No. 181): (hote: This allegation was similar to one previously identified in RIII-85-A-0196-01/#174-01. A violation was issued as documented in Inspection Report No. 50-461/05063.) An individual alleged that a Baldwin Associates (BA) document control technician had been falsifying document control transmittals (at Q-3/DCC station)
for at least two weeks prior to being terminated. The ir.dividual expressed concern that falsification of document control trans-mittals could affect ongoing work perfcrmed using the affected documents.
i NRC Review
! The inspector interviewed the Baldwin Associates (BA) Assistant l Project Manager (APM), in order to determine the circumstances surrounding the termination of the document control technician During the course of this interview, the APM explained that he was made aware that a document control technician was violating personnel safety standards on the job site. Upon learnir.g of this, the APM contacted BA Safety and requested a review of the alleged safety violation. On February 13,1986, EA Safety discovered the document control technician using an electric space heater to cook soup and
- hot dogs. This cooking arrangement was set up at the field document l control station Q-3/DCC on the bottom shelf of a bookcase. It I appeared that the document control technician was cooking not only l for personal use, but was selling the cooked items to personnel working near the Q-3/DCC station.
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Upon confirmation of the above safety violation (cooking inside a document control station), the BA determined that this was a " Major Offense" which was defined as a " Violation of safety rules involving hazard to personnel and/or property". The document control technician was given a five day suspension with intent to discharg In addition to the safety violation which resulted in the termination, the inspector noted that on three previous occasions
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in the preceding 12 months personnel action was taken against the docuraent control technician for absenteeism and/or tardiness, one of which resulted in a two week suspensio On February 14, 1986, a different document control technician assigned to the Q-3/DCC station as a replac ment for the suspended / terminated dccument control technician, identified required document changes (postings) had not been performed even though the docun,ent change transmittal letters had been signed off as having the posting completed and returned to the Document Control Center. He reported this problem to his imediate supervisor. The supervisor then informed the Illinois Pcwer (IP) Supervisor - Document Control. The IP Supervisor, informed the IP Supervisor - Nuclear Records, of the proble The IP Supervisor - Nuclear Records directed that certain actions be performed to review the extent of the identified " failure to post" problem and directed corrective actions necessary to assure required postings were performed at the Q-3/DCC station. Details of the activities performed by the Document Control Center (DCC) were delineated in a mworandum dated February 17, 1986. This memorandum identified that a significant number of posting errors (240) existed at the Q-3/DCC station. In addition, the memorandum identified that all of these posting errors had occurred between February 3 and 12, 196 The inspector interviewed cognizant DCC personnel to ascertain the extent of the " failure to post" and the actions taken by DCC to correct the identified problem. Personrel interviewed included:
two Document Control Technicians (including the replacement docun,ent control technician), the BA Supervisor - Document Control, the IP Supervisor - Document Control, and the IP Director - Support Service The inspector noted through these intervicws that the identified posting problens were corrected on Saturday, February 15, 1986 by two document control technicians. It took about 8 man-heurs of work to correct the identified deficiencies. In addition, the inspector reviewed the actual transmittals and work packages that the suspended / terminated document control technician had left at the Q-3/DCC work statio Following discovery that a document control technician had been signing off transnittals prior to performing the required postings, DCC supervision increased its self-audit frequency to assure similar problems were not occurring at other document control station Self-audits performed at other DCC field stations included:
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l (1) 2/19/86 - reviewed drawings at BA start-up statio (2) 'c./21/06 - Supervisors instructed to review on a weekly !
basis transmittals sent to field station (3) 2/21/86 - reviewed LA reference library drawing (4) 2/28/86 - reviewed En.ergency Operations Facility (E0F)
drawing (5) 3/4/86 - reviewed Nuclear Station Engineering Department (NSED) librar (6) 3/11/86 - reviewed IP Maintenance document control statio The inspector discussed in detail the results of these self-audits with the responsible DCC supervisors and noted that uhile useful information was obtained through this self-audit process, no accept / reject criteria had been established. The inspector suggested that the DCC supervisors rcquest assistance in establishing a workable accept / reject criteria from the IP Supervisor-Audits. The inspector noted that the above self-audits and weekly supervisory reviews identified minor posting errors; however, no major deficiencies or " willful" procedural violations were identified except at the field document control station Q-3/DCC.
The inspector interviewed the IP Manager-Quality Assurance in order to ascertain what actions were taken by.IPQA to evaluate this apparent repetition of violation 50-461/85063-01. IPQA reviewed the actions taken by the IP Director-Support Services to correct the problem identified at the Q-3/DCC station to determine what effect the " failure to post" corrections had on quality and/or safety; and what was done by IP/BA to evaluate the extent of failure to post documents at other locations. The results of this review were documented by IPQA in memorandum C. E. Calhoun, Quality Projects Coordinator to R. E. Campbell, Director-Quality Systems and Audits, dated April 25, 1986.
Conclusion This allegation was partially substantiated in that the requirements of Caldwin Associates Procedure EAP 2.0.1, " Instructions for Maintaining Project Drawings," revision 2, paragraph 5.5 were not being properly implemented for change documents issued against a drawing.
The inspector reviewed the method being used by this particular document control technician to perform the assigned work activities.
The inspector was able to evaluate the work method based on documentation available and interviews with both supervisory personnel and peer group co-workers. The inspector concluded that, while a procedural violation did exist, there was no evidence to suggest deliberate falsification of c!uality record In addition to the documentation reviewed and interviews conducted, the inspector reviewed similar allegation findings reported in Inspection Report No. 50-461/85063 which resulted in a violation. The inspector
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concluded that the backlog of 8 man-hours worth of work effort, resulting from discrepancies accumulated over a two week period,
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was significantly different from the deliberate falsification of quality records reported in Inspection Report No. 50-461/8506 The inspector reviewed the IPQA memorandum (Calhoun to Campbell, dated April 24,1986) which documented the IPQA review of actions taken by the Director - Support Services in responding to the identified deficiencies at the Q-3/DCC station. The IPQA review stated that no irapact on quality and/or safety existed due to this
" failure to post" since the time frame involved was short (two weeks) and the procedures allow up to 25 work days to complete posting. In addition, the IPQA review stated that an inspection er related event would cause a review of the DCC computer system to verify accuracy of reference documents. The inspector concluded that, based on ongoing applicant surveillances and inspection programs, the above conclusion was correc IP's review to evaluate the extent of " failure to post" at other locations determined that this was an isolated instance. The inspector reviewed the results of the IP self-audits and concurred that this appeared to be an isolated exampl Since the applicant identified the discrepancies at the Q-3/DCC station; the identified violation of procedural requirements fits into a Severity Level IV or V; reportability was not required; it was corrected and measures to prevent recurrence were performed in a reasonable time; and the " failure to post", in this particular instance, would not have been prevented by the applicants corrective action taken in response to a similar incident (Ref: Inspection Report No. 50-461/850C3), a citation was not warrante No violations or deviations were identifie . Functional or Program Areas Inspected Site Surveillance Tours (71302/60501)
At periodic intervals throughout the report period, surveillance tours of selected areas of the site were performed. Those surveillances were intended to assess: cleanliness of the site; i storage and maintenance conditions of plant equipment and material; l potential for fire or other hazards which might have a deleterious effect on personnel or equiprent; storage conditions of new fuel;
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[ and to witness maintenance and preoperaticnal testing activities
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in progres The inspector identified a change in the applicant's security plan for storage of new fuel. This change was subsequently reviewed by
- Region III, Division of Radiation Safety and Safeguards (DRSS) and l found to be acceptable. The applicant reported the noted change in their security plan per the requirements of 10 CFR 50.54(p).
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i The inspector comenced bi-weekly tours of the plant with the applicant's Supervisor - Quality Operations and Maintenance. The purpose of these tours was to assure that the inspectors and the applicant's Quality department were viewing conditions in the plant with the same frame of reference. The inspector noted an increased level of effort on the applicant's part to upgrade both the access controls ard cleanliness levels throughout the plan No violations or deviations were identifie Operating Procedures Review (42450)
This inspection contir.ued a review of procedures to be used in the plant operations phase (Ref. IR 461/86017). The purpose of this inspecticn was to confirm that the plant operating procedures are prepared to adequately control safety-related operations within applicable regulatory requirement (1) Completed Review
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The procedures listed below have been reviewed and appeared to
- be technically adequate. Coments discussed with the applicant were either already addressed in the applicant's procedure review program or responses to the inspectors question resolved the comen Procedure Revision Title (a 1405.02 0 LC0 Manual Tracking (b 3313.01 3 LPCS (c) 3314.01 2 Standby Liquid Control (d) 9012.01 20 Scram Disch. Vol. Vent &
Drain Valve Op Test (e) 9051.01 20 HPCS Sys. Purrp O (f) 9052.01 21 LPCS Operability Checks (g) 9092.01 20 Inclined Fuel Xfer Sys. Interlocks Func (2) Discussion
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At the conclusion of this inspection period, review of 18 remaining procedures (ref. IR 461/86017) was still in progres Results of this review will be documented in a subsequent inspection repor No violations or deviations were identifie c. Safety Committee Activity (40301)
The inspector attended and observed treetings of the CPS Facility Review Group (FRG), the onsite safety review committee, to observe the conduct of the committee; to verify that the FRG activities were l 21
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being carried out in accordance with the FRG charter, written FRG procedures, and the draft CPS technical specifications; and to verify that the FRG activities were focussed on plant operational safet The inspector observed FRG meetings held on April 23, 25, and 28, 1986. Each meeting was preceded by distribution of materials to be reviewed during the meeting, such as plant procedures, reports of conditions adverse to quality, plant modification packages, and safety evaluations for plant procedures and modification Observation of the comittee's activities showed that the meetings were conducted in accordance with the FRG charter and applicable procedures; that the committee properly focussed it's attention to matters of plant operational safety; and that meeting minutes were duly recorded by a representative of the plant staff compliance grou The inspector observed that the current workload of the FRG was heavy. That condition was not unusual at the current stage in plant life. The inspector observed that the FRG members were familiar with the documents under review and that pertinent questions raised by the comittee and subsequent comittee discussion indicated a detailed review had been performed by the committee members. The inspector noted that FRG rreeting minutes had been backlogged and that actions were being taken, at the request of the off site review comittee, to upgrade the timeliness of issuance of those minutes. Overall, the FRG performance was considered to be very good for those activities observed by the inspecto No violations or deviations were identifie . Independent Inspection Effort Plant Maintenance Contractor Implementation of IP QA Program (62700)
l (1) Introduction
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During this report period, the inspector conducted an j independent inspection of the maintenance activities performed l by Stone & Webster (S&W) as the maintenance contractor at the l Clinton Power Station. S&W has been working under the l applicant's Quality Assurance program and is contracted to i
provide rcutine and outage maintenance support to the plant I staff maintenance department.
! The objectives of this inspection were to evaluate the effectiveness of the maintenance program impleniented by S&W; to assure that the program was being implemented in accordance with applicable plant procedures; to evaluate the ability of
, the S&W staff; to confirm the corrective actions taken by the applicant in response to a recent violation (see paragraph 2.c
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above); and to follcwup an unresolved item concerning the ddequacy of Maintenance Work Request (MWR) job steppin performed by the S&W Maintenance Engineers (see paragraph above). The following paragraphs provide the details of this independent inspection.
(2) Details Since the Maintenance Contractor was working at the Clinton Pcwer Station under the applicant's quality assurance program, the same plant procedures applicable to the plant staff maintenance department were applicable to Stcne & Webste The primary procedure referenced during the conduct of this inspection was CPS No. 1029.01, Preparation and Routing of Maintenance Work Requests, revision 8. The following safety-related MWRs were selected as a representative sample of S&W's ongoing and completed maintenance activities:
- B-15517 *C-01C24 C-05301
- C-03116 **C-18215 *C-00071
- C-03118 **C-18218 B-36005
- B-17191 C-01745 C-05312
- B-24712 C-01873 C-05498 B-26660 C-01879 C-05683
- B-29178 C-02123 C-05805 B-31245 C-02169 C-05808
- B-31300 C-02211 C-05817
- B-31305 *C-02224 **C-05838 B-32590 C-02804 C-05923
- B-33323 C-02829 *C-06209 B-33931 C-02906 **C-06240
- B-35651 C-02928 *C-06814 C-00238 C-03982 **C-19163 C-00975 C-05024 The above listed MWRs were reviewed for one or more of the following attributes: job steps provided were adequate; cause of failure evaluated; reference material was controlled and kept up to date; pust maintenance testing was appropriate; inspection and hold poi',ts were identified in the procedure or in a documented plan; r ovisions for control of lifted leads was adequate; approval obtained from operations prior to ccimencing work; machinery history records were kept up to date and properly stored; measuring and test equipment was maintained in calibration; and required training completed for assigned S&W craf The above MWRs marked with a single asterisk (*) were subjected to a detailed review by an experienced contractor to the NRC who had perfont.ed similar inspections at four other nuclear plants in Region IV. The MWRs listed above with no asterisk were reviewed in somewhat less detail by the Clinton resident
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inspector usine the attributes above as the criteria for inspection. The MWRs marked with a double asterisk (**) were reviewed in the plant while work was in progres Pesponses to NRC questions asked during this inspection effort were documented in S&W correspondence RPR-140-86, S&W Resident Project Manager to IP Director of Outage Maintenance Suppor In general, the response provided answered the inspector's question. However, several questions required the applicant to provide additional information and/or documentatio (3) Results The inspector identified, and the applicant confirmed, that the Post Maintenance Test requirenents were in a dynamic state at the time of this inspection. The applicant had assigned
, personr.el from the operations department to review the Post Maintenance Test program and resolve outstanding issues. This subject was identified during another inspection effort this report period and was being tracked as unresolved item (461/86023-05) (see paragraph 9.e. below).
The inspector noted that QC inspection and hold points were documented in a separate plan identified as the Quality Control Inspection Plan (QCIP). Since the GCIP was a stand alone document, the inspector asked how S&W maintenance supervision knew that all inspection and hold points had been successfully completed prior to closure of the tiWR. By procedure, the foreman and supervisor's signatures in the last two sign-offs of an PWR indicated that all work was complete and the MWR was sent to the vault as a " closed" document. The response provideo indicated that S&W job supervisors do not track the QCIPs to final closure and that, as a separate plan, the QA department was responsible for tracking closure of the QCI The inspector discussed this item with the IP Supervisor -
Quality Operations & Maintenance and the IP Supervisor -
Maintenance Planning. These discussicns inoicated that the applicant was in the process of upgrading the interface between the MWR and the QCIP. It appeared to the inspector that actions planned by the applicant would result in an improvement i to the current interface. The inspector selected six specific
! MWRs (B-17191, B-29178, B-33323, B-35651, C-03116, and C-06209)
! and reviewed the associated QCIPs. No apparent deficiencies were identifie The inspector confirmed that the job steps for all the selected MWRs were adequate and provided sufficient detail to perform the maintenance activity. This review was the basis for closure of unresolved item (461/86008-02) in paragraph abov . -- .
The applicant generated several condition reports as a result of questions asked by the inspector during the conduct of this inspection. On May 2, 1986, the inspector identified two MWRs (B-25651 and C-05923) that had been designated as "Q" MWRs but were not reviewed by Quality Assurance upon ccmpletion of the work as required by CPS 1029.01, revision 8, paragraph 8.2.2 Both of these MWRs were signed off as complete and sent to the IP vault in violation of the precedure requirement (461/86023-018).
One FWR (C-03982) was identified on May 2,1986, by the inspector as having been closed and vculted with unauthorized work performe The job steps of this MWR specifically stated that the assigned craftsman was to troubleshoot and return the MWR to the Maintenance Engineer for further instruction The assigned craftsman, with the apparent approval of first line supervision, performed the troubleshooting and then performed necessary rework without routing the MWR back to the Maintenance Engineer in violation of the EUR requirements (4bl/E6023-01C). In addition, on May 2,1986, the inspector identified three MWRs (B-31300, B-31305, and C-05024) which required review by the ISI Repair Coordinator per the requirements of CPS 1029.01, revision 8, paragraph 8.2.1 These l'WRs had not been routed to the ISI Repair Coordinator for review (461/86023-01D). The above examples represent violations of 10 CFR 50, Appendix B, Criterion V and the IP Operational QA Manual, Chapter 5, which require that activities affecting quality be accomplished in accordance with written instructions, procedures, or drawings (461/86023-01).
One violation was identified (an additional example of this violation appears in paragraph 2.c. above).
b. Review of Diesel Generator Modification (71302)
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On January 29, 1986, the inspector learned of a modification performed on the Divisions I & II Emergency Diesel Generators (EDG's) which the applicant believed was required in order to achieve diesel response within the design basis (i.e., the ability to start the machine five consecutive times within the design basis start time without adding air to the diesel air start accumulator). The modifications n.ade were controversial in nature since similar EDGs used at other operating nuclear plants have met their preoperational test acceptance criteria without modification to the machine. This matter came to the attention of the inspector through a third party report of an incident in which the ECG vendor representative and an IP engineer exchanged words in a " heated" discussion in the Division I EDG room in ear ~y January. This matter was initially addressed ir. Inspection Report No. 50-461/86008, paragraph This inspection was undertaken to assure that the nature of the EDG deficiency was fully understood; that the vcndor representative was not inhibited from contacting the NRC concerning this matter; thht 25 ._ _ _ _,_
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k the corrective actions taken by the applicant were reasonable an ,
' based on good engineering judgement; and that the reliability and operability of _the Divisions I and II EDGs had not been adversely
, affected by the ncdificatio (1) Additional Documentation Reviewed i
i (a) IPQA investigation file No. 640: Diesel Generator Concern (b) Sargent & Lundy Engineering Design Criteria For Diesel j Generators, DC-DG-01-CP, revision 0 dated March 3,1976.
] (2) Discussion In late December 1985, the applicant identified problems concerning the ability of the division I & II EDGs to come up-to rated voltage and frequency within 10 seconds during five consecutive start attempts from a single air start reservoir
, (each machine was supplied with two trains of air start equipment including two air reservoirs). The problem was
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identified during checkout and initial operation (C&IO) testing of the EDGs. The specifics of the problem were documented in
Inspection Report 50-461/86008.
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' The inspector interviewed the EDG vendor representative, the fluclear Station Engineering Department (llSED) engineer, and
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the inoependent third party to the " heated" discussion that occurred in the Division I EDG rocm in early January 1986.
The inspector also reviewed the results of an IPQA investigation of the " heated" discussion. The discussion took
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place because of a difference of opinion between the NSED '
- engineer and the vendor representative concerning the cause
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of the EDG air start problem and the modification that IP
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performed to correct the problem. The inspector found no indication that either the heated discussion or subsequent discussions between the vendor representative and NSED
- personnel in any way inhibited the
- dClivity (i.e., Contacting the NRC) performance .
of representative The vendor a protected
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stated that if he had concerns about the safety of the facility he would not hesitate to contact the NRC. The vendor representative had been concerned that the nicdification performed by IP NSED had not considered all applicable components dcwnstream of the air start pressure regulator that was removed by the modification. In addition, the vendor representative remained concerned that the action of removing the air start regulator was only addressing a symptom of the real problem and not the problem itself. The vendor representative believed that the real problem with the EDG
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start time was related to the piping configuration (designed by Sargent & Lundy, the architect engineer for CPS) between
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two vendor supplied skids (the EDG skid and the air start accumulator skid) rather than with the vendor supplied
equipment.
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The inspector interviewed several individuals involved in the diesel generator modification process; performed a detailed review of records related to the modification; and discussed this review and its results with a technical specialist inspector in Region III. Some special testing had been performed to determine the need for the modification. The purpose of the test, performed in accordance with Assistance /
Information Request (AIR) No. 144 dated December 22, 1985, was to troubleshoot the Division I EbG to isolate the cause of excessive pressure drops in the air start system. The
" AIR" was carried out by IP Startup under the direction of the cognizant NSED engineer. The inspector noted that the " AIR" did not specify the test equipment to be used; that the documentation of the test method, test procedure, test equipment used, test results, and related information was informal; that there was no objective evidence of the control of a temporary modification installed to facilitate the test; that test equipment used during performance of the test was not apprcpriate to record the type of information recorded (i.e., peak transient air pressure felt at the air start motor during the air start transient); and that information was never recorded during the test to determine if the air pressure drcp was excessive across two suspect air start system components (the air pressure regulator or the piping interconnecting the vendor supplied air start skid and the diesel generator skid),
even though appropriate test-equipment was installed in the necessary locations and monitored before and after the air start transients. Because the information gained during this informal test program was not relied upon to support the modification (i.e., as part of the design basis), the informal nature of the test program did not represent a violation of regulatory requirement Mcwever, the inspector cautioned the applicant concerning the need for positive control over design-related activities performed by NSED and the need for formal documentation of test procedures and test results. In addition, this matter was discussed with the Vice President -
Nuclear during the exit meeting held on May 12, 1986.
At the inspector's request, the applicant provided evidence that the design review process for this EDG modification had considered all applicable components downstream of the air pressure regulator that was removed. The information provided consisted of telephone conversation memoranda (record of coordination), informal hand written notes, and unstatused letters from vendor representatives. That information indicated that all applicable ccmponents had been addressed from the standpcint of their ability to withstand the revised maximum air pressure applied during an EDG air start transient; that one component downstream of the air pressure regulator (EDG air start solenoid valve) had to be replaced as a result of the new design pressure; that the design review had been performed after installation of the modification and was
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completed on May 9, 1986; that the responsibility for the design of the EDG air start system had been transferred from the EDG vendor to the architect engineer; and that the EDG manufacturer and vendor had declined to concur in the modification even thcugh they were requested to do so by the applican The inspector questioned the NSED engineers concerning the original design purpose of the pressure regulators that were removed; the inspector wanted to determine if the purpose of the air pressure regulator was to limit the maximum air pressure applied to downstream components or to control the maximum torque applied to the diesel engine ring gear / flywheel by the air start notor. The inspector observed that the characteristics of the air start motor itself were such that the output torque of the motor varied directly with applied air pressure. Thus, depending upon the intent of the original design, the air pressure regulator may have been intended to limit the torque applied to EDG components (ring gear / flywheel assembly). The NSED engineers stated that they believed the original design purpose of the air pressure regulator was to limit the pressure felt by downstream components. The inspector observed that neither NSED nor S&L had direct access to the original design inputs. The inspector requested the applicant to verify that the purpose of the air pressure regulator was not to limit the torque applied to the EDG ring gear / flywheel assembly. The applicant contacted the supplier of the EDG air start motor and determined that the motor was supplied with an internal clutch assembly; that the clutch assembly was designcd to slip when the applied torque exceeded 250-300 foot-pounds; and that the action of the clutch would limit the torque applied regardless of the applied air pressure. The inspector agreed with the applicant's contention that the design of the air start motor itself could protect the EDG components but questicned whether that air start motor was in the original design basis for the EDG, The inspector cbserved that similar machines provide 1 to other facilities used air start motors provided by a different manufacturer and that, if the original purpose of the air pressure regulator was to limit the torque applied by the air start motor to EDG components, then the pressure regulator setpoint combined with the torque characteristics of the installed air start motor may have limited the applied torque to below 110 foot-pounds. The applicant stated that recent inspection of the EDG ring gear / flywheel assemblies for the Divisions I & II EDGs by NSED engineers did not indicate the application of excessive torque.
The inspector requested that the applicant confirm the original design purpose of the air pressure regulator was not to limit the torque applied by the air start motor or that the air start notor's operating characteristics (clutch limiting applied torque) were specifically designed for the application and were acceptable for its application. At the inspector's request,
the applicant agreed to confirm in writing that the design basis for the EDG air start system was not exceeded by the removal of the air start pressure regulator. This is an unresolved item pending receipt of additional information frcm the applicant (461/86023-03).
Discussion with the applicant's personnel indicated that, subsequent to the installation of the modification to the EDG air start system, a problem had been detected with the boost circuitry of the EDG governor. Subsequent to the correction of that problem, the Divisions 1 & II EDGs respo'nse time was substantially improved such that most EDG starts were completing in about 8-9 seconds and virtually all starts were completed in less than 10 seconds (the original design basis start time). This information indicated that the modification which was the subject of the " heated" discussion between the vendor representative and the hSED engineer may have been unnecessary.
(3) Results The inspector concluded that the vendor representative was not inhibited from bringing safety concerns to the NRC as a result of the " heated" discussion with the NSED enginee The inspector observed that the removal of the air pressure regulators from the EDG air start system may not have been necessary to allow the Divisions I & II EDGs to perform within their original design basis. Testing performed prior to the modification never determined the existence or location of excessive pressure drops in the EDG air start systen. Based on subsequent preoperational testing and surveillance testing of the EDGs which demonstrated their functionality and reliability, the inspector concluded that, except for the resolution of one unresolved item, the modification performed on the Divisions I & II EDGs to remove the air pressure regulators did not adversely affect the reliability or operability of the EDG .
The design review perfonned after installation of the modification determined that one additional component required replacement to maintain the qualification of the machine. The design review was performed by a substitute design organization which did not have direct access to the original design input The manufacturer and the supplier of the EDGs declined to concur in the modification performed by the applicant; the inspector requested that the applicant confirm the original design purpose of the air pressure regulator. This matter is an unresolved ite The inspector observed that the documentation of design related activities by hSED (verification testing and design reviews)
- were informal. This matter was discussed with the NSED Supervisor - Construction /Startup Engineering during the inspection and with the Vice President - Nuclear during the exit meeting on May 12, 1986.
One unresolved item related to the design function of an air pressure regulating valve in the diesel generator air start system was identified.
c. Part 21 Reporting - Baldwin Associates Procured Equipment (92700)
Review of IP referral 86RE06, Potential 10 CFR 21 Deficiency related to Anchor Darling check valves, revealed that the potential deficiency reported by Anchor Darling had been referred to IP by the NRC through the IP licensing representative in Washington D.C. This was not the programatically prescribed process for identification of potentially reportable issues. In this instance, Anchor Darling (the vendor) had provided a letter to BA on December 12, 1985. BA, the construction contractor, had procured valves for IP for installation at CPS. There was no indication as to why BA had not initiated the referral to IP on this matte The matter of 10 CFR 21 reporting for items procured by BA had been previously discussed with the applicant by a Region III specialist inspector. The concern related to the eventual breakup of BA upon completion of the construction project. The inspector wanted to know the programmatic approach IP intended to take to assure that future referrals under 10 CFR 21 continued to be received from vendors who were contracted through BA to supply safety-related equipment for Clinton Power Statio The inspector reviewed the above matters with the applicant's Licensing and Safety (L&S) department. The L&S representative determined the cause of BA's failure to provide IP a referral on the Anchor Darling letter and also verified that no additional letters were pending processing at BA. The Anchor Darling notification letter was referred to IP by BA on April 11, 1986. BA took prcmpt action to retrain personnel in order to preclude repetition of the problem. In addition, BA initiated letters to all suppliers on the BA historical approved supplier list directing that all future correspondence concerning 10 CFR 21 notifications be addressed directly to Illinois Power Company lianager of Quality Assurance at the Clinton Fcwer Station. Those letters were sent between April 23-25, 1986. This action should provide a future reporting mechanism when BA is no longer in existenc The inspector concluded that, while some weakness was apparent in the IP program for identifying, notifying, and evaluating 10 CFR 21 items, no actual prcblems were apparent; the one instance wherein BA had not provided the required notification had been identified by IP. IP's actions concerning future reporting for BA suppliers should preclude future problems. This matter is cicse No violations or deviations were identifie Safeteam Processing of Wrongdoing Allegations (92701)
Inspection report 50-461/86004 (page 9, paragraph c.) identified that the two programatically prescribed mechanisms for investigation of alleged wrongdoing had never been used by the Safeteam. Safeteam had investigated several potential wrongdoing concerns. During the inspection, the inspection team strongly recomended that the Safeteam change their approach to the investigation of alleged
- wrongdoing. In a letter dated March 14, 1986 from IP to Region III the Safeteam identified their approach to the investigation of wrongdoing concern During this inspection, the inspector provided a copy of the Safeteam wrongdoing procedure to Region III for review. That procedure was returned to the inspector with coments. The coments were discussed with the CPS Safeteam. Safeteam agreed to review the ccments and respond to'the inspector. Subsequent to that meeting, the applicant's Manager - Nuclear Program Coordination provided manascment resolution of the Region III coments. The resolution of coments was relayed to Region III. It was the opinion of the inspector that the Safeteam procedure for investigation of potential wrongdoing did not provide sufficient guidance in several area However, considering the nature of the CPS Safeteam activity, no additional action is required in this are i No violations or deviations were identifie e. Review of IPQA Audit Results (35741)
The inspector reviewed CPS Plant Staff responses to three audit findings and one concern contained in IFQA Audit Q38-86-10 dated March 18, 1986. Those audit findings, a sumary of the plant staff responses, and the results of this review were as follows:
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(1) Audit Finding ID-1: Required reading sheets could not be located to verify that current procedure revisions had been reviewed as they were issued. Twenty-five examples were delineated in the audit finding repor Plant Staff Response: Maintenance department review of the procedure cited by the IPQA auditor found no violation of the reference procedures. Some remedial corrective actions were cortaitted to be completed by April 30. No specific generic corrective action was comitte NRC Review: The primary procedure addressed by the audit finding was a plant staff administrative control procedure for qualification of maintenance department personnel. That procedure, CPS No. 1502.03, revision 2, was identified as a aonsafety-relateo procedure; was last revised in 1982; was out of date with regard to the current organization; and the procedure steps referenced by the IPQA Auditor as having been
-_ ._ .- - _ - _ - _ _ . -
i violated referred to a procedure which had been cancelled at some time in the past. The audit finding response provided-by plant staff should have addressed the procedure inadequacy as well as the failure to follow the procedur In addition, review of plant staff administrative procedures identified no programmatic controls to provide for training of plant staff personnel to significant procedure changes prior to implementation of the procedure. Thus the audit finding
, appeared to be indicative of a larger scope proble (2) Audit Finding ID-2: Work activities were completed withcut stopping to allow a QC inspector to accomplish predesignated inspections as identified by a QC hold point. Two specific examples were identified during the course of the audi NRC Reviews: The plant staff response adequately addresseo the narrow scope of the finding.
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(3) Audit Finding 10-3: Post Maintenance Testing (PMT) forms for three 01 three maintenance work requests (MWRs) reviewed by the audit team had not been attached to the MWR or were attached but had not been processed in accordance with the procedur The three MWRs reviewed were fiWRs written on systems that had been turned over from the Startup organization to the plant staff for operatio Plant Staff Response: The response to this audit finding acknowledged that the administrative controls for PMT had broken down. Remedial corrective action was stated as follows:
This condition existed due to the lack of clarification of PMT requirements and the flow path for PMT in CPS No. 1029.01, Revision 6. Revision 7 was scheduled to be issued in September 1985; however, it was not issued until February 1986. This would have prevented this problem from occurring. No action is required on the MWRs identified as the system is not operable and any problem which may occur when the system is in operation will result in the preparation of a new MW Genericcorrectivjactionwasstatedasfollows:
Revision 7 cf CPS No. 1029.01, Maintenance Work Requests, defines the primary responsibility for determining PMT as Operations. Maintenance may request to be present when PMT is performed but it is not required. The flow path for the PMT fann has also been more clearly defined in this revision. Maintenance feels that no further action is required on the findin __ _ __ -. - ~ _ ___
NRC Review: The plant staff response was limited in scope to the three specific MWRs identified by IPQA even though the auditor identified a 100% rejection rate for the MWRs selecte No substantive basis could be identified to support the contentions contained in the remedial corrective action statement. The response did not provide for confirmation of the plant staff contention that revision 7 to CPS No. 1029.01 had corrected the problem. Finally, the generic corrective action statement merely shuffled the problem off on the
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operations department without requiring an operations department respons (4) Audit Concern: The auditor identified a concern that did not require a formal response from plant staff. That concern was stated as follows:
Revised procedure for Maintenance Work Requests did not require signature of the Shift Supervisor ca MWRs imediately prior to performing the mainterane activit Approval is to be obtained verball NRC Review: The above concern was independently identified by the NRC as unresolved item (461/86017-04) which identified an apparent violation of ANSI N18.7-1976, paragraph 5. The above.results were discussed with the applicant's Audit Group Supervisor, the Supervisor - Plant Staff Compliance, the Manager - Quality Assurance, and the Manager - Clinton Power Station. The Manager - CPS agreed that the response to audit finding ID-1 concerning training to significant procedure changes required a generic response. He stated that CPS No. 1005.01 would be revised to provide an administrative mechanism by which necessary training would be determined and accomplished prior to release of the revised procedure for implementation. -In addition, to address the past inadequacies in the administrative controls, a special project was initiated as a joint venture between plant staff and the IP Training Department to provide necessary training to applicable personnel. This matter is open pending review of the precedure revision and verification of personnel training (461/86023-04).
In addition, the Manager - CPS agreed that the response to audit finding ID-3 was inadequate. He agreed to provide an additional response to IPQA to address both the adequacy of the current program and the actions necessary to verify the integrity of equipment for which significant maintenance actions had been performed under the deficient procedure while the equipment was within plant staff jurisdiction. That response was provided to IPQA in letter JWW-1195-86 dated May 2, 1986. This matter will remain as an unresolved item pending completion of necessary corrective acticns (461/86023-05).
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The inspector was concerned that the inadequate responses to audit findings ID-1 and ID-3 could be indicative of a more serious problem involving the interface between plant staff and the QA Departmen At the time of this inspection, the plant staff responses to ID-1 and ID-3 had been evaluated and accepted by the QA audit group. The IPQA audit group supervisor stated that the records would show that numerous plant staff responses had been rejected by IPQA for ,
inadequate response and that these two specific examples were not representative of a larger problem. The inspector requested to receive copies of all plant staff audit responses evaluated as acceptable by IPQA. The audit group supervisor began providing copies of the. requested responses during the inspection period. For the audit responses reviewed, the inspector identified no additional discrepancies. The inspector will continue to review a sample o plant staff responses to IPQA audit findings after the responses have been evaluated as acceptable by IPQ One unresolved item was identified concerning the adequacy of the PliT program. One open item was identified to track the completion
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of actions to upgrade control of training for significant changes
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to plant staff procedure . Site Activities of Interest 4 Fuel Load Schedule (94300)
On March 21, 1986, Illinois Power Cctrpany announced that the March 31, 1986 scheduled fuel load date for Clinton Pcwer Station would not be met. Due to additional testing that must be ccrrpleted prior to fuel load and due to scheduling difficulties, the applicant did not identify a new scheduled fuel load date. The applicant-believes that early to mid-July is a realistic time frame for a licensing decision. At the end of the inspection period, IP was preparing for the last major milestone prior to fuel load;
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performance of preoperational test procedure (PTP)-LE-01, Integrated
, ECCS/ Loss of Off Site Power Tes PTP-LE-01 was expected to begin
, about May 15, 198 _ Readiness For Fuel Load Meeting (30702)
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On May 1,1986, NRC Region III management met with IP management at the Clinton Pcwer Station Visitor Center to discuss the current state of readiness of CPS to load fuel. This was the fourth of a series of such meetings to be held with IP management on a routine (moithly) basis. Personnel attending the treeting are identified by (+) in paragraph 1 of this repor The meeting, which lasted about two hours, included the following:
(1) A short briefing by the Vice President - Nuclear concerning the status of the facility and actions being taken to address current problem _ . _ . _ . . - - . _ - . . _ - . . _ _ _ _ . _ _ . . - . _ . - _ _ _ _ _ . . _ _ . _ _ _ _ (2) Preoperational Test Program Statu (3) Test Deferral Reques (4) Status of the conduct of surveillance testing for credi (5) Plant procedure reviews in progres (6) Results of an IP Operational Readiness Assessr:en (7) CPS " Things" lis (8) Recent problem area (9) Upcoming management change (10) IPQA Operational Nonitoring Progra In addition, the Senior Resident Inspector - Operations (SRI-0)
discussed several matters of concern related to the need for increased procedure adherence by plant staff, increased attention to cetail, and the need to think in an operational rather than in a construction sense. Finally, the heed to increase the technical accuracy and completeness of information provided to close open, unresolved, and violation items was also discusse IP management acknowledged most of the concerns addressed by the SRI-0. The Vice President - Nuclear stated that IP had recognized the need to increase the emphasis in these areas some time ago; that progress hao been slow; and that continued emphasis would be given to the NRC concern .
Both Region III and IP management agreed to schedule the next monthly management meeting for June 10, 1986 in the Region III Office.
c. IP Management Changes (92701)
IP announced several upcoming management changes in support of the operation of the station. The current Manager- NSED, who is a contract employee, will be leaving the corrpany in June. The current Manager-Startup will become the Manager-NSED at that tim The Startup department will be organizationally shifted to report to the Manager-CPS and will be headed by the current Director-Startup Administration. These changes were anticipated to be completed in June.
d. IP Fitness For Duty Program (92701) 1
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IP has established a fitness for duty program based on Edison '
Electric Institute (EEI) guidelines. That program was detailed in Corporate fluclear Procedure (CNP) 4.12, Fitness For Duty, Revision I dated October 7, 198 i
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The IP fitness for duty program provides standards of conduct for all onsite personnel. The sale, posession, or use of illegal drugs and the abuse of legal drugs is prohibited. The program provides that the sale, use, or posession of a controlled substance or abuse of legal drugs on site will result in denial of access to the site and referral of the matter to appropriate law enforcement agencie The use of alccholic beverages during working hours is also prohibited. The program provides for denial of access to the site for personnel reporting to work or working under the influence of alcohol. The program provides for a routine random drug screening of all onsite personnel and mandatory drug screening for all prospective employees. The program also provides for handling allegations concerning fitness for dut The inspector briefly reviewed the implementation of the IP fitness for duty program. The program was being administered by the Supervisor - Medical Programs with chemical analysis support from a contract laboratory. The applicant had performed several audits of l the contract laboratory to assure proper processing of the samples, control of samples and results, and to monitor the quality of laboratory activities. Their audit found that the contract laboratory program was effectively implemente The inspector reviewed the techniques employed for random selection of personnel, techniques employed to assure the validity of the sample and the traceability of the sample, logs of testing perforn;ed under the prcgram, and a sample of test results. The program was being inplemented as described in the CNP and had been effective in identifying and correcting fitness for duty problems.
e. IP Operational Monitoring Program (71302)
The applicant briefed the inspector concerning their operational monitoring program (0MP). The folicwing information sununarizes the briefing provided:
The OMP was intended to monitor activities important to the achievement of project goals and to report observations to responsible management. The OMP uses qualified personnel from the quality assurance staff, supplemented by individuals from plant staff, NSED, and other departments, depending upon technical requirements. There were no full time personnel assigned to 0MP activities other than the program director; operational monitors were secured on loan from other department directors for the duration of the operational monitoring activity. The OMP program provides specific training for all monitors in the principles of the program prior to their assignment to GMP activities. OMP results are documented in a monitor report that is subject to reviews for reportabilit Conditions adverse to quality and nonconformances are appropriately documente OMP activities were being performed during the inspection perio The applicant indicated that the OMP would be used as much as possible to provide for early identification and correction of operating phase prcblems concerning both personnel perfcrmance and program effectiveness, Safety Evaluation Report Review and Followup - Remote Shutdown DTvision II Equipment Testing (92719)
IP letter U-600533 dated April 21, 1986, Subject: CPS Remote Shutdown Division II Equipment Testing - SER Outstanding Licensing Issue No.13, described additional IP connlitments made to the Office of Nuclear Reactor Regulation to resolve an cutstanding licensing issue. In that letter, IP repeated a previous commitment to provide operator training on the procedures for remote shutdown using ESS Division II controls and equipment prior to exceeding 5% power. This matter is open pending verification that the required training is completed prior to excceding 5% power (461/86023-06A). In addition, IP committed to perform a one-time confirmatory test of the appropriate Division II remote shutdcwn equipment prior to fuel load. This natter is open pending observation of the performance of that test (461/66023-068).
11. Unresolved Items Unresolved itenis are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Two unresolved items disclosed during this inspection are discussed in paragraphs 9.b. and 9.e.
12. DenItems Open items are matters which have been discussed with the applicant, which will be revicwed further by the inspector, and which will involve some action on the part of the NRC or applicant or both. Three open items disclosed during the inspection are discussed in paragraphs 6.,
9.e., and 10.f.
1 Exit Meetings (30703)
The inspectors met with applicant representatives (denoted in paragraph 1) thrcughout the inspection and at the conclusion of the inspection on May 12, 1986. The inspectors summarized the scope and findings of the inspection activities and the current status of the inspection progrces for inspection of preoperational activities and TMI Action Plan items. In particular, the inspector cephasized the need for a more formal approach to the performance of NSED design-related activities. The applicant acknowledged the inspection finding The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The applicant did not identify any such documents /prccesses as proprietar I
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l The resident inspectors attended exit meetings held between Region ?II based inspectors and the applicant as follows: i Inspector (s) Date DuPont 5/2/86 Ulie, tiolmes, Hodor, Thcmas 5/2/86 i
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