IR 05000461/1986048
| ML20212N213 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/21/1986 |
| From: | Jablonski F, Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212N159 | List: |
| References | |
| 50-461-86-48, GL-85-07, GL-85-7, NUDOCS 8608280130 | |
| Download: ML20212N213 (38) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report No. 60-461/86048(DRP)
Docket No. 50-461 License No. CPPR-137 Licensee:
Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station j
Inspection At: Clinton Site, Clinton, IL Inspection Conducted: July 1-28, 1986 Inspectors:
T. P. Gwynn P. L. Hiland H. M. Stromberg C. H. Scheibelhut Y
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F.
-lonski k2//6b
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K. A. Connaughton
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M2//fd Approved By:
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Projec s Section IB
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Inspection Summary
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Inspection on July 1-28, 1986 (Report No. 50-461/86048(DRP))
Areas Inspected:
Routine safety inspection by three resident inspectors,
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one regional based inspector, and two contractor inspectors of preoperational
i testing and operational preparedness activities including applicant action
on previous inspection findings; generic letter followup; review of 10 CFR 21 report; employee concerns; functional or program areas (including site
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surveillance tours, operating procedures review; emergency procedure review; j
and plant procedures review); regional requests (including Safeteam status,
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diesel generator event followup, potential equipment tampering incidents,
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and operational readiness assessment); and site activitics of interest.
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Results: Of the thirteen areas inspected, two violations and one deviation i
were identified.
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8608280130 86082."2 PDR ADOCK 05000461 G
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The first violation (Paragraph 2.q.) indicated a continuing failure of plant staff maintenance technicians to pay attention to the details of their work
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and a continuing failure of their supervisors to identify and correct poor performance. A single example of this violation was identified, however the item is more significant since it represents repeat of a previous violation.
The second violation (Paragraph 6.a.(3)) was more significant to plant
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operational safety in that the cooling water source to one train of emergency core cooling system equipment would have been lost during an abnormally high a
lake level (flood). The violation resulted from the failure of the applicant's operational quality assurance program to identify and correct a construction deficiency prior to acceptance of the screenhouse by the operating organization.
The deviation (Paragraph 2.p.) indicated that the applicant's safety evaluation l
performed in accordance with the requirements of 10 CFR 50.59 prior to approval of the affected procedures had been ineffective in assuring that commitments
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contained in the Final Safety Analysis Report had been met by the procedures
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l DETAILS i
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Personnel Contacted
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IllinoisPowerCompany(IPl
+*K. Baker, Supervisor, I&E Interface, Licensing and Safety
- D. Burke, Lead, General, Instructor
+*R. Campbell, Director, Quality Systems and Audits
+*W. Connell, Manager, QA
- E. Corrigan, Director, Quality Engineering and Verification
+ H. Daniels, Project Manager i
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+*S. Fisher, Manager, Nuclear Planning and Support
+ W. Gerstner, Executive Vice President
+*J. Greene, Manager, Nuclear Statior. Engineering Department (NSED)
+*D. Hall, Vice President, Nuclear
+*H. Lane, Manager, Scheduling and Outage Management
- J. Loomis, Construction Manager l
+*J. Perry, Manager, Project Control Center
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+ T. Riley, Supervisor, Licensing Operations l
+ R. Schaller, Director, Nuclear Training
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+*F. Spangenberg, Manager, L&S
+*J. Weaver, Director, Licensing
+*J. Wilson, Manager, Clinton Power Station (CPS)
Soyland/Wipco l
+ E. Williams, Vice President j
- J. Greenwood, Manager, Power Supply U.S. NRC l
+R. Bernero, Director, Division of BWR Licensing, Office of Nuclear Reactor Regulation (NRR)
+W. Butler, Director, BWR Project Division 4, NRR
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+B. Siegel, Clinton Licensing Project Manager, NRR
+*T. Gwynn, Senior Resident Inspector, Operations
- D. Keating, Senior Resident Inspector, Construction-t
- P. Hiland, Resident Inspector
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+C. Norelius, Director, Division of Reactor Projects-l
+R. Knop, Chief, Projects Section IB
+B. Grimes, Director, Division of QA, Vendor & Tech. Training Center,
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Office of Inspection and Enforcement i
+S. Black, Technical and Operations Support Branch, NRR
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- R. Barnett, Region III
- Denotes those attending the monthly exit meeting on July 28, 1986.
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+ Denotes those attending the management meeting on July 10, 1986.
I The inspectors also contacted and interviewed other staff and contractor personnel.
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2.
Applicant Action On Previous Inspection Findings (92701) (92702)
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(Closed) Open Item (461/85005-43):
Verify that commitments listed
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in SSER2, Paragraph 9.3.5 are incorporated into the Clinton Core Damage procedure prior to fuel load (TMI Item II.B.3).
This item was previously reviewed by the inspector as documented in Inspection Report No. 50-461/85065, Paragraph 2.
During that review, the inspector identified a number of discrepancies which required additional action by the applicant, specifically the applicant was to provide an implementing procedure or instruction, approved by the Facility Review Group (FRG), which referenced Technical Specification Requirement 6.8.4.c and which was responsive to the SER requirements.
During this report period, the applicant again presented this item
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to the inspector for clo,sure.
The inspector reviewed procedure CPS No. 1890.30, Post Accident Sampling Program, Revision 0, dated July 3, 1986. The inspector noted that the procedure provided the information which had been missing in the previous inspection. This item is closed, b.
(Closed) Open Item (461/86016-03):
Verify that containment isolation valves are properly tagged.
During the conduct of a special NRC team inspection of the Clinton Technical Specifications, it was noted that a significant number of containment isolation valves were not identified with proper tags.
The applicant presented this item to the inspector for closure.
The applicant provided a complete list of containment isolation valves, annotated during a walkdown they had performed.
Discrepancies identified during their walkdown were documented as corrected. The inspector reviewed the valve tagging list and performed a spot inspection of nineteen valves. All valves inspected were properly tagged.
This item is closed.
c.
(Closed) Open Item (461/85039-01):
" Demonstration of capability to augment the onsite staff during an emergency to meet the 30 and 60 minute goals of table B-1 of NUREG-0654, Revision 1."
Upon activation of the emergency organization, key personnel must respond to augment onsite personnel in the manning of the Technical Support Center (TSC), the Operations Support Center (OSC), the Emergency Operations Facility (EOF), and the Joint Public Informa-tion Center (JPIC). Table B-1 of NUREG-0654, Revision 1, delineates minimum personnel and time response goals to activate.
The applicant's capability had not been demonstrated.
The applicant condt.cted an actual shift augmentation drill (personnel called and arrival'at the site logged) on February 13, 1986. The drill identified weaknesses in the notification scheme which resulted in a number of late arrivals. The applicant evaluated the test results and subsequently issued more pagers to shorten the notifica-tion time. The applicant then performed another drill for the groups having excessive late arrivals on April 14, 1986. The second
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drill was found to be successful. To demonstrate the overall capability of the staff augmentation program, the applicant initiated a call-out on June 23, 1986, in which the applicant exercised the notification system. Each notified emergency response organization member completed a questionnaire identifying notification time and estimating site arrival time.
The applicant reviewed the simulated call-out drill results and considered the drill successful. The inspector-reviewed the results and ' agreed that the applicant had i
demonstrated the capability to augment the onsite staff in the event of an emergency.
This item is closad.
d.
(Closed) Open Item (461/85039-10):
Equipment (sample containers, shielding,_ handling, and transport equipment) needed to enable sartpling at existing grab sample ports for the plant vent stack and Standby Gas Treatment system (SGTS) stack had not been developed and tested.
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The applicant presented this item to the inspector for closure. As a method of demonstrating that their system for sampling wotild function as required, the applicant simulated a condition where it
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was necessary to obtain a sample via a drill.
The drill sequence required plant personnel to obtain a sample from the SGTS accident
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range monitor exhaust. During the drill, the applicant demonstrated that, while dressed in anti-contamination clothing and self contained breathing apparatus, they could perform operations necessary for
obtaining samples. Their sample assembly consisted of a shielded
sampling unit in which a charcoal cartridge and filter had been l
installed. The sample assembly was connected into the sample path i
by using quick disconnect couplings that appeared to work easily and to seal completely. Once the sample assembly was connected in the sample path, the sample was drawn through the sample assembly.
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sample assembly was removed and transferred to the chemistry lab for sample analysis.
Once in the lab, the drill personnel procedurally demonstrated
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removing the sample. The sample assembly was disassembled while in l
a shielded, ventilated hood. Then the charcoal cartridge and filter
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j were removed using special handling tools.
l The applicant successfully cemonstrated their ability to obtain and analyze necessary samples in accordance with their procedures.
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inspector reviewed the accident range monitor exhaust flow path and found that a return path existed for uncollected samples to return l
to the sample lines. Based on the inspector's observhtions and j
review of drawings, this item is closed.
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(Closed) Open Ittm (461/85039-11):
Demonstrate the ability to safely collect and transport high activity level samples from the HVAC and Standby Gas Treatment System (SGTS) grab sample ports.
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On July 24, 1986, the a*pplicant initiated a drill which required a particulate iodine sample to be drawn from the SGTS exhaust transfer
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port. The drill sequence was for personnel to dress in anti-contami-
nation clothing and self-contained breathing apparatus and proceed to the sample site. Drill persennel carried a SA-16 shielded sample assembly (on a carrying rod), a copy of the procedure,'necessary.
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equipment for obtaining the sample and radiation monitoring equipment.
At the sample site, drill personnel demonstrated that it was possible to safely obtain a sample following CPS Precedure No. 1890.36, Stack
Effluent Sampling (EP), Revision 2 (a draft proceuure). Once the
sample was taken, it was demonstrated that tha sample could be transported safely to the Chamistry Lab. Transportation of the
sample was made by two personnel carrying the SA-16 sample assembly
on a rod specially designed for the task. Once the sample reached the chemistry lab, the sample assembly was transferred tc a shielded, ventilated neod.
The sample assembly was disassembled and the filter
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and cartridge sample analysis performed.
The inspector did not witness samples being taken from the accident range monitor exhaust (AXM) and SGTS. However, the AXM installation
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was inspected and found to be sufficiently unobstructed to allow sampling following tae same procedure. Based on the demonstration and inspection, the inspector concluded that sampling ability had been adequately demonstrated.
This item is closed.
f.
(Closed) Open Item (d61/85030-24): All emergency alarms must be completely installed and operational prior to fuel load.
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The applicant presented this item to the inspector for closure.
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The inspector reviewed preoperatior,al test procedure, PTP-CQ-01, Communications System, Revision 0.
This procedu.re was a completed, approved copy of the preoperational test procedure for the communications system at Clinton Power Station.
The test procedure adequately demonctrated the operability of the emergency alarm system. To verify operation, an alarm test is performed weekly.
On Tuesday, July 22, 1986, the test was witnessed. There was an
NRC inspector located in containment, on the turbine deck, and in j
the control room. The inspector in the control room clearly heard
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the test.
The inspector inside containment clearly heard the test but identified an inoperable speaker. The inspector on the turbine
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j deck did not hear the test at all.
The applicant researched and identified that, during conduct of the test, Division II electrical power had been deenergized for other
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maintenance activities. The inspector noted that the announcing i
system on the turbine deck receives Division II power which explained the inoperability.
The applicart wrote a NR for the inoperable speaker in containment. Based on this knowledge, the appropriate preoperational testing (PTP-CQ-01) had been completed, and the energized portions of the emergency alarm system worked per design. This item is closed.
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(Closed) Open Item (461/85061-04):
Failure of bolts en cell
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connections of division III battery.
During a previous inspection, review of a completed maintenance work report (MWR) identified that
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bolts for cell number 1 on the safety-related Division III battery had been stretched and stripped during replacement.
The nonconformance had not been properly dispositioned prior to closure of the MWR.
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The applicant. presented this item to the inspect..r for closure.
The applicant researched this item and determined that three inconsistencies existed: (1) the MWR identified tnat torquing
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had been recorded as 75 foot pouncs when it should have been to
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75 inch pounds, (2) the procedure did not identify a torque value that was applicable to the type of bolting material used, and (3) inadequate maintenance supersision review of MWRs.
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Concerning the issues of the torque value recorded and inadequate supervisory reviews, the applicant found that the torque wrench
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used had a range of 0-200 inch pounds, which would not allow 75 foot pounds to be reached.
Therefore, the applicant concluded
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j that the 75 foot pound entry on the MWR was a clerical error. The j
associated QC inspection report identified the torque wrench and
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supported the applicant's finding.
To prevent recurrence, the
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applicant required training for electrical maintenance technicians and supervision; they were instructed on paying attention to detail, providing complete and accurate work documentation, supervision g
responsibilities, and proper review of documents.
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the battery bolts, the applicant identified that the bolts should be tightened to " snug-tight."
The applicant defined " snug-tight" to be when the associated lock washer was flat.
To verify that the
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term " snug-tight" was understood by the electricians, the inspector I
interviewed seven Stone & Webster and one IP electrician. The IP l
electrician and two Stone & Webster electricians demonstrated their j
knowledge of the definition; the other electricians interviewed did j
not have a clear understanding.
The applicant subsequently co.nducted
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training for all electricians and training records were provided to j
the inspector for review.
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The inspector questioned the applicant as to whether or not the
I snug-tight criteria not being understood by all personnel could
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have resulted in bolts being over-torqued. The applicant stated
that if the bolts were over-torqued and the torque value went above i
the yield strength of the bolt, the failure would be identified during installation.
If tne torque did rpt cause failure, it would
constitute an individual severe load test and meet the design
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intent. There were no additional loads applicable to these bolted l
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This item is closed, h.
(Closed) Open Item (461/85005-44):
Verify the loose parts monitoring f
systems are operational prior to fuel load.
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The applicant presented this item to the inspector for closure.
The inspector reviewed procedures CPS No. 9000.01, " Control Room Surveillance Log," Revision 20, dated July 7, 1986: CPS No. 9037.20,
" Loose Parts Monitoring System Functional Test," Revision 20, dated June 13, 1986; and CPS No. 9437.20, " Loose Part Detection System Channel Calibration," Revision 20, dated May 17, 1986. These procedures appeared to be adequate to control calibration and surveillance requirements for this system.
The inspector also observed a control room operator perform applicable steps of CPS No. 9000.01 on the loose parts monitoring system. The system appeared to work properly. This item is closed.
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(Closed) Open Item (461/85065-01): Non-Licensed Operator Training.
During a previous report period, the inspector noted that a number of training requirements for non-licensed operators had not been performed due to the construction status of the Clinton Power Statien.
The Director - Plant Operations identified via memorandum DMA-0082-86, dated May 29, 1986, those qualification requirements for non-licensed training that were to be deferred until after fuel load.
This memorandum identified eight qualification requirements for system operation and/or practical factors siga-offs that would not be completed until commercial operation.
The inspector noted that the eight deferred qualification requirements were on nonsafety-related systems that were not required to be operating to support fuel load activities.
The inspector reviewed the Qualification Log (CPS No. 1402.04F003)
and the Qualification Record (CPS No. 1402.04F004):2eing aaintained in the Shift Supervisor's office in accordance with procedure CPS No. 1402.04, Operations Department Watchstanding Organization and Qualifications. The inspector noted that these logs were being maintained for all operations department shift personnel, both licensed and ncn-licensed.
The inspector selected a number of qualification requirements that had previously been waived during the construction phase of Clinton Power Station. The inspector confirmed that a Qualification Requirement form was assigned and that completion of the required training was docum2nted or selected individuals' Qualification Records.
The inspector confirm 2d that non-licensed training requirements were being maintained in acccrdance with applicable procedures and training which had been waived due to plant construction was completed (except for the eight qualification requirements toentified above).
This item is closed.
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(Closed) Open Item (461/86028-05):
Public address system and sound powered phone system operation.
During a previous inspection, the ir.spector identified that a number of public address system (gaitronics) and sound powered phone system components were inoperable.
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This item was presented to the inspector for closure.
The applicant presented signed off preoperational test results approval sheets for PTP-CQ-01, Communication System.
The inspector reviewed the completed test procedure results and noted that the test results appeared to be adequate. However, since test completion, numerous deficiencies have been identified in the Gaitronics communications system. A similar open item (461/85039-23) identified that the public address system must be operational prior to fuel load.
To reduce duplication of open items, this concern is closed.
Problems identified in the Gaitronics system will be monitored under open item 461/85039-23 (see Paragraph 2.u. below).
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(Closed) Open Item (461/86023-06A):
CPS Remote Shutdown Division II Equipment Testing and Training.
IP letter U-600533 dated April 21,
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1986, 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.
The in spector confirmed that Remote Shutdown classroom training with Division II Equipment was provided to 30 of the 33 licensed operators currently assigned shift duties.
In addition, a number of supervisory and technical sti.ff personnel were provided this training. The three licensed operatcrs that had yet to receive the committed training
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included one Assistant Shift Supervisar (SRO) and two Control Room Operators (RCs). All three of these individuals were scheduled to
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receive Remote Shutdown training during their next Licensed Operator Requalification training effort.
As documented previously (reference Inspection Report No. 50-461/86037), the inspector observed " hands-on" training provided to a number of plant operators during the conduct of a confirmatory test. The confirmatory test was performed to demonstrate that Division II Residual Heat Removal (RHR) and Shutdown Cooling (SX) systems could be operated from outside the main control room.
Based on the observed " hands-on" training and the documented classroom training provided to licensed operators on the procedures for remote shutdown using ESS Division II controls and eqiipment, this item is closed.
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(Closed) Open Item (461/86026-010):
Post Maintenance Testing.
During a previous report period, the inspector questioned the status of Post Maintenance Test (PMT) requirements identified in the body of maintenance procedures since PMT requirements were addressed separately in administrative procedure CPS No. 1029.01,
" Preparation and Routing of Maintenance Work Roquests." A related concern regarding the adequacy of the PMT program was identified as an unresolved item (461/86023-05).
This unresolved item was initiated to follow the IP Operations Department response to an
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IPQA audit finding (IPQA Audit finding Q38-86-10) that identified a breakdown in the administrative controls.
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i During this report period, the inspector conducted an extensive
review of the current program established by the applicant to identify, monitor, and perform post maintenance testing. The
inspector reviewed administrative procedures CPS No. 1401.01,
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Conduct of Operations, Revision 7 and CPS No. 1029.01, Preparation l
and Routing of Maintenance Work Requests, Revision 10.
In response to the inspector identified concerns and the applicant's own audit findings, the applicant revised the programmatic /
administrative controls over the PMT process. CPS No. 1029.01-identified in Section 3.5 that the Director - Plant Operations was
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rssponsible for... the identification and performance of pMT in
accordance with CPS No. 1401.01, CONDUCT OF OPERATIONS." The flowpath detailed in CPS No. 1029.01, Figure 1, showed the completed i
maintenance work request (MWR) copy being routed to the Shift
Supervisor to " Perform PMT."
I CPS No. 1401.01, " Conduct of Operation," was revised to include
direction for post maintenance testing evaluation and tracking.
i Section 8.5.7 of CPS No. 1401.01, Revision 7, detailed the process for determining the need to perform a PMT evaluation. Appendix A to CPS No. 1401.01 provided criteria to be used by the Shift Supervisor j
and/or Assistant Shift Supervisor in determining requirements for PMT.
l In response to NRC questions regarding the applicant's commitment to l
their augmented-D Quality Assurance program, the applicant' revised
Appendix A to CPS 1401.01 to include a PMT review for augmented-D (Quality Group E) systems. As a minimum, a review for PMT was required for all safety-related MWRs, fire protection MWRs,
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augmented-D MWRs, IEEE Class IE MWRs, and MWRs requiring ISI
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In addition to the controls established by the change to CPS
No. 1401.01, " Conduct of Operations," the applicant performed a
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review of all MWRs completed on Phase II released (turned over to i
plant staff) systems between May 16, 1985 and the issuance of
Revision 7 to CPS No. 1401.01 (May 28, 1986). The purpose of this
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review was to "Backfit" the current post maintenance test program
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reviews onto MWRs that had not had the required PMT performed under j
the previous program.
I The applicant stated that some PMT requirements were included j
in maintenar.ce procedures. The applicant stated that those
. requirements were identified in order to determine the adequacy of
'the work performed under the procedure. The inspector noted that
i Section 8.5.7.1.1 of CPS No. 1401.01,' Revision 7, detailed the i
PMT requirement review performed by the Shift / Assistant Shift
Supervisor.
PMT requirements determined from the above review
I were to t'e documented on CPS No. 1401.01F008, PMT EVALUATION.
In addition, the program provided that maintenance personnel tray recontend the performance of additional PMT.
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l The inspector verified by direct observation and interviews of cognizant applicant personnel that the programmatic controls described above were in place.
Implementation of the PMT review
program is discussed further in Paragraph 2.y. below. This item a
is closed.
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(Closed) Open Item (461/86030-01):
Post maintenance testing following modifications performed on emergency diesel generator lubricating oil system.
During a previous inspection, the inspector i
identified post maintenance test documents included in modification i
packages TDG-58 and TDG-59 that had the post maintenance test requirements marked not applicable (N/A) without required signatures
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and dates.
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The applicant presented this item to the inspector for closure. The
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inspector reviewed final document packages and determined that the
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applicant had re-reviewed and obtained appropriate signatures.
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Necessary PMT had been performed but the PMT evaluation had not l
been documented. To prevent future occurrences of post maintenance j
testing being completed, the applicant provided Technical Department
personnel with training in post-maintenance testing review techniques.
The applicable training records were reviewed by the inspector.
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This item is closed.
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(Closei) Open Item (461/86040-02):
Process Grab Sample Lines.
During a previous 1.nspection, it was identified that five of 116 radwaste system grab sample lines were plugged.
t The applicant presented this item to the inspector for closure, i
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Closecut documentation demonstrated that the sample lines in
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question have been unplugged. Also presented were the results of
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an evaluation made by ~the CPS Chemistry 1cpervisor which determined
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that the line plugging was the result of abnormal valve lineups required to support startup test activities, higher than normal
amounts of solid matters. fro's initial plant flushing activities
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(resins, particulates, dirt and debris), and operator inexperience.
l The Chemistry Supers!sor felt that once startup activities are i
completed and plant operators gain necessary experience, the problem
would be resolved.
Based on the sample lines being unplugged and
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the Chemistry Sup'arvisor's evaluation results, this item is clcsed, o.
(0 pen) Open Item (4G1/84025-01): CPS descriptior s not naintained up to date.
During a review of the Clinton training department's license review course, the inspector identified that CPS system i
l descriptions were'not being maintained up to date, i
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j The applicant's Nur, lear Station Engineering Department performed t
j a review of all system training lesson plans to ensure that
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i information in the training material was correct and accurate.
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With this review as the baseline, the applicant had established
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proceduralized controls for the Nuclear Training Department to maintain lesson plans current with respect to system design,
operating procedures, and industry experience.
The applicant has stated that the use of system descriptions is not needed sinca lesson plans provided to each candidate were very detailed. The inspector noted that 39 of 44 candidates received their SRO license and 14 of 16 candidates received their R0 license based on training provided using the detailed lesson plans.
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The applicant awarded a contract for development of up-to-date system descriptions. This contract was scheduled for completion
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in December 1987.
This item will remain open pending review of
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j completed system descriptions, p.
(0 pen) Open Item (461/85005-32): Verify that procedures to ensure independent verification of system lineups are completed before fuel
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load (TMI Item II.K.1.10).
The applicant presented this item to the inspector for closure.
The inspector reviewed portions of the following procedures:
CPS No. 1401.01, " Conduct of Operations," Revisions 6 and 8,
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CPS No. 3312.01, " Residual Heat Removal (RHR) System Operations,"
Revision 3, and CP3 No. 3313.01, " Low Pressure Core Spray (LPCS)
System Operations," Revision 3.
CPS No. 1401.01 was reviewed to determine if a communications link existed that ensured control
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room operators were notified when system lineups were changed.
Both revisions of the applicable procedure delineated the sequence
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j for shift communications flow. The inspector observed performance j
of a tagout of the division 2 battery (Tagout No. 86-4639) to verify the communications sequence was being followed. The communications
were in accordance with CPS No. 1401.01 and appeared to be adeqdate.
i Valve lineups in procedures CPS No. 3312.01 and 3313.01 were compared to requirements identified in FSAR Sections 6.3.7.8.,
13.5.2.1.1, and Appendix D.
The inspector fcund that the valve i
lineup sheets in the referenced procedures did not provide an
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j independent verification for all valves in the safety-related systems / components as committed in the FSAR sections.
Numerous locked valves (as required by the FSAR) as well as system vent
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and drain valves were not independently verified.
In particular,
independent position verification was provided for only 19 of
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l approximately 53 valves in the LPCS system.
In addition,
discrepancies existed between' system valve lineups such that valves l
of similar function required independent verification in one ECCS j
system and not in the other.
This was a deviation from FSAR commitments (461/86048-03). This itcm remains open pending
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resolution of the above deviation and additional inspection.
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(0 pen) Open Item (461/85005-41):
SSER2, Paragraph 7.4.3.2 - Verify
installation of loss of voltage alarms prior to fuel load.
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This item was previously reviewed for closure in Inspection Report No. 50-461/86023.
That inspection identified that two of the five loss of voltage alarms had been identified as deficient on Startup Test Authorization Form (STAF)85-102.
The STAF referenced an MWR that was intended to correct the two deficient alarms. The MWR referenced on the STAF did not address either of the alarms involved; a separate MWR contained in the closure package did address one of the deficient alarms. However, the MWR was closed without completion of a required functional test; this was identified as a violation
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(461/86023-01A). At the time the closure package was returned to the applicant, the inspector had reviewed no information concerning the other deficient alarm.
The applicant again presented this item to the inspector for closure.
Review of the information presented indi:ated that the alarm which was the subject of the previous violation had been adequately tested and demonstrated to be operational.
However, the information provided did not clearly demonstrate tnat the second alarm was operational.
Due to the lack of clarity in the documentation, the inspector requested and the applicant performed an eperational test of the two alarms which had been in question.
The alarm that was the subject of the previous violation functioned properly; the second alarm failed to function as required.
A prompt review by the applicant revealed that the maintentnce technician assigned to correct deficiencies identified on
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STAF 85-102 had not completed MWR C06466 in accordance with the job steps. This was a violation of CPS No. 1029.01,' Revision 10, Preparation and Routing Of Maintenance Work Request's,
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Paragraph 8.2.21 which required that the maintenance group supervisor evaluates the MWR for adequacy of corrective action taken and work completion (461/86048-02).
This violation appeared to be a repeat of the previous violation.
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This item remains open pending demonstration by the applicant that all five loss of voltage alarms will function as required.
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(0 pen) Open Item (461/85012-02A):
CPS procedures had not received an independent technical review.
Several administrative procedures reviewed by the inspector did not reflect the applicable requirements of ANSI N18.7-1976, the CPS technical specifications, and other regulatory requirements.
This item was previously reviewed in Inspection Reports No. 50-461/85045, 85053, and 85065. As a result of the inspection documentcc in Inspection Report No. 50-461/85065, Paragraph 8.6.,
the applicant was requested to respond to the unresolved item in writing. 'lhe applicant % response, documented in IP letter U-600544 dated April 30, 1986, identified the corrective actions taken and indicated that all corrective actions would be complete by May 15, 1986.
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Subsequent to that date, an NRC inspector identified another apparent example of this unresolved item (unresolved item 461/86017-04f, follc.wup inspection documented in Inspection Report No. 50-461/86049,
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Paragraph 2.b). In addition, folloi up inspection on unresolved item 461/85012-03 (documented in Paragraph f:.s. below) indicated a continuing failure of CPS administrative procedures to meet the
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requiremer,s of the applicable CPS tecqnical specification.and 10 CFR 50.59. These recent inspection results indi:ated that the
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i corrective actions taken by IP to datt may not have been effective in resolving this item.
The applicant presented this item to tha inspector for closure.
The management ccrrective actions taken, as documented in IP letter U-600544, were as follows:
(1) CPS Procecure 1003.01 has been revised to include applicable
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requirements.
(2) A program ta train and qualify independent technical reviewers for procedure revies has been implementel.
(3) Trained reviewers (corrective action No. 2) have completed a review of all plant safety-related administrative control procedures.
(4) Procedure revisions to incorporate items identified during the above review (corrective action #3) will be completed by
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May 15, 1986.
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i The inspector asked IP management if they had prepared the source document index required by ANSI N18.7-1976, Paragraph 5.1, and if
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that index had been used during the conduct of independent technical reviews. The index had been prepared but was not used during the
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reviews. The inspector suggested that IP management consider reviewing their program against the applicable requirements prior to NRC review of this item for closure. This item remains unresolved.
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(0 pen) Open Item (461/85012-03):
Plant staff procedures for document control were improperly classified and had not received an appropriate level of review.
The a,plicant presented this item to the -inspector for closure.
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The inspector reviewed the results of a detailed QA audit conducted
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In addition, the inspector verified that the specific procedures that had been of
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concern had been reclassified and had received the required level
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of review and approval.
However, review of the applicant's Operating Manual Status Report (OMSR) indicated that a significant number of plant administrative procedures remained that were classified as nonsafety-related, no Facility Review Group (FRG) review required.
The followir.g issues were identified as remaining unresolved:
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(1) Technical Specification (TS) 6.5.1.6.a required that the
FRG, the onsite independent review committee for CPS, shall be responsible for review of all administrative
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procedures and changes thereto. CPS procedures implementing the TS requirement included the following:
l (a) CPS No. 1001.03, Facility Review Group
(b) CPS No. 1001.04, Facility heview Group Review Of l
Assigned Documents (c) CPS No. 1005.03, Operating Manual Status Report
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I CPS No. 1001.03, Revision 5 dated March 12, 1986, Paragraph 3.3.1 reflected the TS requirement (verbatim).
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CFS No. 1001.04, Revision 2 dated April 12, 1986, Paragraph 8.1 provided the administrative controls for implementation of the TS required reviews.
In accordance
with Paragraphs 8.1.1, 8.1.2, and 8.2, the FRG reviewed
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j only those plant procedures with a class code of SXXX.
l Procedure classification codes were assigned in accordance with CPS No. 1005.03, Operating Manual Status Report
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l (OMSR). The purpose of this procedure was to provide guidelines to personnel preparing computer input sheets for the OMSR which in turn controls the initiation and revision of the OMSR and tracking of all station procedures (including plant administrative procedures).
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The procedure also provided guidelines to personnel
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be classified as safety-related (SXXX class code) or j
nonsafety-related (NXXX class code). The guidelines i
explicitly addressed plant administrative procedures
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in Appendix A but did not require review of all plant administrative procedures; the determination as to whether
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i or not a plant administrative procedure required FRG l
review was thereby left to the judgement of each plant
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department.
Procedure CPS No. 1005.02, Organization Of The Station Sperating Manual, Revision 8 dated March 21, 1986,
identified the plant administrative procedures as being those procedures designated as CPS No. 1XXX.XX. NRC
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review of the CPS operating manual on July 18, 1986, j
identified that approximately 150 of 250 total IXXX.XX CPS l
procedures had a class code of SXXX. This indicated that
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l about 40'. of the CPS administrative procedures were not
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being reviewed by the FRG.
Procedures not receiving FRG review ranged from CPS No. 1005.02, Organization Of The
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Station Operating Manual and CPS No. 1038.01, Control 08
Technical Specifications to CPS No. 1101.99, Control
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l Of The IP Recreational Area. This inspection result indicated that the applicant's corrective actions under the unresolved item had not been adequate to assure that the letter of the TS requirement had been met.
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(2) In addition, the inspection identified that the plant
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administrative controls for downgrading the safety classification of station procedures contained in CPS No. 1005.03, Paragraph 8.4.4, allowed the individual department head to downgrade a procedure from safety to nonsafety-related without FRG review and plant nanager approval, even though the procedure originally required a 10 CFR 50.59 safety evaluation, FRG review and approval by the Manager - CPS. This matter appeared to be cantrary to the inter.t of CPS TS 6.5.1.6, 6.5.3, and 10 CFR 50.59.
The above matters were discussed with the applicant in a meeting between the NRC Senior Resident Inspector, an NRC contractor inspectnr, the Manager - Licensing & Safety, the Manager - Clinton Power '>.ation, and the Assistant Manager - Clinton Power Station on July 19, 1986.
The applicant'took the position that the administrative controls described and/or referenced above were l
i adequate to meet the intent of the technical specifications and regulatory requirements. The inspector was not in agreement. After
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reconsideration, the applicant committed to reclassifying all of
their administrative procedures to a safety classification and i
performing a 10 CFR 50.59 review on procedures that had been or will be downgraded.
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This item remains open pending demonstration that technical specification requirements are met.
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(0 pen) Open Item (461/85039-12):
Emergency Sampling and Analysis
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Procedures. During a previous inspection, it was identified that neither the " normal" nor the " emergency" procedure for sampling and analysis had been completed.
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The applicant presented this item to the inspector for closure. To resolve the item, the applicant was requested to perform a drill simulation to demonstrate that their procedures were adequate to
obtain and analyze samples. During the drill briefing, the i
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applicant presented the inspector with copies of CPS procedures j
RA-11, Stack Analysis and Sampling, Revision 2, CPS No. 1890.35,
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Stack Effluent Analysis (EP), Revision 2, and CPS No. 1890.36, Stack i
Effluent Sampling, Revision 2.
These three procedures were used q
for obtaining and simulating sample analysis. All three procedures
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appeared to work as intended.
However, all three procedures were draft procedures and were not approved by the appropriate personnel.
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The applicant stated that there were approved procedures in place I
and that the drafts were implementing improvements, i
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Since the drill simulation was demonstrated through draft procedures,
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the inspector was provided assurance that the revised procedure
would perform as intended. However, the assurance that the in place procedures would provide adequate guidance was not demonstrated.
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Therefore, this item remains open pending issuance of the revised procedures.
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(0 pen) Open Item (461/85039-23): The public address system must j
be completely installed and operational prior to fuel load.
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The applicant presented this item to the inspector for closure.
- The inspector reviewed a preoperational test procedure, PTP-CQ-01, Communications System, Revision 0.
This procedure was a signed off copy of the preoperational test procedure for the communications system at Clinton Power Station. The test procedure adequately demonstrated that the public address system had been installed and tested. However, during a plant tour by the resident inspector
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on June 21, 1986, a number of Gaitr'onics telephone units were determined to be inoperable. To evaluate the extent of the problem, i
operations personnel performed a walkdown of the Gaitronics
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communications system.
MWR C-21339 was generated to repair
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inoperable equipmentidentified during the walkdown.
This item remains open pending completion of the MWR and demonstration of
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equipment oeprability.
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(0 pen) Open Item (461/86016-04):
Standby Liquid Control System operability verification. During the witnessing of a surveillance l
test conducted by the applicant to verify standby liquid control operability, it was identified that the surveillance procedure (CPS No. 9015.01) could not be performed.
The applicant presented this item to the inspector for closure.
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The inspector reviewed CPS No. 9015.01, " Standby Liquid Control System Operability," Revision 22, as well as two marked up copies of Revision 20.
To permit initial procedure performance,
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temporary changes were made to Revision 20. Once the procedure i
was performed, permanent changes were made which resulted ir, i
Revision 22.
Revision 22 was reviewed and found to be adequate j
for test performance. This procedure was not required to be
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performed again until October 1986. A hold point was established
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so that the resident inspector would be notified prior to
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performance. This item remains open pending the inspector witnessing performance of the procedure.
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(0 pen) Open Item (461/86037-04A):
Review of applicable procedures
indicated that the procedure for declaring systems technical specification operable did not reflect minimum requirements needed
prior to the declaration of operability. The applicant statea that
the procedure, CPS No. 1401.01, Conduct of Operations, Revision 7, i
would be' revised to impose minimum requirements for the initial
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The inspector reviewed CPS No. 1401.01, revision 8, and found several discrepancies which were discussed in detail with the applicant. Those discrepancies related to the following:
(1) Providing for a final system / area walkdown to assure no conditions existed which would restrain system operability and to assure that the operational status of the system was documented correctly by plant administrative controls, i
(2) Providing a clearly defined and auditable trail for each system operability declaration.
(3) Defining the prerequisites to be met for system operability.
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Some minor clerical errors were also discussed. As a result of this discussion, revision 9 to CPS No. 1401.01 was issued on July 24,.1986.
In addition, Operations Standing Order No. 49, j
System Walkdown For Initial Operability, Revision 0, was issued the same date. Those revisions provided a basis for declaration of
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initial system operability that appeared adequate to assure that
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I each system required for operation was operable and that any inoperable items were adequately identified and tracked. Two i
questions remained open at the conclusion of this inspection, as
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follows:
i (1) IP was to provide a listing of plant systems required to I
support plant operation, by milestone, for NRC review.
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(2) CPS No. 1401.01, Paragraph 8.5.10.1.2. required "The Fuel Load Milestone Coordinator (FLMC) shall coordinate a review of the t
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i lists in Appendix B by the appropriate departments.
The
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departments shall ensure that the review verifies that open
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items associated with the lists are correctly coded as non fuel
load restraints."
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l The inspector requested that the FLMC identify the appropriate f
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departments for each item listed in Appendix B and identify the i
i criteria to be used to make the required determination.
l This item remair5 open pending review of the responses to each
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question above.
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(Closed) Unresolved Item (461/85012-028): Misclassification of Procedures.
During a previous inspection, it was identified that i
j some procedures had been misclassified as "N" (nonsafety-related)
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or "F" (non safety-related, FRG review required) and therefore did
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i not receive all required reviews, i
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This item was reviewed as part of unresolved item (461/85012-03; see
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Paragraph 2.s. above). The issue of misclassification of procedures i
was addressed in two active concerns; therefore, to reduce duplication, t
this item is closed.
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(0 pen) Unresolved Item (461/86023-05): Post Maintenance Testing Implementation Deficiencies. An IPQA audit finding identified
deficiencies in the applicant's program for the PMT. As described in Paragraph 2.1. above (open item 461/86026-010), the applicant
revised the procedures that were in place for control of post d
maintenance testing.
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The applicant performed a "litrited scope" audit of the implementa-
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tion effectiveness of the new PMT program during this report period.
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This limited scope audit indicated that some implementation i
deficiencies still existed in the PMT program.
This item will remain open pending review of the applicant's final response to the identified deficiencies.
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(Closed) Violation (461/85061-05):
Procedure for jurisdictional control of plant systems was changed by verbal directive rather than
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through the required review and approval process.
During a previous
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t inspection, the inspector identified that the Manager - CPS had
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provided verbal directives to remove requirements for hanging plant t
staff jurisdictional tags.
l The applicant presented this item to the inspector for closure. The inspector reviewed the applicable procedures (CPS No. 1440.01, i
" System Turnover and Release" and CPS No. 1040.01, " System Release
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Review and Acceptance">) and verified the requirements for
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jurisdictional tag hanging had been changed.
The applicant also
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held training for plant managers and operators.
Training records l
were reviewed. The actions taken appeared to be adequate. This
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item is closed.
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aa.
(0 pen) Violation (461/86017-03): A temporary procedure change
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(procedure deviation for revision or PDR) No.86-094 was issued
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against CPS No. 1029.01, Revision 7, Preparation and Routing of
i Maintenance Work Requests, in violation of procedure CPS No. 1005.07,
Temporary Changes To Station Procedures. The violation resulted in
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CPS No. 1029.01 being inadequate to control the documentation of
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l nonconforming conditions on a maintenance work request within the l
l requirements of the IPQ4 program.
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The applicant presented this item to the inspector for closure. The
closure package indicated that POR 86-094 was disapproved for use
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and that CPS No. 1029.01 was revised in accordance with site
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procedures.
In addition, the applicant had reviewed 959 MWRs that had been generated curing the period PDR 86-094 was in ef feet.
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i Their review was to ensure that there was no inadequate reporting j
and documentation of nonconformances in MWRs.
No deficiencies were
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identified by the applicant's review.
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l The applicant's response to the notice of violation stated that all
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plant staff members authorized to approve PDRs would be required to
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read the notice of violation prior to June 30, 1986 to prevent
recurrence of this violation.
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This inspection identified that only about 50% of the CPS personnel authorized to approve a PDR had read the notice of violation. This j
matter was discussed with CPS management and with the Vice President
- Nuclear at the exit meeting in order to assure that future
corrective actions are carried out as committed in a timely fashion.
j This item remains open pending completion of the required training.
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bb. (0 pen) Violation (461/86023-01): Maintenance work requests not per'ormed in accordance with written instructions, procedures, and i
drawings. An inspection of maintenance activities being performed
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by the plant staff maintenance department and the maintenance
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j contractor. Stone and Webster (S&W) identified a number of examples
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where written instructions were not adhered to.
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i During this report period, the applicant formally responded to the
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violation and stated that full compliance would be achieved by July 30, 1986.
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I Item "a." of the notice of violation'(NOV) identified a Maintenance t
Work Request (MWR) performed by plant staff that had work done that l
did nut address the problem described.
In addition, the post
maintenance functional testing required by the MWR job steps was l
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not documented as having been performed.
The applicant initiated
MWR-C20749 to perform a functional test of the item described above.
In addition, the applicant provided letters from the Supervisor -
l Control and Instrumentation (C&I) to the technician and Assistant
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(C&I) Supervisor involved with the original MWR stressing the j
importance of completing MWR Job steps, paying attention to detail, j
and reviewing work documents to ensure all work is complete.
The
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above comments were also stressed at C&I group meetings. Based on
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the above corrective action and the inspector having witnessed a
satisfactory functional test or the equipment involved in the i
original MWR, the inspector concluded the applicant's specific
corrective action in response to item "a." was adequate.
The violation identified in Paragraph 2.q. above will require an additional response concerning generic corrective action on this
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item. This matter will be followed under that violation.
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Item "b." of the NOV identified that maintenance work requests
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(MWRs) requiring a review by Quality Assurance after completion I
of work (identified as QMWRs) hac not been routed to QA prior to transmittal to the CPS records storage vault. The applicant
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initiated a Condition Report (CR No. 1-86-05-004) and identified all QMWRs processed by their maintenance contractor S&W. The applicant determined that 12 MWRs had been classified 4 QMWRs ano
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that ten of those had not receivec the requisite QA review. All
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f 12 QMWRs were resubmitted to IPQA for final review, and no adverse conditions were identified by the applicant. The applicant revised
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the governing procedure (CPS No. 1029.01), revised tracking forms used by the maintenance contractor, and provided training to S&W Maintenance Engineers.
Based on the above corrective action and a recent related inspection performed during the last inspection period (reference Inspection Report No. 50-461/86037, Paragraph 8),
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the inspector concluded that the applicant's response to item b" was adequate.
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Item "d." of the NOV identified a number of MWRs that did not I
receive the required ISI Repair Coordinator review prior to their being vaulted. The applicant initiated a Condition Report
(CR No. 1-86-05-008) and identified all MWRs that had been processed by S&W without receiving the required ISI review. A total of 42
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MWRs were found to need review and of that total, two MWRs required l
Post Maintenance Testing.
The. applicant provided training to the S&W Maintenance Supervisors, Planners, and Engineers who had responsibility for assuring that MWRs were properly processed for
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ISI review.
Based on the above corrective action and a recent i
related inspection performed during the last inspection period
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(reference Inspection Report No. 50-461/86037, Paragraph 8), the
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inspector concluded that the applicant's response to item "d." was adequate.
Item "c." of the NOV identified a MWR where work was performed
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r without routing the MWR back to planning. shen a change in scope was
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required. At the conclusion of the report period, the inspector was
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still reviewing the applicant's response. The inspector requested
additional information concerning the applicant's corrective action to avoid further violation.
Pending the' inspector's review of the
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requested information, this item will remain open.
One violation and one deviation was identified.
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l 3.
Generic Letter Followup (92703)
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(Closed) Generic Letter 85-07(461/85007-HH):
Implementation of integrated schedules for plant modifications. This generic letter distributed a survey forrr to collect views, intentions, and ccncerns regarding an integrated schedule for plant modifications.
The applicant responded to this generic letter via IP letter U-600207,
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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 prioritizatior i
methodology for plant modifications would be selected prior to fuel load.
This generic letter was reviewed in Inspection Report No. 50-461/86037.
At the time of that inspection, the applicant's files did not identify the prioritization methodology which IP had committed to provide prior
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to fuel load.
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During this report period, the applicant provided via IP memorandum
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Y-202760 dated July 15, 1986, a description of the intended prioritiza-
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tion methodology as follows:
a.
The originator of the Plant Modification normally suggests a priority of the modification at the time of origination in accordance with Clinton Power Station Procedure 1003.01 " Design Control and Modification."
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b.
In accordance with Corporate Nuclear Procedure (CNP) 4.08 " Plant Modification System," Sections 2.3 and 2.6, the Manager of Nuclear Station Engineering and the Manager of Clinton Power Station review and recommend a priority for plant modifications.
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c.
In accordance with CNP 4.08, Section 2.1, the Vice President is responsible for approving the priority and the schedule for Plant Modifications. Modification priorities are defined in Attachment 2 to CNP 4.08 as follows:
Emergency - flodifications which must be made immediately to avert or
j correct situations that could lead to the imminent loss of operating capability, damage to equipment, or endangerment of the health or
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safety of employees or the public.
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Urgent - Modifications for which installation is required to maintain safe, reliable, and efficirnt operation.
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Priorijt - Modifications which provide improvement in the safe, reliable, and efficient operation of the plant or result in
j significant cost savings ad are constrained by time and/or event.
Routine - Modifications which provide improvements in the safe, i
reliable, and efficient operation of the plant or result in cost j
savings.
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d.
Although not specifically required by procedures, the Director of Configuration Management monitors the scheduling and tracks the
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completion of Plant Modifications by Milestone designators.
l The applicant had selected a prioritization methodology as described i
above.
This item is closed.
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4.
Review of 10 CFR 21 Report (92700)
(Closed) 10 CFR 21 Report (461/80001-PP): General Electric (GE) Nuclear System Protection System (NSPS) power distribution panel C71-P011 deviates from separation requirements of Regulatory Guide 1.75 in that four
divisions of power plus nonessential power are used within the panel without isolation or proper isolation,
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s Correction of the deviation was accomplished by GE redesigning the power
distribution panels as well as modifying the NSPS panels to accept the new power distribution design.
Power distribution panel C71-P011 was replaced by two panels C71-P011A and C71-P0118.
Records contained in the IP file for this matter, 21-80-01, showed that IP had completed the installation of the two distribution panels, and GE had completed revisions to the NSPS panels to make them compatible with the revised
power distribution scheme. These changes were accomplished to satisfy i
concern identified in Item 8.4.7 of the Clinton Supplementary Safety
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Evaluation Report Supplement.
Construction and preoperational testing i
of the NSPS has been completed by IP. This matter is closed.
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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 submitted to Region III. Two concerns were transmitted to the regional office during this report period.
6.
Functional or Program Areas Inspected l
a.
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 corditions of plant equipment and material;
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potential for fire or other hazards which might have a deleterious
t effect on personnel or equipment; storage conditions of new fuel; i
and to witness maintenance and preoperational testing activities in
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progress.
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(1) New Fuel Storage
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Several tours of the new fuel storage area identified no deviations from the special nuclear materials license
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requirements for security, fire protection, and environmental controls'for new fuel storage.
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(2) Housekeeping and Cleanliness _ Control
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l Early in the report period, the inspectors observed that
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improvements in the cleanliness of the drywell had not kept
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pace with improvements observed in general plant cleanliness.
In addition, the cleanliness of the suppression pool and, in particular, the drywell weir area of the suppression pool, had degraded over past observations.
This matter was discussed
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j between NRC and IP management representatives on July 3, 1986.
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IP stated that prompt action would be taken to address the
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i current cleanliness condition and to' prevent recurrence.
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The next day, the resident inspectors observed that action had
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been taken to prevent further accumulation of dirt, debris, and other materials in the suppression pool weir area. Additional plastic had also been placed over access grating to prevent
dirt and debris from falling through the containment building
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and into the suppression pool. A large crew of laborars were
assigned to upgrade the cleanliness and housekeeping condition of the drywell and plans were prepared for cleaning the suppression pool using divers and a special underwater vacuum system.
The applicant made progress on this activity throughout the report period. At the conclusion of the inspection, the
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inspectors noted the following:
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(a) Diving operations had substantially improved the cleanliness of the suppression pool. The diving
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operations were still in progress on July 27, 1986.
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The drywell weir area was not available for visual inspection due to the installation of barriers to maintain cleanliness.
The applicant stated that the weir area had been returned to the required level of cleanliness.
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(b) Cleaning / housekeeping operations had improved the level of cleanliness in the drywell.
The work was still in progress on July 27, 1986. Additional cleaning / house-keeping was needed to achieve a satisfactory level of
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housekeeping in the drywell.
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(c) Continued attentioa to housekeeping and cleanliness
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control was needed and apparent.
The resident inspectors will continue to monitor the applicant's activities in this area.
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(3) Floodproofing Of Shutdown Service Water Pump (SSW) Cubicles On July 25, 1986, during a routine tour of the SSW portion of
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the CDS screenhouse, the inspector noted that a security vital j
area Loundary had been posted inside the Division II SSW pump cubicle. Since the SSW pump cubicles were designed to be a i
floodproof vital area, the inspector reviewed the matter and
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noted the following.
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i According to the CPS FSAR, Paragraph 9.2.1.2.3, the SSW pump
cubicles and all system piping are protected from tornado generated missiles and floods. According to FSAR Paragraph 3.4 1.1, measures adopted for seismic category I
systems and components located below the probable maximum flood
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(PMF) level (defined as elevation 708.9 feet for CPS) include:
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(a) water stops in all construction joints up to the maximum flood level; (b) water seal rings for all penetrations in exterior walls below the maximum flood level; (c) watertight caors designed to withstand the hydrostatic head of the PMF level on exterior walls below the maximum flood level; and (d) a hatch on the roof of the essential service water pump structure for access during PMF.
The inspector observed that the floor of the SSW pump cubicles was located at elevation 699.0 feet. The SSW pipe tunnel (at elevation 657.0 feet) was located below the SSW pump cubicles and connected directly to the division II SSW pump cubicle through a manway that had no watertight barrier. The pipe tunnel, which contained piping from all three divisions of SSW, ran across the entire eastern end of the screenhouse structure.
It had been designed to allow direct access from Unit I to Unit II (the cancelled unit) SSW equipment without leaving the vital area of the plant. Another manway from the pipe tunnel to the Unit II Division II SSW cubicle floor (the cubicle was never constructed) provided the access pathway; this exterior wall (floor) was not flood protected. Because Unit II was never completed, incomplete construction openings at the 699.0 foot elevation (which would have been on the floor of the Unit II SSW pump rooms) provided additional access to the SSW pipe tunnel; this exterior wall (floor) was also not flood protected. This finding indicated that the construction of the SSW portion of the CPS screenhouse had not been completed in conformance with the requirements of 10 CFR 50 Appendix A, General Design Criterion II and the CPS FSAR in that the Unit I SSW cubicles and system piping were not protected from the effects of flooding. Discussion with the applicant indicated that the screenhouse had been completed by the constructor, Baldwin Associates, and had been accepted by the applicant's operating organization on. December 11, 1985.
Implementation of the CPS Quality Assurance Program for turnover and acceptance of plant areas and commodities did not identify the above deficiency. The failure of.IP to assure that the screenhouse SSW system pump cubicles and piping tunnel were completed in compliance with the CPS FSAR prior to final acceptance is a violation of 10 CFR 50, Appendix B, Criterion II and the IP Operational QA Manual, Chapter 2, which states in part that the IP Nuclear Power Operational QA Program... is implemented to assure that necessary inspection and testing on the transferred system, structure, or component are performed
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and properly evaluated and to confirm that the system, structure, or component will perform satisfactorily (461/86048-03).
One violation was identified.
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b.
Operating Procedures Review (42450)
This inspection completed a review of procedures to be used in the plant operations phase (reference Inspection Reports No. 50-461/86017 86023, and 86037). The purpose of this inspection was to confirm that the plant operating procedures are prepared to adequately
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control safety-related operations within applicable regulatory requirements.
This inspection is complete with the exception of resolution of open/ unresolved i'tems identified during the inspection.
(1) Completed Review The operating procedures listed below have been reviewed and
y.,91aared to be technically adequate to guide the accomplishment of t~e purpose stated in the scope of the procedures. Questions n
and comments discussed with the applicant were either already addressed in the applicant's procedure review prcgram or responses to the inspector's question resolved the comment.
Procedure Revision Title (a) 3001.01
Approach to Criti~ cal (b) 3002.01
Heatup and Pressurization (c) 3203.01
Component Cooling Water (2) Discussion The inspector questioned the applicant concerning the availability of BWR-6 operating experience for feedback inte the CPS integrated plant operating procedures. The inspector noted that ANSI N18.7-1976, Paragraph 5.2.15 considered the feedback of operating experience an important factor in the ongoing development and improvement of all plant procedures.
The inspector suggested the applicant obtain copies of the integrated plant operating procedures from an operating BWR-6 to determine if CPS may benefit from the operating experience already gained on this model boiling water reactor. 'The applicant acknowledged the suggestion.
(3) Results No violations or deviatiens were identified. The procedures reviewed appeared adequate to control safety-related plant operations within applicable regulatory requirements.
The feedback of operating experience, consistent with ANSI N18.7-1976, should result in improved procedures.
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Emergency Procedures Review (42452)
This inspection commenced a review of procedures to be used in the plant operations phase to confirm that the plant emergency procedures are prepared to adequately control safety-related functions when a system or component malfunction is indicated.
(1) Applicable Requirements, Applicant Commitments, and Guidance Documents (a)
10 CFR 50 (b) Regulatory Gside 1.33, Revision 2, " Quality Assurance Program Regt;irements" (c) ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" (d) ANSI N45.2-1977, " Quality Assurance Program Requirements for Nuclear Facilities" (e) CPS No. 1005.01, Revision 16, " Preparation, Review and
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Approval of Station Procedures" (f) Various System Anr:unciator Panel Drawings (2) Procedures Reviewed The procedures reviewed were for annunciator panels that include all alarms located on the Display Control System, the 680 panel.
(a) CPS No. 5000, Revision 20, " Alarm Panel Annunciators 5000.01 through 5000.30" (b) CPS No. 5001, Revision 20, " Alarm Panel Annunciators 5001.01 through 5000.40" (c) CPS No. 5002, Revision 20, " Alarm Panel Annunciators 5002.01 through 5002.75" (d) CPS No. 5003, Revision 20, " Alarm Panel Annunciators 5003.01 through 5003.60" (e) CPS No. 5004, Revision 20, " Alarm Panel Annunciators 5004.01 through 5004.33" (f) CPS No. 5005, Revision 20, " Alarm Panel Annunciators 5005.01 through 5005.33" (g) CPS No. 5006, Revision 20, " Alarm Panel Annunciators 5006.01 through 5006.60" (h) CPS No. 5007, Revision 20, " Alarm Panel Annunciators 5007.01 through 5007.60" (1) CPS No. 5008, Revision 20, " Alarm Panel Annunciators 5008.01 through 5008.55" (j) CPS No. 5039, Revision 20, " Alarm Panel Annunciators 5009.01 through 5009.45" (3) Discussion The inspector verified that each procedure was in the format specified in CPS No. 1005.01. The inspector verified that each procedure was technically adequate to accomplish its
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stated purpose, that is, the procedures were clear, concise,
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and easily readable; the titles were descriptive of the
emergency, and the procedure contained the alarm set point, other indications, possible causes, automatic actions, and
operator actions.
l The inspector observed the-annunciator windows at the operator's console and ccmpared the window engravings with the nomenclature used in the procedures and associated drawings. The inspector i
determined that there were minor differences between all three
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references including the use of multi-colored annunciator. lenses which were not mentioned in the procedures. The inspector was mainly concerned with how changes made to the annunciator panels
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i would ultimately be reflected in the procedures utilized by the operators' in the control room, and how the window engravings,
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procedures, and drawings would all be made identical.
Based upon discussions with ccgnizant IP personnel, the
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inspector determined the following:
The meaning of the multicolored annunciator lenses, while,
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i amber, red, red / blue, and blue, is included in the " Control I
Room. Operator's Hanabook" and part of routine operator
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training sessions. Therefore, the meaning of the colored lenses was not needed to be part of the annunciator a
procedures.
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Systems final released to Plant Staff have design changes controlled by procedures CPS No. 1003.01, " Design Control
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and Modification," and CPS No. 1003.04, " Design Change Transition." Both procedures include the requirement for
determining the impact of the modification on procedures.
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Control room annunciator panels were being " walked down" independently of system turnover. The walkdowns were
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j being performed on a panel basis according to Operations j
Standing Order (0S0) 047 which ensures that'all alarms and i
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j panel engravings are properly identified, and annunciator response procedures properly address all alarms per design drawings. The walkdowns will ensure that all changes made l
to annunciators, including those made prior to final
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system release to Plant Staff, comply with OSO 047.
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The inspector reviewed results of walkdowns maae in reference.
to annunciator panels 5000 and 5001. The walkdowns were in
. compliance with OSO 047, and the activity was being tracked on the IP Cormitment Tracking System as number 042803. The_
t commitment was to complete a walkdown of all control room I,
annunciators before fuel load, and all remaining annunciators, prior to exceeding 5% power.
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..- i Results Annunciator response instructions were adequate to aid operator's responses to alarm conditions; minor procedural discrepancies identified by the inspector were being corrected by the applicant in accordance with approved written instructions and commitments to correct annunciator discrepancies were appropriately tracked.
Inspection of Off-Normal procedures will be documented in a subsequent inspection report.
No violations or deviations were identified.
d.
Plant Procedures Review (42400)
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This inspection continued a review of procedures to be used in the plant operations phase (reference Inspection Reports No. 50-461/85005, 85012, and 85063) to confirm that the scope of the plant procedures system is adequate to control safety-related operations within applicable regulatory requirements, and to verify the adequacy of management controls in implementing and maintaining a viable procedure system.
(1) Applicable Regulatory Requirements and Applicant Commitments (a)
10 CFR 50 (b) Regulatory Guide 1.33, Revision 2, Quality Assurance Program Requirements (Operation)
(c) ANSI N18.7-1976, Administrative Controls and Quality Assurance For The Operational Phase Of Nuclear-Power Plants (d) ANSI N45.2-1977, Quality Assurance Program Requirements For Nuclear Facilities (e) CPS Final Safety Analysis Report (FSAR), Chapter 13.5 through amendment 38 (f) CPS Draft Techn! cal Specifications (2),Precedures Reviewed (a) CPS No. 3001.01, Approach To Critical, Revision 3 (b) CPS No. 3002.01, Heatup And Pressurization, Revision 4 (c) CPS No. 3003.01, Heatup And Pressurization, Condenser Isolated And Condenser Recovery, Revision 4
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(d) CPS No. 3004.01, Turbine Startup And Generator Synchronization, Revision 3 (e) CPS No. 3005.01, Unit Power Changes, Revision 3 (f) CPS No. 3006.01, Unit Shutdown, Revision 4 (g) CPS No. 3007.01, Preparation For And Recovery From Refueling Operations, Revision 1 (h) CPS No. 1041.01, Post Trip Review, Revision 1 (3)' Discussion The inspector reviewed the purpose of the CPS integrated plant operating procedures (identified in (2) above) against the list of procedures identified in Appendix A to Regulatory Guide 1.33, Quality Assurance Program Requirements (0peration). The inspector noted that the approved procedures available in the CPS Operating Manual included all integrated plant operating procedures listed in the CPS Final Safety Analysis Report (FSAR) Chapter 13.5.
The procedures purpose sections were required by CPS No. 1005.01, Preparation, Review, and Approval Of Station Procedures And Documents, to clearly identify the purpose for which the procedure was intended.
The inspector found, on the basis of a review of the procedure purpose alone, that the operations covered by Regulatory Guide 1.33 Appendix A, Paragraph 2.c, 2.d, and 2.g were not procedurally addressed. Discussion with the applicant indicated that the operations in question were covered by the integrated plant operating procedures but were not explicitly included in the procedure purpose section. Due to a lack of available inspection time and considering the nature of the operations in question (i.e., Recovery From Reactor Trip, Operation At Hot Standby, and Power Operation and Process Monitoring), this matter remains open pending a future inspection (461/86048-04).
(4) Results One open item was identified for followup inspection after fuel load.
7.
Region III Requests (92701)
a.
Safeteam Status The inspector selected a sample of Safeteam concerns for followup inspection by a Region III specialist inspector (reference Inspection Report No. 50-461/86004, open item 461/86004-01).
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The following concerns were selected and copies of records related to Safeteam investigation of each-concern were transmitted to Region III:
10028-A*
12023-C*
10270-A 12099-A 10490-A 12704-A 11676-A
- Previously reviewed in Inspection Report No. 50-461/86004.
The inspector also reviewed the current status of Safeteam activities to update information contained in the previous report.
The following information was obtained concerning the status of Safeteam concerns as of July 18, 1986:
DATA TYPE NUMBER Number of Individuals Processed Through the SAFETEAM Appreciaticn Center.
9391
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Number of Exit Interviews.
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Number of Scheduled Interviews 1628
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Number of Drop-Ins 243
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Telephone Calls Received
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Letters Received 241
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Total Number of Interviews Conducted 3104
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Total Number of Quality Concerns Received.....
1909 Total Number of Quality Concerns Open......
Total Number of Non-Quality Concerns Received...
929 Total Number of Non-Quality Concerns Open.....
Total Number of Concerns Closed 2794
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Total Number of Ccncerns Open...........
Total Number of SAFETEAM Substantiated Concerns Requiring SAFETEAM Initiated Corrective Action..
106 The above status indicates that the SAFETEAM has processed a substan-tial number of employees; that a significant number of quality related concerns were received and investigated by the SAFETEAM; and that
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only a minimal number of concerns were open at the time of this inspection. The SAFETEAM director indicated that there was essentially no backlog of concerns at the time of this inspection (i.e., each open concern was currently under investigation),
b.
diesel Generator Event Followup
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On July 1,1986, the applicant informed the NRC that on June 29, 1986, the Clinton Power Station's division I Emergency Diesel Generator (EDG) was inadvertently started when the generator became motorized. At the time of occurrence, the diesel engine was
" mechanically" tagged out-of-service in preparation for a plant modification to the diesel engine lubrication system.
The EDG apparently became motorized when the associated 4160 volt bus 1A1 for Division I was energized after a maintenance outage.
Upon energization of the 1A1 bus from the emergency reserve auxiliary transforme- (ERAT), the EDG-1 output breake-closed automatically and caised the EDG-1 generator to act as a motor.
This motoring action w1s sufficient to start the diesel engine.
The 1A1 reserve feed breaker (ERAT supply) tripped soon after the diesel engine had started.
The third source of power to the 1A1 bus was the reserve auxiliary transformer (RAT) which had been tagged out for maintenarce and did not reenergize the 1A1 bus.
Since the EDG-1 output switch was positioned in " maintenance" and control circuits were deenergized and tagged, plant operators were unable to use normal methods to stop the diesel engine. The diesel engine continued to run for about five minutes until an operator was able to close the fuel racks and shut down the machine.
The applicant wrote a condition report and performed an investiga-tion.
Immediate action taken included additional tagouts for the EDG-1 output breaker to be in the " racked-out" position. The applicant's investigation revealed that the Division I EDG had operated as designed and that the event was caused by an inadequate tagout (personnel error).
As a result of the above incident, Region III requested that the inspector observe a portion of the applicant's actions taken to assure that no damage had been caused to the EDG. The applicant provided chemical analysis results of lube oil samples taken from the Division I EDG sumps. The applicant stated that the analytical resuits indicated normal lube oil (like new) with no damage to the machine apparent through the lube oil analysis.
The applicant's investigation of the above incident daterrdned that a number of inspections should be performed prior to operating the EDG, as follows:
(1) Perform a crankshaft thrust check.
(2) Check piston to head clearances.
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(3) Check connecting rod snap rings.
(4) Check for bearing damage at (1) the turbocharger, (2) the lower main bearings.
(5) Perform chemical analysis of lube oil samples.
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Generator (11 Vendor perform visual inspection of generator internals.
(2h Vendor check clearances, as required.
(3) Perform vibratioaal analysis the first tinie the generator is run.
The above actions had not been completed at the conclusion of the irispection period. The inspector reviewed chemical analysis results for lube oil samples taken from the Division I EDG lube oil sumps and discussed the results with a Region III specialist inspector.
The specialist inspector agreed with the applicant's conclusion regarding damage but identified that, according to the EDG manufacturer's maintenance instruction (MI) No. 1762, Revision E, there was indication of possible contaminants in the fuel oil and a potential for silicon contamination of the combustion air intake.
The inspector brought these indications to the applicant's attention.
Fuel oil samples were obtained and sent offsite for analysis. The applicant completed their review of these indications and concluded that the fuel nil was not contaminated. New lube oil analysis indicated that aluminum was a nonr.al constituent of the oil. The silicon problems came from sand blasting of the air intake pipes prior to installation.
On July 3, 1986, the inspector observed the applicant's mechanical maintenance department perform a visual inspection of a sample of the lower main bearings and the turbocharger bearing for the Division I EDG. The applicant's n rsonnel were assisted by an EDG specialist from Morrison-Knldson Lompany. The inspector reviewed the results of lead wire readings taken on Division I EDG and the visual inspection results with a Region III specialist inspector.
There was no indication of damage to any portion of the machine.
One. stuck fuel injector was identified by the applicant and was replaced. The inspector requested the results of the applicant's comparison of the lead-wire reading results with the original factory (" Birth") records for the machine. This comparison had not been completed at the conclusion of the inspection.
The applicant concluded that the Division I EDG engines had not been damaged by the event. Actions to complete the modifications to the lube oil system were completed during the report period. However, (a) the EDG had not been run; (b) vibration readings on the generator had not been taken; and (c) the comparison of lead-wire readings with the birth records had not been completed at the conclusion of the inspection. This is an open item (461/86048-05).
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c.
Operational Readiness Assessment The inspector reviewed the licensee's administrative controls for the identification, tracking, scheduling, and accomplishment of remaining facility work items requiring completion prior to fuel load as well as subsequent operating milestones. This review was conducted to assure that these administrative controls were comprehensive in scope and addressed remaining work items associated with all aspects of facility design, construction, testing, licensing, and operation.
The review was also conducted to assess the decisional process by which work items were scheduled for completion.
The following Clinton power Station (CPS) Procedures and Startup Administrative Procedures (SAPS) were included in the inspector's review and assessment:
Procedure Number Title
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" Field Problem Reporting" SAP-06
" Phase 2 Release" CPS No. 1040.01
" System Release, Review, and Acceptance" CPS Ho. 1042.01
" Area Release" CPS No. 1014.02
" Designating Systems Ready For Fuel Load" CPS No. 1002.04
" Maintaining, Modifying, and Operating Systems" CPS No. 1401.01
"Ccnduct of Operations" At the time of this inspection, jurisdictional control of all plant systems had been transferred from the construction organization to the startup and operating organizations. All safety-related plant areas were under the jurisdictional' control of the operating organization. The licensee's program for plant completion employed a computer-based data management system called the Site Wide Statusing System. This system tracked the status of items from a large number of data bases pertaining to plant design issues and documents, construction, preoperational testing, naintenance, modifications, operation, surveillance testing, licensing issues, quality assurance organization findings, NRC inspection and enforcement items, plant procedures, and personnel training. The sitewide statusing system provided licensee management with an overview of remaining work and a consolidated list of things to be accomplished in support of fuel load and subsequent operating milestones.
Items contained on the Sitewide Status System had been subjected to preliminary reviews by the licensee's engineering and licensing staffs and completion milestones had been assigned to each item. At the time of this inspection, the licensee indicated that further reviews would be conducted and refinements to the assigned completion milestones would be forthcoming.
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The licensee's programs and procedures for plant completion broke down the remaining work items on a system and area basis.
Work items which were not specific to any given system, but instead pertained to plant structures were sorted and managed by the areas of the plant to which they pertained.
Items pertaining to specific systems were evaluated for significance prior to release of a system to the startup organization and again prior to the time the system was released from the startup organization to the plant staff. When jurisdictional control was released to the plant staff, remaining preoperational testing, system configuration control, maintenance, surveillance testing, equipmer.t lineups, and operations were controlled by the licensee's operating quality assurance program and plant procedures.
Outstanding items which remained at the time of system turnover to the plant staff, were subsequently reevaluated by cognizant engineering, licensing, technical, quality assurance, and operating personnel to determine impact on system operability. Based upon these evaluations and technical specification equipment operability requirements, the items were scheduled for completion.
Following completion of significant work items required for fuel load and performance of system unique surveillance tests, systems were declared " ready for fuel lead." Remaining work items against a system declared " ready for fuel load" were tracked either as exceptions (i.e., items which must be completed prior to fuel load)
or deferred items (i.e., items which may be completed subsequent to fuel load),
following completion of integrated system surveillance tests, verification that supporting systems and equipment are operable or in service, and completion of remaining work items determined to have an impact on system operability, systems will be declared operable for the purposes satisfying technical specification requirements. System operability will be statused and maintained in accordance with the licensee's operating administrative controls which utilize checklists for verifying that required systems and equipment are operable prior to entering the applicable Operational Condt tion.
In addition to the foregoing, the licensee has established a comprehensive set of prerequisites as part of startup test procedure STP-03, " Fuel Load" to provide additional assurances that required systems and equipment are operable or in service, as applicable, prior to initial entry into Operational Condition 5.
As previously discussed, when systems were declared " ready for fuel load," remaining work items which impacted system operability were to be tracked as exceptions or deferred items. The inspector determined by review of documentation pertaining to declaration of the Low Pressure Core Spray system (LPCS) " ready for fuel load," by discussions with the Senior Resident Inspector, and by visual examination of portions of the LPCS system during plant tours, that
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a number of conditions existed which potentially impacted LPCS i
j system operability and which had not been identified, documented, L
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evaluated, and scheduled for correction prior to declaration of LPCS (
operable per technical specifications. These conditions should have
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been identified during system walkdowns conducted prior to release
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of the LPCS system to the plant staff. These and other deficiencies
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concerning the adequacy of prior system walkdowns were previously
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identified as open item (461/86037-04A). Licensee actions to assure
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i that such conditions are properly identified, documented, and r
i resolved in a timely manner are discussed in Paragraph 2 of this
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The inspector reviewed documented inter-disciplinary evaluations of l
i the Division 1 diesel generator and the component cooling water
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system conducted in accordance with Clinton Power Station procedure j
number 1014.02, " Designating Systems Ready for Fuel Load." The i
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documented evaluations were conducted by the licensee's engineering,
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startup, quality assurance, licensing and safety, project management,
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technical and operating organizations and included determinations
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of the impact of identified work items on system operability,
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provided a schedule for resolution of each item, and provided
i documented bases for the schedule. The. evaluations were assembled I
by the Plent Technical Department System Engineers and submitted for
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approval by the Director of the Plant Technical Department, Director,
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Plant Operations, and the Plant Manager. The inspector's review
l determined that identified items were appropriately scheduled based r
upon adequately detailed and documented evaluations.
i The licensee's management approach to assuring facility readiness
was found to be similar to that employed by a number of other
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recently licensed facilities. The remaining work items, while
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varying considerably in scope and complexity, were enumerated in a r
i manner quite comparable to that employed at the other facilities.
i Continued attention to detail and conscientious implementation of i
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l the established administrative controls should provide the requisite
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assurance of operational readiness to support issuance of the
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operating license.
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No violations or deviations were identified.
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8.
Site Activities of Interest j
a.
Fuel Load Schedule (94300)
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j On June 17, 1986, the applicant notified the NRC by letter that l
CPS would be ready for issuance of a low power license on or about
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July)15,1986. At the conclusion of the inspection period (July 28,
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1986, there were no plant systems declared operable under the CPS
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final draft technical specifications to support fuel load. That
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activity was in progress. The applicant believed that CPS would
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be ready to load fuel by August 7, 1986.
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b.
Readiness For Fuel Load Meeting (30702)
On July 10, 1986, NRC management from the Office of Nuclear Reactor Regulation (NRR) and Region III met with IP management at the CPS Visitor's Center to discuss the current state of readiness of CPS to
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load fuel. This was the sixth of a series of such meetings to be held with IP management on a routine (monthly) basis.
Key personnel
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attending the meeting are identified by (+) in Paragraph 1 of this report.
The meeting, which lasted about three hours, included the following:
(1) A short introductory statement by the NRC Director - BWR Licensing, Office of NRR, concerning the purpose and scope of the meeting.
(2) Opening remarks by the President - IP.
(3) An introduction and briefing by the IP Vice President - Nuclear
concerning the current status of CPS.
(4) A detailed discussion by key IP managers of areas significant to the licensing process.
(5) A summary discussion by the IP Vice President - Nuclear concerning management philosophy, policy, organization, and challenges.
(6) Closing remarks by the NRR Director - BWR Licensing.
(7) An opportunity for questions / comments from members of the public and news media representative.
There was no schedule determined for a follow on meeting.
c.
IP Management Change (71302)
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On July 8, 1986, the a Quality Assurance (QA)pplicant announced that the IP Manager -
l was taking a lateral transfer to replace the i
Manager - Nuclear Planning and Support (NP&S).. The former Manager -
NP8S was a contractor to IP whose contract was to expire soon. On
July 17, 1986, the applicant named the IP Director - Quality Systems and Audits as the new Manager - QA.
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d.
IP LUor Negotiations (92709)
On July 16, 1986, the applicant notified the NRC Senior Resident Inspector that the four unions representing Iliinois Power (IP)
Company workers, including those workers at Clinton Power Station, voted not to accept the conditions of IP's recent contract proposal.
The vote also gave the bargaining committee for the four unions concurrence to authorize a strike, if warranted. The unions have
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been working on the basis of a 30 day contract extension since
the previous contract expired in late June 1986. Acditional
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negotiations began on July 23, 1986. Any job action by the unions
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would require a ten day notification to IP and authorization by the i
international union (IBEW).
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The unions identified no specific issues as the basis for rejecting the contract.
IP management stated that the vote turnout was low (less than 65% of the represented workers) and the vote margin was small (54% voted to reject the contract proposal).
IP management is reviewing their contingency plans but anticipate no adverse union
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action.
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l 9.
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 disclused during the inspection was discussed in Paragraphs 6.d(3) and-
7.b.
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Exit Meetings (30703)
10.
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The inspectors met with applicant representatives (denoted in Paragraph 1)
throughout the inspection and at the conclusion of the inspection on
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July 28, 1986. The inspectors summarized the scope and findings of the j
inspection activities. The inspectors discussed the significance of the
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findings in relation to the adequacy of the area turnover process and
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the effectiveness of plant staff management in correcting NRC identified problems.
In addition, the inspectors reiterated the suggestion that
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CPS integrated plant operating procedures be reviewed with respect to
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i operating experience gained at another BWR-6 plant and that reviews of f
plant administrative procedures be performed with reference to the applicable requirements. The applicant acknowledged the inspection
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findings and the inspector's suggestions.
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The inspectors also discussed the likely informational content of the
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inspection report with regard to documents or processes reviewed by the inspectors during the inspecticn. The applicant did not identify any i
j such documents / processes as proprietary.
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The resident inspectors attended exit meetings held between Region III
based inspectors and the applicant as follows:
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. Inspector (s)
Date j
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i Wohld 7/02/86
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Connaughton 7/03/86 i
Drouin 7/11/86 Scheibelhut, Paul, Slawinski 7/11/86
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