IR 05000461/1986037

Safety Insp Rept 50-461/86-37 on 860512-0701.Violation Noted:Procedure Did Not Contain Sufficient Acceptance Criteria to Ensure LPCS Injection Valve Would Open

ML20212A594
Person / Time
Site:	Clinton
Issue date:	07/17/1986
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212A574	List: IR 05000461/1986037 ML20212A570 ML20212A578
References
50-461-86-37, GL-84-23, GL-85-03, GL-85-06, GL-85-07, GL-85-13, GL-85-22, GL-85-3, GL-85-6, GL-85-7, GL-86-02, GL-86-2, IEB-86-001, IEB-86-1, NUDOCS 8607290078
Download: ML20212A594 (37)

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db U. S. NUCLEAR REGULATORY COMMISSION s

REGION III

i Report No. 50-461/86037(DRP)

Docket No. 50-461 License No. CPPR-137 !

l Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 ,

l Facility Name: Clinton Power Station  !

Inspection At: Clinton Site, Clinton, IL Inspection Conducted: May 12 through July 1, 1986 Inspectors: T. P. Gwynn P. L. Hiland F. J. Jablonski C. H. Scheibelhut

'\ D. L. Summers

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Approved By: . op, Chief ft 7//7!bb

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Projects Section IB Ddte '

Inspection Summary

, Inspection on May 12 through July 1, 1986 (Report No. 50-461/86037(DRP))

Areas Inspected: Routine safety inspection by two resident inspectors and two regional based inspectors of preoperational testing and operational preparedness activities including applicant action on previous inspection findings; IE Bulletin followup; generic letter followup; employee concerns; review of allegations; functional or program areas (including site surveillance tours, operating procedures review, maintenance procedures review and safety committee activity); independent inspection effort (including plant staff maintenance program implementation, and operational safety verification); regional requests (including draft low power license review, preparation of information notice, review of fitness for duty drug screening results, and review of low level radioactive waste storage facilities): and site activities of interes PDR ADOCK 05000461 G PDR

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b Results: Of the 15 areas inspected, one violation and one unresolved item were identified. The violation (paragraph 7.b(3)) related to an inadequate surveillance test procedure. The procedure contained safety significant discrepancies which had potential implications for other surveillance test procedures and the applicant's inservice inspection program for valves. The unresolved item (paragraph 7.b.(3)) related to the adequacy of the applicant's inservice inspection program for valves.

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DETAILS 1. Personnel Contacted Illinois Power Company (IP)

• K. Baker, Supervisor - I&E Interface, Licensing and Safety (L&S)

• R. Campbell, Director - Quality Systems & Audits

+ W. Connell, Manager - QA

• H. Daniels, Project Manager

• S. Fisher, Manager, Nuclear Planning & Support

+*W. Gerstner, Executive Vice President

+*J. Greene, Manager - Nuclear Station Engineering Department (NSED)

+*D. Hall, Vice President, Nuclear

+*H. Lane, Manager, Scheduling and Outage Management

• J. Loomis, Construction Manager

+*J. Perry, Manager - Project Control Center

• T. Riley, Supervisor - Licensing Operations

+* Schaller, Director - Nuclear Training

+ D. Shelton, Former Manager - NSED

+*F. Spangenberg, Manager - L&S

• J. Weaver, Director - Licensing

+*J. Wilson, Manager - Clinton Power Station (CPS)

Soyland/Wipco

+ J. Greenwood, Manager - Power Supply U. S. NRC Region III

+ J. Keppler, Regional Administrator

+*T. Gwynn, Senior Resident Inspector - Operations

• P. Hiland, Resident Inspector

+ R. Knop, Chief, Projects Section IB

+ C. Norelius, Director, Division of Reactor Projects

• F. Jablonski, Project Inspector

• Denotes those attending the monthly exit meeting on July 1, 1986.

+ Denotes those attending the management meeting on June 10, 198 The inspectors also contacted and interviewed other staff and contractor personne . Applicant Action On Previous Inspection Findings (92701) (Closed) Open Item (461/85005-25): Verify the installation of a flood proof door between the turbine building and the auxiliary building, and flood proofing of all penetrations up to the 731'

foot elevation (Clinton SER, paragraph 10.6).

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The applicant presented this item to the inspector for closur The inspector reviewed construction documentation which indicated that water-tight door SD-1-6 between the auxiliary and turbine buildings at elevation 707 feet had been installed and inspected by Baldwin Associates, the construction contractor. The inspector also reviewed documentation which indicated that all penetrations between the auxiliary building and the turbine building had been flood proofed up to the 731 foot elevation. Each penetration seal had been inspected by the contractor's quality control organizatio Finally, the inspector reviewed documentation which indicated that an annunciator had been installed in the main control room which indicated the status of door 50-1- The inspector walked dcwn the area in question to verify the installation of the water-tight door and penetration seals. The inspector verified that annunciator 5014-3C was lit in the control room when door SD-1-6 was open. In addition, the applicant had initiated a semi-annual preventative maintenance item to inspect the seals on door SD-1-6. This item is close b. (Closed) Open Item (461/85015-02): Verify that the applicant is participating in the GE surveillance program for new safety relief valves (SRVs) (Clinton SER, paragraph 5.2.2).

The applicant presented this item to the inspector for closur This item was previously reviewed in Inspection Reports 50-461/85042 and 86017. The inspector reviewed CPS No. 3831.01, " Safety Relief Valve Report", revision 1 dated June 16, 1986. This revised procedure, which was subject to biennial review, had been issued for use. The procedure appeared adequate to fulfill the applicant's commitment to report SRV leakage and actuation to the Institute for Nuclear Power Operations. This item is close c. (Closed) Open Item (461/85005-30): Verify that a corporate management directive has been prepared emphasizing the management responsibility of the shift supervisor and the establishment of a training program for shift supervisors to meet the guidelines of NUREG-0578 (Three Mile Island item I.C.3 - Clinton SER, paragraph 13.1.2.1).

The applicant presented this item to the inspector for closur This item was previously reviewed in Inspection Report 50-461/85065, paragraph 2.6. This item remained open pending review of a training program for shift supervisors that met the guidelines of NUREG-0578 and pending verification of performance of the required trainin The applicant provided documentation which demonstrated that the IP Supervisory Development Program met the commitments confirmed in the SER. Additional documentation demonstrated that all personnel currently qualified to act as shift supervisors, with one exception, had completed the necessary training. One shift supervisor was scheduled to attend the training in August 1986. A centralized

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commitment tracking (CCT) form, CCT #042314, had been generated to assure completion of the necessary training. That CCT was to be completed by September 30, 198 In addition to the above, the inspector verified that the applicant's training program for future shift supervisors included the requirement for supervisory development training. This item is close d. (Closed) Open Item (461/86023-02): A site employee requested that the inspector review the transfer of a slightly radioactive component (a bottom disposal cask made of depleted uranium dioxide)

in order to determine the actual radiation exposure received by the employee during the transfer operatio This review began as documented in paragraph 6 of Inspection Report No. 50-461/86023. At the conclusion of that inspection, the matter remained open pending review of the applicant's investigation report, corrective actions, and discussion of the review results with the site employe The inspector reviewed the results of a special IP corporate investigation of circumstances involved in the handling of radioactive materials which included the subject of this open item. That investigation also reviewed circumstances surrounding the transfer of an unirradiated traversing incore probe detector containing a small quantity of licensed special nuclear materia The following summarizes the results of IP's investigation:

An investigation of circumstances involved in the handling of radioactive material was conducted by IP corporate representatives. The investigation found that the event occurred from the compounding of several minor errors made by each of the involved organization On April 12, 1986, radioactive material consisting of a Bottom Disposal Cask (BDC) and a Traversing Incore Probe (TIP) detector were erroneously released as nonradioactive material and transferred from the Blue Warehouse Radioactive Material Storage Area to the Control Rod Drive Rebuild Room on the 737 elevation of the Fuel Building. The TIP detector was also classified as Special Nuclear Material. Both items were in wooden crates that were not identified as containing radioactive material. The crates were surveyed by a Radiation Protection Technician prior to removal from the storage area; however, the survey failed to detect that both crates contained uranium, which does not produce measurable radiation levels outside the crates. The crates were moved to the power block and subsequently moved to the Control Rod Drive Rebuild Room by Stone and Webster personnel. The error was discovered on April 15, 1986, during an unscheduled inventory of '

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Special Nuclear Material and proper controls were reestablished later that same da Resultant exposures were very low with a maximum calculated possible dose equivalent of 2 millirem. Potential for significant radiation exposure was very low since material with a radiation level greater than approximately 0.1 mr/hr at the surface of the crates would have been detected and the transfer controlled as radioactive materia The investigation concluded that control of radioactive material and an exempt quantity of Special Nuclear Material was lost for a period from about 11:30 p.m., April 12, 1986 to about 5:00 p.m., April 15, 198 Specific causes and corrective action recommendations were provided in the repor The inspector reviewed the applicant's investigation report and the calculational basis for the maximum possible dose equivalent of 2 millirem. The inspector concluded the following:

(1) The maximum possible dose equivalent was based on a conservative estimate of actual radiation exposures likely to have been received by the individuals involved in the transfer operatio (2) 10 CFR 20 did not require posting of the area as a radiation area or monitoring of personnel radiation exposure because the radiation levels involved were so low. The potential for a significant radiation exposure did not exist as a result of the inciden (3) The incident did involve minor violations of the applicant's special nuclear materials license. However, the applicant identified the violation; the violation was of minor significance; the violation was not reportable but was brought to the attention of the NRC resident inspector; the violation was corrected in a timely fashion with corrective action comitments to preclude repetition; and the violation was not a violation which could reasonably be expected to have been prevented by the applicant's corrective action for a previous violation. For these reasons, a Notice of Violation was not issued by the NRC in this cas (4) The applicant's investigation appeared to be thorough and the results properly reflected the significance and severity of the incident. The corrective action recommendations provided both specific and generic corrective action to preclude repetition of the incident. However, the corporate recommendations were l under review by site personnel at the conclusion of this inspection. A Region III radiation protection specialist

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inspector will review the applicant's corrective actions during a routine scheduled inspection. This is an open item (461/86037-01).

The above results were discussed with the site employee on June 24, 1986. The individual appeared to be satisfied with the above results. This item is close e. (Closed) Open Item (461/86023-06B): CPS Remote Shutdown Division II Equipment Testing. In order to resolve SER outstanding licensing issue No.13, IP committed to perform a one-time confirmatory test of appropriate ESS Division II remote shutdown equipment prior to fuel load. In addition, IP committed to provide operator training on the procedures for remote shutdown using ESS Division II controls and equipment prior to exceeding 5% power (0 pen Item 461/86023-06A).

The inspector witnessed portions of a confirmatory test (XTP-RS-01)

performed by the applicant. The objective of this test was to demonstrate by the lifting of wires and installation of jumpers, that Division II Residual Heat Removal (RHR) and Shutdown Cooling (SX) systems could be operated from outside the main control roo The inspector reviewed the completed test results and noted that the objective, as stated above, was met. This item is close During the conduct of the confirmatory test (XTP-RS-01), the inspector observed the participation of several plant operator The inspector noted that " hands-on" training was provided to a number of licensed and unlicensed operators. The subject of training for operators in the use of remote shutdown procedures will continue to be identified as Open Item (461/86023-06A) pending the inspectors review of completed trainin f. (0 pen) Open Item (461/86017-05): Verify that a 2'6" high berm has been constructed around the Unit 2 excavation site and that the berm has been stabilized with vegetation, if necessary, to prevent soil erosion (Clinton SER - Supplement 5, paragraph 2.6.1.1).

The applicant presented this item to the inspector for closure. The inspector toured the area of the Unit 2 excavation. One location was observed, at the plant northwest end of the excavation where the berm abuts the Radwaste Building, where the berm height did not meet the applicant's commitn.ent. This location extended approximately 10 feet along a concrete wail and approximately another 20 feet along the earthen berm. Another location was observed, at the plant southwest end of the excavation where the berm abuts the diesel generator building, where the berm had not been adequately stabilized with vegetation and erosion had begun to reduce the ber This location extended approximately 150 feet along the earthen berm. These areas were discussed with cognizant applicant personnel who acknowledged the discrepancies. The applicant stated that the noted discrepancies would be corrected. In addition, the applicant was considering the need for a routine monitoring program to assure the integrity of the berm is maintaine This item remains ope _ _ - _ _

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. (Closed) Unresolved Item (461/86023-03): The diesel generator air start pressure regulators for the Division I and II Emergency Diesel Generators (EDGs) were removed by a design change. Review of the design change documents indicated that the applicant's design review had not explicitly addressed the original design purpose of the air pressure regulators. The design change documents addressed the regulator's effect of limiting the working air pressure on downstream components but did not address the effect on the torque output of the EDG air start motors. 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, that is, maximum allowable torque applied to EDG ring gear was not exceede The applicant presented this item to the inspector for closur In particular, the applicant provided memorandum Y-500336, D. Shelton to Diesel Generator File B52 dated June 4, 1986, with two enclosures. That memorandum stated the following:

It is concluded testing is not required and the 250 psig pressure will not damage the ring gear. The maximum torque that could be induced into the ring gear is 275-300 ft.-l This is controlled by the clutch in the starter drive, and this maximum torque is obtained at 175 psig. The original design pressure prior to removal of the air regulator was 175 psi Therefore using 250 psig does not induce additional torque into the ring gear and no damage could occu A record of coordination, B52-86 (06-30)-6 dated June 30, 1986, indicated that a manufacturer's specification sheet for the EDG air start motor contained a significant error. The correction of that error resolved the inspector's concern. This information provided a sufficient basis to determine that the design basis for the Division I & II EDGs was not adversely impacted by the diesel generator modification. This item is close No violations or deviations were identifie . IE Bulletin Followup (92703)

(0 pen) IE Bulletin 86-01(461/86001-BB): Minimum Flow Logic Problems That Could Disable RHR Pump This bulletin was sent to all General Electric (GE) Boiling Water Reactor (BWR) facilities on May 23, 1986. The purpose of the bulletin was (1) to inform BWR licensees and al cants of a recently identified problem with the minimum flow logic for w.ich a single failure could disable all RHR pumps, (2) to request that licensees affected by the problem immediately provide appropriate instructions and training to plant operators on how

' to recognize the problem if it occurs and take appropriate mitigating actions, (3) to request that licensees notify the NRC of the existence of the problem at their facility within seven days of receipt of the bulletin,

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and (4) to request that licensees inform the NRC of measures taken to correct design or installation problems that were identified as a result of the bulleti The inspector verified that the applicant received the bulletin on May 30, 1986, and responded by letter U-600602, D. P. Hall to J. G. Keppler, Regional Administrator, Region III, on June 6,198 The applicant's Nuclear Station Engineering Department performed a prompt review and determined that the problem identified by the bulletin did not apply to the Clinton Power Station (CPS). The inspector reviewed applicable piping and instrument detail drawings and control and instrument detail drawings to verify that the applicant's determination was reasonabl At the time of this inspection, additional reviews were required in order to meet the applicant's program requirement In addition, the NRC was preparing a temporary instruction for inspection of this bulletin. This bulletin remains open pending completion of the required reviews and further inspection followu No violations or deviations were identifie . Generic Letter and Information Notice Followup (92703)

The inspector reviewed the applicant's program for processing IE information notices and NRC generic letters. The inspector also reviewed a number of selected generic letters to ascertain whether the information discussed in the generic letters had been addressed by the applican The applicant's procedure for handling IE information notices and NRC generic letters was described in Licensing and Safety (L&S) procedure L.1, " Feedback Program", revision 1, dated May 5,1986. Based on the inspector's review of the governing procedure (L.1), interview of the responsible L&S personnel, and review of the applicant's files as detailed below, the inspector concluded that the applicant had a system in place for the appropriate handling of IE information notices and NRC generic letters. Detailed results were as follows: (Closed) Generic Letter 84-23 (461/84023-HH): Reactor Vessel Water Level Instrumentation in Boiling Water Reactors. As a result of the staff review of the S. Levy, Inc. report SLI-8211, Generic Letter 84-23 was sent to licensees requesting a description of plans to address three potential improvement categories for Reactor Vessel Water Level Instrumentatio Illinois Power responded to Generic Letter 84-23, via IP letter U-0766, dated December 5, 1984. In that response, the applicant identified improvements made to the Clinton Water Level Measurement System (WLMS). In addition, the applicant provided a plant specific report, Reactor Pressure Vessel Water Level Measurement System Evaluation Report, dated November, 198 . . _ _ _ _ _ --

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Section 4.4.2 of Supplement 4 to the Clinton SER found the above response acceptable. This item is close b. (Closed) Generic Letter 85-03 (461/85003-HH): Clarification of Equivalent Control Capacity for Standby Liquid Control Systems (SLCS). This generic letter was issued to all Boiling Water Reactor licensees and applicant The applicant initially responded to Generic Letter 85-03 via IP letter U-60079, dated October 16, 1985. In that initial response, the applicant committed to impose a Technical Specification minimum limit of 10.0 weight percent sodium pentaborate concentration in the Standby Liquid Control syste The applicant revised the initial commitment via IP letter U-600582, dated May 23, 1986. The applicant established a minimum SLCS pump flow of 41.2 gpm. Using this pump flow value, the applicant calculated a minimum sodium pentaborate concentration of 10.2 weight percent. The applicant had discussed the revised commitment with the Clinton Licensing Project Manager, (LPM). The inspector contacted the LPM and confirmed the acceptability of the applicant's revised commitment. This item is close c. (0 pen) Generic Letter 85-06 (461/85006-HH): Quality Assurance Guidance for ATWS Equipment that is not safety-related. This Generic Letter provided specific NRC QA guidance to be considered for nonsafety-related component The inspector reviewed the applicant's response to this Generic Letter contained in IP letter U-600279, dated October 16, 1985. The inspector's review indicated that the applicant had not properly addressed the Generic Letter due to an apparent miscommunication with the NRC staff. In the response provided, the applicant stated that "... requirements for nonsafety-related quality assurance for the alternate rod insertion (ARI) and recircuiation pump trip (RPT)

systems will be addressed by IP following the issuance of guidance from the Staff in addition to that provided in Generic Letter 3-06...". The inspector, with concurrence from the Clinton LPM, advised the applicant that no additional QA guidance was forthcoming. This item will remain open pending additional review by the applicant in accordance with their established procedure d. (0 pen) Generic Letter 85-07 (461/85007-HH): Implementation of integrated schedules for plant modification This generic letter distributed a survey form to collect views, intentions, and concerns regarding an integrated schedule for plant modification The applicant responded to this generic letter via IP letter U-600207, dated August 5, 1985. In their response, the applicant provided the staff its decisions and methodologies concerning integrated schedules. The applicant stated in the referenced response that a prioritization methodology for plant modifications

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would be selected prior to fuel load. At the conclusion of this

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inspection period, the applicant had not made the selection for prioritization methodology. This item will remain open pending the applicant's selection of a prioritization methodolog e. (0 pen) Generic Letter 85-13 (461/85013-HH): Transmittal of NUREG-1154 Regarding the Davis-Besse Loss of Main and Auxiliary Feedwater Event. This generic letter transmitted the NRC staff's report on the June 9, 1985, Davis-Besse event; requested recipients to review NUREG-1154 for applicability to their facility; and requested recipients to ensure information was made available to their plant staff as part of their training program in connection with the Feedback of Operating Experience to Plant Staff (TMI Action Plan Item I.C.5).

The inspector reviewed the applicant's internal response to this generic letter, IP memorandum Y-201833, dated February 3, 1986. The applicant had implemented a Motor Operated Valve Analysis and Test System (MOVATS) program at Clinton Power Station. The results of this program will be reported to the NRC in response to IE Bulletin 85-03. The inspector noted that the IP training department review indicated that this generic letter was not applicable to Clinto The inspector requested additional justification for the Clinton training department's response. This generic letter will remain open pending the inspector's review of the requested informatio (Closed) Generic Letter 85-14 (461/85014-HH): Commercial Storage

' at Power Reactor Sites of Low-Level Radioactive Waste Not Generated by the Utility. This generic letter discussed NRC requirements for the commercial storage of low-level wast The applicant reviewed this generic letter and stated in their closure file that the generic letter guidance to ship wastes to current disposal sites was incorporated in the applicant's waste disposal plans. The applicant did not plan to commercially store wastes at Clinton Power Station. This item is close g. (0 pen) Generic Letter 85-22 (461/85022-HH): Potential for Loss of Post-LOCA Recirculation Capability Due to Insulation Debris Blockage. This generic letter discussed the potential for thermal insulation blockage of suction strainers in the suppression pools of BWR The applicant reviewed this generic letter and defined specific changes to their procedure for the conduct of 10 CFR 50.59 Review At the time of this inspection, the applicant had not yet revised the applicable procedure. This generic letter will remain open

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pending the inspector's review of the procedure changes, h. (0 pen) Generic Letter 86-02 (461/86002-HH): Technical Resolution of Generic Issue B-19, Thermal Hydraulic Stabilit This generic letter provided the NRC staff's conclusion on the technical

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evaluation of topical reports submitted by General Electric and Exxon. BWR owners were requested to review the need for technical specifications in light of the approved stability criteri The inspector confirmed the applicant had received this generic letter and had commenced the internal review process. At the conclusion of this report period, the applicant's review was still in progress. This generic letter will remain open pending the inspector's review of the applicant's final respons No violations or deviations were identifie . Employee Concerns (99014)

The inspectors reviewed concerns expressed by site personnel from time to time throughout the inspection period. Those concerns related to regulated activities were documented by the inspectors and sutmitted to Region III. Six concerns were transmitted to the regional office during this report period. One of those concerns was inspected and documented in paragraph 6.c. of this repor . Review of Allegations (99014) (Closed) Allegation (RIII-85-A-0106; #152): On June 18, 1985, a former employee at the CPS contacted RIII. That person's position was described as conducting technical specification reviews in the preoperational area. During the reviews the person claimed to have found several safety related concerns and reported them to management. The person claimed to have been dismissed because of identifying the concerns, and for involvement with allegations at another facility. The inspector informed the alleger that he must file his discrimination issue with the Department of Labor (DOL)

within a prescribed time. The alleger has not contacted D0L and this issue is considered close Concern No. 1:

Illinois Power had not incorporated some of NRC's guidance, NUREG/CR-1369. into preoperational test procedure NRC Review:

Extensive NRC inspection of preoperational test procedures has been conducted as documented in Inspection Reports No. 50-461/85036, 85048, 85055, and 85061. Inspectors utilized NRC Inspection and Enforcement Manual inspection procedure 70300 "Preoperational Test Procedure" while conducting their inspections. Procedure 70300 includes the elements of NUREG/CR-1369. The inspectors verified that preoperational test procedures complied with the Final Safety Analysis Report, Safety Evaluation Report, and Regulatory Guide 1.68

" Initial Test Programs for Water-Cooled Nuclear Power Plants".

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A similar concern is discussed at length in paragraph 6.b Concern i No. 3 of this report. As stated there, NUREG/CR-1639 is a guide developed for NRC use and imposes no requirements on IP. The NUREG

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was utilized by the inspector during review of C&I developed surveillance procedures wherein the inspector noted extensive use

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of the NUREG by IP in development of the procedures. No procedural

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deficiencies were identified by the inspecto >

Results:

The allegation was not substantiated as discussed above. Similar matters are further discussed in paragraph 7.c of this repor Concern No. 2:

, Contract suployees used an outdated revision of the Technical j Specification in their reviews of preoperational procedures; diesel

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generator preoperational test procedure No. PTP-DG/D0-3 required 16 l ^ Technical Specification tests be performed during preoperational

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testing but less than half have been satisfie : NRC Review:

i A draft version of the Technical Specification was used during

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preparation of preoperational test procedures; currently the final draft of the Technical Specification is being reviewed and certified by NRC and Illinois Power. As documented in Inspection Report No. 50-461/85036 preoperational test procedures, including PTP-DG/D0-3, were reviewed by NRC inspectors and found to be in

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compliance with the Final Safety Analysis Report, Safety Evaluation '

i Report, Start-up Manual, and Regulatory Guide 1.68.

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As documented in Inspection Report No. 50-461/85055, NRC inspectors j witnessed the preoperational test described in preoperational test procedure PTP-DG/D0-3. The tests included verification of the

. diesel generator starting time, sequence and loading times; t

acceptance criteria of the full load reject test was met.

Results:

! As discussed above the allegation was not substantiated. Inspectors i

verified that preoperational test procedures met requirements, and tests indicated that the diesel generator met acceptance criteria.

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b. (0 pen) Allegation (RIII-86-A-0034; No. 184): Inadequate

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surveillance procedure preparation, review and approval process,

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Concern No 1:

A review for technical adequacy was not performed on reformatted procedure NRC Review:

In late 1985, a group of contract employees was hired by IP to

, revise and update surveillance procedures to comply with a new f

philosophy and format. Format requirements were outlined in procedures CPS No. 1005.01, " Preparation, Review, and Approval of

, Station Procedures and Documents", and CPS No. 1011.05, " CPS Surveillance Guidelines". As defined in CPS No. 1005.01, a change to correct format was a non-technical change, that is, one which does not affect the content or purpose of the procedure.

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The procedure review process, as described in CPS No. 1005.01, included reviews by the originator, group supervisor, department head, independent technical reviewer, compliance group, and others as necessary including the plant sta"f technical departmen Reviewer's comments, including techn' cal comments, were incorporated into the procedures or otherwise resilved. In addition, all surveillance procedures must be revi wed by the Facility Review Group (FRG), the onsite review committee, which has the opportunity to review all comment sheets that are attached to the procedures submitted for approva The inspector reviewed several surveillance procedures that were in the review cycle. The inspector noted that there were technical comments on the comment sheets which had been incorporated into the procedures. The inspector also interviewed several C&I technicians who were responsible for implementing surveillance procedures and verifying their technical adequacy. Those C&I technicians stated that any adverse comments which they noted were incorporated into the procedure Results:

The allegation could not be substantiated. Reformatted procedures were reviewed for technical adequacy and proved technically adequate by implementatio Concern No. 2:

Uncontrolled and possibly outdated drawings were used for preparation of surveillance procedures; this practice was condoned by supervisio NRC Review:

Surveillance procedure writers were contract employees of the IP C&I department and were located in a room one floor below the

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maintenance department file room. The plant staff maintenance department file room contained a complete and controlled set of drawings, instrument loop sheets, data sheets, and the Sargent &

Lundy (maintenance) instrument index. The maintenance department file room was utilized by all maintenance personnel, including contractors, who needed to reference controlled document Some procedure writers informed C&I supervision that a complete set of drawings and documents should have been made available in the immediate work are CPS No. 1005.01, " Preparation, Review, and Approval of Station Procedures and Documents", required that the most current references be used. ANSI N45.2-1977, " Quality Assurance Program Requirements for Nuclear Facilities", requires that documents be distributed to and used at the location where the prescribed activity is performe The inspector was informed by senior C&I supervision that procedure writers had expressed displeasure with the location of their work area in relation to the maintenance file room; however, C&I supervision always felt they were in compliance with NRC requirements. Because of working space considerations and a large number of referenced documents, the maintenance file room was considered by IP management to be an extension of the procedure writer's work area. All maintenance personnel were allowed to check out " reference only" drawings and documents; however, it was the procedure writer's responsibility to assure that the most up to date document was used for preparation of surveillance procedure During interviews with C&I technicians who were qualified to perform technical reviews, the inspector determined that the technical reviews were made with reference to the most current drawing. This precluded the use of the "most current" drawing by procedure writers. The inspector determined that those reviewers who were interviewed never found a problem where the wrong drawing revision had been used to update a surveillance procedur Results:

The allegation could not be substantiated. The maintenance department file room was a logical extension of the procedure writer's work area; therefore, there was no requirement to have the "most current" drawing at the immediate work location of the procedure writers. Based on technical reviews performed by IP reviewers there was no indication that outdated drawings were used for the preparation of surveillance procedures, or that supervision condoned situations in violation of NRC requirement Concern No. 3: Retrofitted procedures deviated from NUREG/CR-1369 requirement NRC Review:

NUREG/CR-1369, " Procedure Evaluation Checklist for Maintenance, Test and Calibration Procedures Used in Nuclear Power Plants", was

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developed.for use by NRC inspectors as a guide to evaluate maintenance, test, and calibration procedures. NUREG/CR-1369 does not impose any requirements on IP. CPS No. 1011.05, " CPS Surveillance Guidelines", makes reference to the NUREG and incorporates many of.its suggestion Results:

The allegation could not be substantiated. NUREG/CR-1369 does not impose any requirements on IP; however, surveillance procedures reviewed by the inspector showed that the procedures met or exceeded the NUREG guidelines. Also, refer to paragraph 7.c. of this report

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for further discussion about NUREG/CR-136 Concern No. 4:

Some plant staff C&I technicians performed 10 CFR 50.59 safety evaluations but were not praperly qualified to the applicable ANSI standar NRC Review:

CPS No. 1005.01, " Preparation, Review, and Approval of Station Procedures and Documents", required that independent technical reviewers be qualified to PMS0-022, " Procedure Independent Review Qualification", and meet the minimum qualifications as stated in ANSI /ANS 3.1-1978, " Standard for Selection and Training of Personnel for Nuclear Power Plants".

The inspector determined that only one person, a consultant, was hired by IP to make independent technical reviews and sign the CPS No.1005.01F001 procedure consnent sheet recommending approval /

disapproval of surveillance procedures. The consultant exceeded the requirements of PMS0-022 and ANSI /ANS 3.1-197 In addition to the consultant, the inspector reviewed the qualifications of four C&I technicians who at times performed preliminary reviews of surveillance procedures before final review by the independent technical reviewer. All four C&I technicians had six years prior military experience including approximately 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> related technical training in electronics and 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> related technical training in reactor theory and operations; all four C&I technicians met the requirements of ANSI /ANS 3.1-197 Records showed that the technicians had attended a training session about the background and performance of an independent technical review as required by PMS0-02 The inspector reviewed several station procedure approval fonns and determined that only the consultant had signed as the independent reviewer even though other personnel were qualified and certified to do s . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ __

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C&I technicians do not perform 10 CFR 50.59 safety evaluation Those evaluations are performed by the FRG which is comprised of personnel who collectively have experience and competence in nuclear plant operations, engineering, chemistry, metallurgy, et Both the C&I supervisor and the consultant were qualified members of the FR Results:

The allegation could not be substantiated. The C&I technicians were qualified and certified to perform independent reviews even though all such reviews were performed by the consultant; 10 CFR 50.59 safety evaluations were done by the FR Concern No. 5:  ;

Trip annunciators are not considered to be technical specification data when the technical specification definition for channel functional test or channel calibration states that the test shall verify alarm and/or trip function NRC Review:

Surveillance requirements relate to test, calibration, or inspection to assure that necessary quality of systems and components is maintained, that facility operations will be within safety limits, and that limiting conditions for operation will be met. IP utilized a series of surveillance procedures to ensure operable statu Included within a surveillance procedure are acceptance criteria (

requirements for both technical specification and non-technical specification data. Alarms are not included as technical specifica- ;

tion data, that is, if an alarm failed the shift supervisor would l not be notified to determine if a limiting condition for operation (LC0) existe The NRC technical specification definition of operability does not include alarms; however, the NRC definitions for channel calibration and channel functional test includes verification of alarms to l verify operabilit The inspector discussed this discrepancy with the person in charge  !

of plant operations support who stated that it was not appropriate I to be placed in a LC0 because an alarm was out of service for any reason. The inspector also discussed this matter with the NRC Nuclear Reactor Regulation licensing reviewer responsible for

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j Clinton Pcwer Station's technical specifications. The reviewer agreed that it was not the intention of the technical specification to place the plant in a LC0 because of an inoperable alar i t . .

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Results:

The allegation was substantiated; however, CPS No. 1011.05 is being changed to add the requirement of notifying the shift supervisor anytime data exceeds either the technical specification or non-technical specification acceptance criteria. This allows the shift supervisor to determine if a LC0 has been exceeded. The clarification will be addressed in each surveillance procedure as part of the biennual review process. In the interim, a Plant Manager Standing Order (PMS0) has been written to clarify this requirement. A similar matter is discussed further in paragraph 7.b.(2)(b) of this repor Concern No. 6:

A surveillance procedure could be approved even though all departments had not recommended approval because there aren't any revision numbers on the comment routing sheet. (This concern was brought to the inspector's attention while interviewing IP personnel).

NRC Review:

The person making the allegation did not know of any surveillance procedures which had been surreptitiously approved, only that it could happen if a devious person desired to do s Per the requirements of CPS No. 1005.01, " Preparation, Review, and Approval of Station Procedures and Documents", only the independent technical reviewer actually recommends approval / disapproval of a procedure. A copy of the procedure review fonn, comments, and comment resolutions are forwarded to the Records Management Group for retention. The department or group responsible for the procedure ensures that comments are properly handled (not all comments are necessarily implemented into procedures but require resolution). If any technical content changes are made to a procedure during the approval cycle then the procedure and change require review by all organizations that previously signed the approval form. The Facility Review Group reviews procedures complete with all comment sheet Results:

The allegation could not be substantiated. The built-in procedural controls are appropriate to preclude inadvertent approval of procedures. There was no information provided or reason to believe that incorrect procedures had been erroneously or surreptitiously approved.

, Concern No. 7:

Surveillance procedure writers were given verbal instructions that seemed to contradict plant procedures about the responsibilities of the procedure originator defined in CPS No. 1005.0 _ - - _ -

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NRC Review:

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I CPS No.1005.01, " Preparation, Review, and Approval of Station

!

Procedures and Documents", requires the originator of a procedure-to ensure that a procedure fully satisfies the requirements of

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upper tier documents, satisfies commitments, and provides necessary guidance for compliance with station technical specifications.

[ No specific instances of contradictory verbal instructions were made known to the inspecto Interviews with surveillance procedure writers did not disclose any instances where verbal instructions contradicted plant procedures.

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The inspector reviewed a copy of the " Format Model" provided by the alleger to the resident inspector. Changes to the model were administrative, for example, changing " acceptable limits" to j " limits" and correcting typographical errors made to annunicator

window designators, and would not change the. technical aspect.of a j surveillance procedure. The changes reviewed by the inspector were

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in compliance with CPS No. 1005.0 !

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Results:

i The allegation could not be substantiated. No instances of verbal or other instructions that contradicted plant procedures were identifie Concern No. 8:

The surveillance procedure format model was not an approved, controlled document. Several changes made to the format model

over time may have resulted in inconsistencies in the final l' approved surveillance procedure.

NRC Review

! CPS No.1005.01, " Preparation, Review, and Approval of Station

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Procedures-and Documents", and CPS No. 1011.05, " CPS Surveillance

Guidelines", provide the requirements for formatting procedures.

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Appendix A to CPS No. 1005.01 listed generic procedure format

requirements, and section 8 of CPS No. 1011.05 listed general format

! requirements to ensure that surveillance procedures were written and maintained in a proper and consistent manner. CPS No. 1011.05 is t

consistent in interpreting the requirements of CPS No. 1005.01;

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however, it was very complex. An uncontrolled "model" surveillance

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procedure was prepared to promote uniformity among surveillance procedure writers. The model procedure contained all of the

elements of the controlling procedures. Any time either controlling i procedure was revised, so was the model. Based on interviews with surveillance procedure writers, the inspector determined that

changes made to the model were format changes, that is, those which I did not affect any technical aspect of the procedure. Although i several changes were made to the model those procedure writers

! interviewed believed that the model never deviated from the j requirements and guidelines stated in CPS 1005.01 and CPS 1011.05.

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As previously stated above in other Concerns, surveillance

procedures are reviewed for technical adequacy and submitted to

the FRG for approva ;l Results:

The allegation was partially substantiated in that it was not an l- approved, controlled document; however, there were no known

! significant technical inconsistencies with final approved surveillance procedure ,

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Concern No. 9:

Several C&I technicians were allowed to make changes to the l individual's procedures without feedback to the originator,

{ possibly in violation of plant procedure i t

NRC Review:

CPS No. 1005.01, " Preparation, Review, and Approval of Station Procedures and Documents", states that the originator of a procedure

shall ensure that the procedure fully satisfies the requirements of I

upper tier documents, satisfies commitments, and provide necessary guidance for compliance with technical specifications. As described j

in Concern No. 4, qualified C&I technicians performed preliminary j' reviews of surveillance procedures before being reviewed by the

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i independent technical reviewer ~who ensured that the procedure con. plied with upper tier requirements and was technically adequat >

Handling of comments about procedures is as described in Concern

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j No. 6, that is, the department or group responsible for the procedure ensures that comments are properly handled. The practice

of having changes handled by the originating organization is

consistent with ANSI N45.2-1977. There is no requirement that the i originator of a procedure receive any feedback about comments or changes made to procedure Results

i i The allegation could not be substantiated. There was no requirement to feedback procedure changes to the originato . (Closed) Allegation (RIII-86-A-0104;#192): An individual alleged

' that he had been assigned a maintenance work request (MWR) to clean a foreign material which had deposited on containment electrical

penetration IEE18E but could not do so because the penetration was j energized. The individual was concerned that subsequent cleaning may have been inadequate.

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NRC Review: Electrical penetration IEE18E is a safety-related containment

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penetration designated "1C1E" (control cables, division 1, safety

)

related). The inspector reviewed the applicant's machinery history

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files and identified five MWRs (B-16563, B-35337, B-35339, C-06559, and C-12184) that had been written for work on this penetration in the last 12 months. Two of the five MWRs reviewed addressed cleaning of penetration IEE18 MWR C-12184, initiated April 22, 1986, required cleaning of the penetration in accordance with nonconformance report (NCR) No. 41947 and in conjunction with MWR C-06559. MWR C-12184 was completed and closed after final QA review on May 18, 198 MWR C-06559, initiated April 23, 1986, also required cleaning of penetration IEE18E in addition to replacement of two terminal boards. This MWR was still open on June 12, 1986, when the inspector conducted an unannounced inspection of penetration IEE18E. During i this inspection, the inspector substantiated the individual's !

concern that foreign material was present on a number of terminal connections; however, it was noted that MWR C-06559 was still open and the disposition of NCR #41947 (initiated March 25,1986),

included in the job steps of MWR C-06559, required cleaning of the penetration. In addition, the inspector noted that a number of Quality Assurance mandatory hold points had been established to verify completion of the MWR and closure of the NC Results:

As noted above, this allegation was substantiated. However, based on the field observations and the review conducted, the inspector concluded that the penetration would be cleaned. The open MWR C-06559 and the open NCR #41947 provided documented evidence that this concern was being properly addressed in the applicant's routine corrective action program. This item is close d. (Closed) Allegation (RIII-85-A-0159-02;#163): During the investigation of Allegation RIII-85-A-0159-01, " Qualification / '

Certification of U. S. Testing Co. Inspectors", a very close connection was noticed between the allegation and an allegation i received by the Clinton Safeteam (Concern No. 12345) concerning ,

the use of alcohol and drugs by HVAC Overinspection inspector Some of the individuals alleged to be drug abusers were the same -

individuals alleged to be unqualified mechanical overinspection inspector On August 8, 1985, the Clinton Safeteam received an anonymous telephone call. The caller named three people (Individuals A, B, and C) in the U. S. Testing Co. office that he claimed used and sold marijuana. The caller gave seven first names of people in the HVAC group that he claimed were cocaine users and dealers. The caller wanted to know why urine tests were not being given and stated that if dogs were taken into the U. S. Testing Co. office right now that drugs hidden throughout the office and bathroom would be foun _

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The ncxt day, August 9, 1985, the applicant selected 23 U. Testing Co. HVAC group personnel for drug screening urinalysis tests. The selections were made at random from over 50 persons in the organization. Three (Individuals A from above, D, and E) of the 23 individuals selected tendered their resignations on the grounds that their legal rights were being trampled; however, they did provide urine samples. Later that same day, they reconsidered their resignations and asked to be reinstated. This was denied and their resignations were processe The 23 samples were evaluated over the weekend and on Monday, August 12, the applicant received the report that two samples were positiv (These two individuals were not the same as the three identified by the caller). One of these individuals was on prescribed medication which accounted for the positive sample; the other individual was retested satisfactorily on Tuesday, August 13, 1985. Individuals A, B, C, D, and E were among those whose tests were negativ On Monday evening, August 12, 1985, Illinois State Police Drug Detection dogs searched the trailer complexes north of the protected area fence, south of the construction office building, and west of the main access road. This area included the U. S. Testing C offices. No drugs were discovere On August 13, 1985, an anonymous call was received on the Illinois Power Co. Quality Assurance (IPQA) " Hotline" (a tape recorded hotline service) by an individual concerned about the urinalysis testing conducted August 9 on U. S. Testing Co. personnel. The individual stated that several of the persons tested had not provided their own sample, but had substituted another person's sample for their own. The individual provided the names of three individuals who he claimed had done this but stated he did not know the others by name. The three identified were the individuals who had tendered their resignations before testing and had already left the site (Individuals A, D, and E); therefore, retesting was not possibl On the morning of October 9, 1985, the alleger called to determine the status of the investigation. He was not satisfied and asked the Safeteam representative to arrange a phone call with the QA Manage This was done and the alleger was to call back at 4:00 p.m. At 3:15 p.m., the alleger called back and told the Safeteam representative to cancel all arrangements. He said that all of the people he had named were laid off, and he had no further interes He was asked if he considered the case closed. He said ye NRC Review:

The inspector reviewed all of the applicant's files and found that l they corroborated the summary given abov In no instance was any evidence found which indicated that illicit drugs were used by U. .

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Testing personnel or existed in the area searched. The inspector interviewed the Safeteam Director, the Director of Human Resources, and the Director of Quality Systems and Audits. These persons were directly involved in the applicant's investigation. The interviews revealed that all of the people named by the alleger (as well as others not named) had been interviewed by one of the directors (no notes were taken to preserve confidentiality). These interviews indicated that there was no substance to the allegation Of the three persons who resigned because of the random urinalysis testing, two were office workers and one was an inspecto Individual A was not an inspector. Since the U. S. Testing C was performing an overinspection, based on a statistical sampling method, the applicant concluded that even if the allegations were true, the statistical validity of the overinspection was not jeopardize Results:

Based on the materials reviewed and personnel interviews, the inspector concluded that the allegation was not substantiated. As stated above, the inspector agreed that based on the work being done by U. S. Testing and results of the overinspection program, there would have been no impact on the quality of the plan '

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No violations or deviations were identifie . Functional or Program Areas Inspected Site Surveillance Tours (71302/60501)

Surveillance tours of selected areas of the site were performed at periodic intervals throughout the report period. Those surveillances were intended to assess: cleanliness of the site; storage and maintenance conditions of plant equipment and material; potential for fire or other hazards which might have a deleterious effect on personnel or equipment; storage conditions of new fuel; and to witness maintenance and preoperational testing activities in progres Several tours of the new fuel storage area identified no deviations from the special nuclear materials license requirements for security, fire protection, and environmental controls for new fuel storage.

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The inspectors noted substantial improvements in general plant cleanliness and in cleanliness control throughout the plant during the report period. Continuing attention to housekeeping and cleanliness control was needed in order to maintain and improve the level of cleanliness achieved to dat The inspectors confirmed several housekeeping conditions previously identified as a violation in Inspection Report No. 50-461/8604 During a tour of the plant accompanied by the Manager - Nuclear Program Coordination on June 21, 1986, the following conditions were identified and documented for corrective action by the applicant:

Several minor housekeeping deficiencies such as communications paging speakers stuffed with rags, extraneous materials such as unnecessary tags, and minor amounts of trash and debris in one are Numerous unidentified minor equipment deficiencies such as packing leaks, inoperable communications equipment (Gaitronics telephone units and one speaker unit), piping insulation that interfered with the operation of vent and drain valve handwheels, inoperable lighting units, and vent and drain piping without end caps required by the drawing *

Several valves and instruments missing identification tag Each of the above items, taken by.itself, was not indicative of a safety problem. However, the relatively large numbers of such deficiencies and the obvious nature of the deficiencies indicated a lack of attention by the plant operators who routinely tour plant area No violations or deviations were identified, Operating procedures Review (42450)

This inspection continued a review of procedures to be used in the plant operations phase (reference Inspection Report Nos. 50-461/86017 and 86023). The purpose of this inspection was to confirm that the plant operating procedures are prepared to adequately control safety-related operations within applicable regulatory requirement (1) Completed Review The procedures listed below have been reviewed and appeared to be technically adequate. Questions and comments discussed with the applicant were either already addressed in the applicant's procedure review program or responses to the inspectors question resolved the commen ..

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Procadure Revision Title I

(a) 1013.02 5 Fuel Handling General Responsibilities b 1014,01 8 Safety Tagging Procedures cl1405.02 0 LC0 Manual Tracking (d) 3101.01 1 Main Steam System (e) 3208.01 3 Cycled / Makeup Condensate (f) 3211.01 2 Shutdown Service Water (SX)

(g) 3220.01 3 Suppression Pool Makeup h) 3313.01 3 LPCS i 3314.01 2 Standby Liquid Control j 3412.01 2 Essential Switchgear Heat Removal i (k 3501.01 3 High Voltage Auxiliary Power System 1 3509.01 2 Instrument Power System m 3842.01 1 Plant Comunication Alarm Test n 9012.01 20 Scram Disch. Vol. Vent &

l Drain Valve Op Test (o 9051.01 20 HPCS Sys. Pump Operability Checks I (p 9052.01 21 LPCS Pump Operability Checks (q) 9053.03 20 ECCS Division 2 Simulated Auto i

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Actuation (r) 9080.03 20 Diesel Generator IA Operability 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and LOP test (s) 9080.04 20 Diesel Generator 1C Operability 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and LOP test (t) 9080.09 20 Unit Power Supply Operability Normal to Alternate Circuit Transfer  ;

(u) 9090.01 20 Refueling Interlocks Operability Test (v) 9092.01 20 Inclined Fuel Xfer Sys. Interlocks Funct.

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At the conclusion of this inspection, two procedures were pending review to complete the scope of this inspection.

i (2) Discussion Two minor changes were made to the scope of this inspection as l it was previously documented. The first change involved the

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substitution of CPS No. 9052.02, LPCS Valve Operability Checks, revision 20, for the previously scheduled review of CPS No. 3305.01, Reactor Protective System. The second change ( involved the addition of one integrated plant operating procedure, CPS No. 3001.01, Approach To Critical. These changes resulted in a slightly broader scope of the inspection and allowed the inspection to address apparent deficiencies in one procedur _ _ . _ . . ,-- __ _ _ . _ . _ _ _ _ _ _ _ - _ . _ _ - . - _ _ --_ _ _ _ _ __ __ , _

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CPS No. 9052.02, LPCS Valve Operability Checks, was intended to

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verify the operability of Low Pressure Core Spray (LPCS) system valves in accordance with CPS Technical Specifications and to

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provide for inservice inspection (ISI) of LPCS system valves.

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Review of the procedure revealed numerous minor discrepancies in technical content, procedure, format, and a general lack'of sufficient instructions for performance of the work activit These discrepancies were discussed in detail with the

applicant. In addition to the minor discrepancies, several significant procedure deficiencies were identified which were of more than minor safety significance, as follows:

L (a) CPS No. 9052.02, paragraph 8.3.8 accomplished opening stroke timing of the LPCS injection isolation valve (1E21-F005). The valve timing acceptance criteria, as denoted on the LPCS Valve Operability Data Sheet (CPS No. 9052.020001, revision 20) was 37 seconds. This number was consistent with the ISI acceptance criteria l specified in CPS No. 1887.00, Inservice Inspection i Program, revision 2.

I Reference to the CPS Final Safety Analysis Report (FSAR)

indicated that the opening time required to support the i

safety analysis for this valve (1E21-F005) was 37 seconds which included power supply availability.- When the 12 second diesel generator start time was subtracted from

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the 37 second total time, the appropriate opening time '

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acceptance criteria was 25 seconds. Thus, the procedure was non-conservative with respect to this acceptance

criterion; the safety analysis could have been exceeded without any failure to meet acceptance criteria. Both CPS No. 9052.02 and CPS No. 1887.00 were not consistent with

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FSAR requirements. This indicated a deficiency in the i ISI program as well as a deficiency in the surveillance procedure.

(b) CPS No. 9052.02, paragraph 6.4 required immediate i i notification of the shift supervisor whenever data was

! recorded that did not meet. technical specification

! acceptance criteria. The acceptance criteria on the

! data sheet, CPS No. 9052.020001, revision 20, was broken

! into two sections; technical specification acceptance

! criteria and ISI acceptance criteria. The stroke time for valve 1E21-F005 was identified in the ISI acceptance criteria. Thus, the failure to meet 1E21-F005 stroke acceptance criteria, regardless of the value applied, i would not necessarily have been reported to the shift i supervisor for evaluation of the impact of the failure

on LPCS system operability.

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(c) At least two LPCS system valves (1E21-F003 and 1E21-F006)

that had ISI requirements identified in the ISI program i

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,-m__-,_.-.--y_r.- . - - . ---m.- ___ __ _ ________ __

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document (CPS No. 1887.00) were not tested in CPS No. 9052.02. In addition, stroke timing criteria for closing of two containment isolation valves (1E21-F001 and 1E21-F005) were not included in the procedure data shee This indicated a failure to fully implement the ISI progra (d) Two applicable technical specifications (4.6.4.1 and 4.8.4.2.2) were not reflected in the procedure, the acceptance criteria, or the procedure references. In addition, the procedure did not reference the applicable portions of the FSA (3) Results The matters documented in paragraphs (2)(a,b,c, and d) above represent examples of a violation of 10 CFR 60, Appendix B, Criterion V and the IP Operational QA Manual, paragraph 5.2 in that procedure CPS No. 9052.02 did not provide sufficient detailed instructions and/or appropriate acceptance criteria for determining that important activities had been satisfactorily performed (461/86037-02). These matters had potential generic implication for other surveillance procedure The matters documented in paragraphs (2)(a and c) above indicated pote'ntial generic problems with the CPS ISI progra This matter is unresolved pending followup inspection by a RegionIII~specialistinspector(461/86037-03).

One violation and one unresolved item were identifie c. Maintenance Procedures Review (42451)

This inspection completed a review of maintenance procedures to be used during the plant operations phase. The purpose of the inspection was to confirm that surveillance procedures used by the C&I maintenance department were prepared to adequately control testing of safety-related systems within regulatory requirements including the CPS technical specification (1) _ Applicable Regulatory Requirements ir:d Applicant Procedures (a) 10 CFR 50 Appendix B, Criterion I and V (b) ANSI N18.7-1976, " Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants" (c) ANSI N45.2-1977, " Quality Assurance Program Requirements for Nuclear Facilities" (d) CPS Draft Technical Specifications (e) CPS No. 1005.01, Revision 16. " Preparation, Review, and Approval of Station Procedures and Documents" (f) CPS No. 1011.05, Revision 0, " CPS Surveillance Guidelines"

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(2) Checklist The inspector used NUREG/CR-1369, Revision 1. " Procedures Evaluation Checklist for Maintenance, Test and Calibration Procedures Used in Nuclear Power Plants". The checklist imposes no requirements on the applicant but was used to evaluate procedural characteristics for deficiencies that could most likely lead to performance error (3) Surveillance Procedures Reviewed

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(a) CPS No. 8630.01, Rev. 20 Transmitter Response Time Test (b) CPS No. 1011.02, Rev. 3, Implementation and Control of Surveillance Testing (c) CPS No. 1019.02S, Rev. O, System Cleanliness (d) CPS No. IOP3601.01S, Rev. 0,. Instrumentation Valve Lineup Operation (e) CPS No. OMP8801.04S, Rev. 0, Rosemount Series 115X Pressure Transmitter Maintenance {

(f) CPS No. 9431.19, Rev. 20, Reactor Level and Pressure Scram Response Time (g) CPS No. 9432.30, Rev. 20, Reactor Level / Main Steamline Pressure / Flow Isolation Instrumentation Response Time (h) CPS No. 9433.09, Rev. 20, ECCS Reactor Vessel Water Level B21-N095A(R) Channel Calibration (i CPS No. 0433.34, Rev. 20, LPCS System Response Time (j CPS No. 9433.35, Rev. 20, LPCI System Response Time (k CPS No. 9433.36, Rev. 20, HPCS System Response Time (4) Scope of Review Procedures (a) and (h) were reviewed in detail; procedures (f),

(g), (1), (j), and (k), upper documents of procedure (a), were reviewed in detail; and procedures (b)-(e) were reference The main criteria used as references for the review included CPS 1005.01, CPS 1011.05, and specific elements of NUREG/CR-136 (5) Results (a) CPS No. 1005.01, paragraph c8.1.2.2 states "all procedures...shall be in the format shown in Appendix A".

Appendix A, References, a) states that "This section (References) shall be numbered 11.0". NOTE: " Ensure that references are the most current and CPS specific". It was not possible to determine if the documents referenced in section 11 were the most current because revision numbers were not included with the referenced document.

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This matter'was discussed with representatives of IP who informed the inspector that six procedures controlled revisions to procedures and documents including:

CPS No. 1005.01, " Preparation, Review, and Approval

of Station Procedures and Documents CPS No. 1005.07, " Periodic Review of Station

' Procedures and Documents"

• CPS No. 1006.01, " Document Control"

• CPS No. 1005.04, " Distribution and Control of Station Procedures and Revisions"

,. CPS No.1003.01, " Design Control and Modifications"

CS0-053, " Updating and Obtaining Sorts of the Procedure Cross Reference"

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~ A review of the above procedures by the inspector showed

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that revisions to and updating of procedures was

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l adequately controlle ,

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(b) CPS No. 1005.01, Appendix (Format), and NUREG/CR-1369 discuss acceptance criteria. CPS No. 1005.01 states

" specific acceptance ' criteria against which test results shall be judged for approval / disapproval shall be clearly stated". Section 9 of each prccedure is required to state applicable acceptance criteria. Some of the procedures reviewed by the inspector did not have specifically stated

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acceptance criteria in section 9 for making sound judgments about operability of systems, components or devices. In some cases, acceptance criteria were

!

dispersed throughout the procedural steps so the person performing the test was made aware of what to expect during a test.

(c) Although not a requirement, none of the procedures

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reviewed had QC witness / hold points or surveillance notification points as discussed in section 2.2 of

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CPS No. 1005.0 The procedures had been reviewed by

the quality organization who chose not to insert witness or hold points. Ongoing revisions to the Maintenance Work Request program should include insertion of QC point ;

i (d) Although not required, NUREG/CR-1369 considers " double verification" of alignment for certain types of component CPS No. 1005.01 does not discuss this aspect but it is implied in some procedures. This matter was clarified by representatives of IP. Independent and dual verification are adequately addressed by surveillance

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(e) Prerequisites and plant conditions were stated in upper tier documents but not in working documents. This is not considered a problem because technicians are trained to refer to upper tier documents and determine plant conditions prior to conducting a surveillance tes (f) In most instances, instructions were written in short, concise, identifiable steps. With a few minor exceptions, for those procedures reviewed the " Complexity Index" and

" Specificity Index" met or exceeded the guidelines stated in NUREG/CP.-136 (6) Conclusion The inspector concluded that the minor discrepancies identified in the above surveillance procedures will not lead to errors in performance of calibration or tests. Based on discussions with IP representatives, the procedures will be periodically reviewed and revised based on operating experienc No violations or deviations were identified, Safety Committee Activity (40301)

The inspector attended and observed two meetings 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 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 safety. The inspector observed FRG meetings held on May 20 and 21, 1986. The meetings specifically addressed a matter of interest to the inspector - 10 CFR 50.59 Safety Evaluation program change No violations or deviations were identifie . Independent Inspection Effort Plant Staff Maintenance Program Implementation (62700)

(1) Introduction The inspector conducted an independent inspection of maintenance activities performed by plant staff. The objective of this inspection was to evaluate the effectiveness of the maintenance program being implemented by the applicant's " plant staff" maintenance department. A similar inspection was performed on the applicant's maintenance contractor, Stone &

Webster (S&W), during a previous report period. The results of that inspection were documented in Inspection Report No. 50-461/8602 , _ _ - _ _ _ _ .

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(2) Details The primary procedure referenced during this inspection was CPS No.1029.01, " Preparation and Routing of Maintenance Work Requests", revision 8. The following safety-related Maintenance Work Requests (MWRs) were selected as a representative sample of the plant staff's ongoing and completed maintenance activitie B-11648 B-11901* B-12991 B-13010 B-14698 B-17936 B-25208 B-25301 B-27528 B-31896 B-31897 B-32689 B-32861 B-34665 B-35103 C-00075 C-00456 C-01473 C-01713 C-02143 C-03222 C-03921** C-05492 C-05637**

C-05854 C-05942 C-07267 C-07277 C-07717 C-07730 C-07767 C-12292 C-12589 C-16866 C-17086 C-17456 C-18033 C-18111 C-18122 C-18123 C-18129* C-18258 C-18609 C-18910 C-19011** C-19556 C-19583 C-19604**

C-19989 C-24041 C-24048 C-24049 C-24216 C-24375** C-25050 C-25058 C-25139 C-25162 C-25192 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; inspection and hold points were identified in the procedure or in a documented plan; provisions for control of lifted leads was adequate; approval obtained from operatic prior to commencing work; measuring and test equipment was maintained in calibration; and completed MWRs had been cycled through all required reviews prior to close-ou As was done during the inspection of the applicant's maintenance contractor, S&W, the above MWRs were reviewed by an experienced NRC contractor who had performed similar inspections at four other nuclear plants in Region IV. In addition, the Clinton resident inspector reviewed a portion of the above MWRs using the attributes above as the inspection criteria. The MWRs marked with a single asterisk (*) were asseabled by the applicant as completed packages with all referenced document The MWRs marked with a double asterisk were observed in the field as on-going maintenance activitie Responses to NRC questions asked during this inspection effort were documented in Illinois Power memorandum RAH-026-86 dated June 12, 1986. The responses provided answered all the remaining questions asked by the inspectors during this inspection effor . _ . _ __ . -

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(3) Results Since the previous inspection of S&W maintenance activities identified several examples of failure to follow procedures (see Inspection Report 50-461/86023, Notice of Violation), the inspectors concentrated their review on MWRs that had been closed by plant staff after the S&W inspection. This inspection indicated the applicant had taken action to increase the attention to detail in the implementation of the MWR procedure by plant staff maintenance personne Based on the review of completed MWRs, observation of maintenance activities in progress, and interviews conducted with plant staff maintenance personnel, the inspectors concluded that, for the MWRs within the scope of this inspection, the MWR program was implemented by the applicant's plant staff in accordance with the requirements of the approved procedur No violations or deviations were identifie b. Operational Safety Verification (71707)

This inspection was performed in order to assist Region III in their evaluation of the readiness of CPS to load fuel. The inspection was performed using an inspection procedure that is normally applied to plants in operatio The inspection consisted of a review of applicable procedures for declaring plant systems technical specification operable; observation of a plant staff operator performing a partial walkdown of the Low Pressure Core Spray (LPCS) System; review of the implementation of operational administrative controls for the LPCS system; and observation of the conduct of control room activities for portions of two shifts, including shift relief / turnover activitie (1) Procedures / Documents Reviewed (a) CPS No. 1014.02, " Designating Systems Ready for Fuel Load",

Revision 3, dated May 28, 198 (b) CPS No. 1410.01, " Conduct of Operations", Revision 7, dated May 28, 1986; paragraph 8. (c) " System Ready For Fuel Load Declaration - LPCS", dated May 9, 198 (2) Discussion /0bservation (a) Review of the procedures referenced in paragraph 8.b.(1)(a and b) above indicated that the procedure for

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declaring systems technical specification operable, CPS No. 1401.01, paragraph 8.5.6, did not reflect minimum requirements needed prior to the declaration of operability (that is, the procedure primarily consisted of recommendations and allowed methods of operation rather than imposing minimum requirements). At the time of this inspection, no plant systems had been declared operable under the CPS Technical Specifications. This matter was discussed with the applicant who stated that the procedure would be revised to impose minimum requirements for the initial declaration of technical specification operability. This matter is open pending review of the revised procedure (461/86037-04A).

(b) Review of the LPCS system declaration package referenced in paragraph 8.b.(1)(c) above revealed that the system walkdown had been performed using revision 2 of the procedure. That revision only required a walkdown of the system for obvious damage. Revision 3 to CPS No. 1014.02 required a much more extensive system walkdown by both the plant technical system engineer and by a plant staff operator using a somewhat detailed checklist. Since the Supervisor - Operations Support was unable to identify the individual who performed the LPCS walkdown that was documented in the LPCS system declaration package, the inspector requested that a plant staff operator demonstrate the performance of the LPCS system walkdown under revision 3 of CPS No. 1014.02 using the new checklist. Observation of the walkdown process indicated

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that the walkdown could be improved if a systematic approach was specified, that is, marking up system drawings as the walkdown progressed or similar approach to assure that all applicable components were checked. The walkdown performed by the plant staff operator identified l numerous minor discrepancies that should have been identified and corrected if the earlier walkdown had been effective. Discussion with the applicant indicated that a final walkdown of plant systems would be completed prior l to declaring systems operable under the CPS technical i specifications. This item is open pending verification of I final walkdowns for systems declared operable under the l CPS Technical Specifications (461/86037-04B). '

(c) The following operational administrative controls were reviewed for the LPCS system:

Main Control Room Journal Safety Tag Log Component Abnormal Configuration Log Temporary Modification Log Limiting Condition for Operation (LCO) Log Shift Supervisor Journal

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Outstanding Radiation Work Permit Log System Status File Maintenance Work Request Log Control Room Master Surveillance Schedule Shift Turnover and Relief Status Report Night Orders The inspector noted that the logs, files, schedule, and journals were implemented and up to date with two exceptions; the Temporary Modification Log was not being used to track out of service annunciatorc as required by CPS No. 1014.01; and the LC0 Log was not up to date for one LC0 that was being tracked by the plant staff operators for practice / experience. No actual LCOs existed at the time of the inspection. The LC0 log was promptly corrected by the on-duty Shift Supervisor. The applicant stated that the matter of tracking out of service annunciators would be addressed in a revision to CPS No. 1401.01 and the revised method would be implemente This item is open pending followup inspection to verify implementation of the revised procedure (461/86037-04C).

(d) Observation of the conduct of control room activities indicated that activities were carried out in an orderly and controlled manner; that personnel did not refer to plant procedures during the performance of routine activities; that there was a lack of knowledge of the requirements of CPS No. 1401.01 on the part of the control room operators; and that several very minor discrepancies in the implementation of CPS No. 1401.01 requirements existed as a resul Each minor discrepancy was discussed with responsible supervision on June 30, 1986. The inspector observed that revision 7 to CPS No. 1401.01 was relatively recent and that the minor discrepancies may reflect deficiencies in the training provided to the plant staff operators prior to implementation of the procedure revision. The applicant acknowledged the discrepancies and stated that the observed conditions would be correcte Additional control room observation will be performed ,

prior to fuel load to assure proper implementation of CPS No. 1401.01 (461/86037-04D).

The inspector recommended that the applicant increase the frequency of self-audits in the control room in order to provide self-identification and correction of minor procedural discrepancies. The inspector also recommended that the applicant's operators refer to and use the plant operating procedures during the conduct of routine control room operations; the recommendation was based on the need to familiarize the plant operators with recently revised plant operating procedures. The applicant acknowledged the inspector's recommendation .- --- .

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Results One open item requiring followup inspection prior to fuel load was identified (461/86037-04).

No violations or deviations were identifie . Region III/ Headquarters Requests (92701) Review of Draft CPS Low Power Licence The inspector reviewed a draft Low Power License for CPS as requested by Region III. The draft license was dated May 29, 198 Comments were provided to Region III for transmittal to the NRC Office of Nuclear Reactor Regulatio Draft Information Notice - Stuck Control Rod ,

The inspector reviewed a draft of an information notice prepared by the NRC Office of Inspection and Enforcement (I&E) based on an incident that happened during preoperational testing of the Control Rod Drive System at CPS. The incident involved mispositioning of a valve wM ch resulted in damage to one control rod drive mechanis Comments on the draft information notice were transmitted to I& IP Fitness for Duty Program - Positive Drug Screening Test

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The applicant informed the inspector in April thau positive drug screening test results had been confirmed for an IP QC inspector under the IP Fitness For Duty (FFD) Program. The QC inspector had been processed in accordance with the FFD program provision The inspector reviewed the applicant's actions taken to verify there had been no impact on plant quality / safety as a result of the apparent drug use by the QC inspector. The applicant had performed a review of the QC inspector's work using a random sampling plan developed by IPQA (Quality Systems and Audits). The sampling inspection involved a total of 260 of 341 activities performed by the QC inspector involved. The results of their statistical sample inspection identified no discrepancies in the work that was inspected under the statistical sampling plan. This information provided a high level of confidence in the work performed by the individua In addition to the above, the inspector interviewed the QC inspector's supervisor concerning the inspector's past performanc No abnormal behavior had been noted by the supervisor prior to the FFD positive test result The inspector concluded that no additional NRC action was required on this matte __ _

O IP Plans To Construct low Level Radioactive Waste Storage Facilities Region III requested the inspector contact the applicant and determine what plans, if any, IP had to construct onsite low level radioactive waste storage facilitie The inspector contacted the IP Manager - Licensing and Safety (L&S)

concerning this matter. L&S personnel responded that IP had no formal plans to construct onsite low level radioactive waste storage facilitie The need for construction of such facilities is reviewed annually by IP. The inspector requested that IP inform the resident inspector of any change in their plans based on their annual revie This information was communicated to Region II No violations or deviations were identifie . Site Activities of Interest Fuel Load Schedule (94300)

The applicant provided a letter dated June 17, 1986, in which they notified the NRC Office of Nuclear Reactor Regulation that CPS would be ready for issuance of a low power license on or about July 15, 1986. A public meeting with IP and NRC management was scheduled at the CPS Visitor's Center for July 10, 1986. The applicant's fuel load schedule will be reviewed in detail at that time, Readiness For Fuel Load Meeting (30702)

On June 10, 1986, NRC Region III management met with IP management at the Region III Office in Glen Ellyn, Illinois, to discuss the current state of readiness of CPS to load fuel. This was the fifth of a series of such meetings to be held with IP management on a routine (monthly) basis. Personnel attending the meeting are identified by (+) in paragraph 1 of this repor The meeting, which lasted about two hours, included the following: l (1) A short briefing by the Vice President - Nuclear concerning the status of the facility and actions being taken to address current problem i (2) Preoperational Test Program Statu (3) Test Deferral Reques (4) Status of the conduct of surveillance testing for credi i (5) Plant procedure statu (6) CPS " Things" lis {

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d (7) Activities to Facilitate the Transition from Construction to an Operational Mod The IP Vice President - Nuclear concluded the meeting with a brief discussion of activities to close out the construction projec Both Region III and IP management agreed to schedule the next monthly management meeting for July 10, 1986, at the CPS Visitor's Center in conjunction with a scheduled NRR site visi . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. One unresolved item disclosed during this inspection is discussed in paragraph . Open Items Open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which will involve some action on the part of the NRC or applicant or both. Two open items disclosed during the inspection is discussed in paragraphs 2.d.and 8 . Exit Meetings (30703)

The inspectors met with applicant representatives (denoted in paragraph 1) throughout the inspection and at the conclusion of the inspection on July 1, 1986. The inspectors sunnarized the scope and findings of the inspection 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 / processes as proprietar The resident inspectors attended exit meetings held between Region III based inspectors and the applicant as follows:

Inspector (s) Date C. Scheibelhut 5/16/86 R. Sutphin 5/16/86 K. Ward 5/21/86 J. Neisler 5/22/86 B. Drouin 5/22/86 C. Gill 5/23/86 M. Oestmann 5/30/86 P. Kaufman 6/5/86 J. Holmes 6/6/86 C. Scheibelhut 6/13/86

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