IR 05000461/1986054

Safety Insp Rept 50-461/86-54 on 860728-0908.Violation Noted:Failure to Initiate Condition Rept When Mgt Walkdown Identified Steel Plate Installed W/O Approved Design & Work Documentation

ML20210Q713
Person / Time
Site:	Clinton
Issue date:	09/26/1986
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210Q701	List: IR 05000461/1986054 ML20210Q694 ML20210Q704
References
50-461-86-54, NUDOCS 8610070012
Download: ML20210Q713 (29)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/86054(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 Inspection At: Clinton Site, Clinton, IL Inspection Conducted: July 28 through September 8, 1986 Inspectors: T. P. Gwynn P. L. Hiland B. H. Little S. M. Hare B. L. Siegel J. F. Schapker W. Liu Approved By:

RF~lDA R. C. Knop, Chief

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f/bE4/JP4 Projects Section 1B vate Inspection Summary Inspection on July 28 through September 8, 1986 (Report No. 50-461/86054(DRP))

Areas Inspected: Routine safety inspection by three resident inspectors, three regional based inspectors, and the licensing' project manager of preoperational testing and operational preparedness activities including applicant action on previous inspection findings; applicant action on 50.55(e)

item; employee concerns; functional or program areas (including site surveillance tours and emergency procedure review); independent inspection (including review of electrical penetration status; ESF system walkdown; control room observations; and onsite review committee activity); safety evaluation report review and followup; inspection of Title 10 requirements; and site activities of interes Results: Of the twelve areas inspected, no violations or deviations were identified in eleven of the areas. One violation was identified in the area of ESF system walkdown (failure to write a condition report paragraph 6.b). ,

The specific violation by itself was not highly significant; however, the licensee has been requested to determine generic implication PDR ADOCK 03000461 G pna

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DETAILS ,

. ! Personnel Contacted Illinois Power Company (IP) '

$ D. Antonelli, Director, Operations

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$ *K. Baker, Supervisor - I&E Interface, Licensing and Safety

• Bell, Assistant to Manager, Scheduling and OM

$ +*R. Campbell, Manager - QA

$ *W. Connell, Manager - Nuclear Planning & Support , ,

$ J. Cook, Assistant Plant Manager '

$ E. Corrigan, Director, Quality Engineering and Verification

$ H. Daniels, Project Manager *

$ J. Dodson, Supervisor, Nuclear Communications

$ L. Ferguson, Utility Engineer, ICC ..

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$ S. Fisher, Manager, Nuclear Planning & Support

$#+*W. Gerstner, Executive Vice President .

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$ K. Graf, Director - Operations Monitoring '

$ + J. Greene, Manager - Nuclear Station Engineering Departmsnt (NSED)

$ R. Greer, Director - Outage Maintenance Programs

$#+*D. Hall, Vice President, Nuclear

$ T. Helton, Supervisor, Visitor Center

$ D. Hillyer, Director, Radiation Protection

$ D. Holtzsher, Director - Nuclear safets

$' R. Hubbard, Consultant (Vice President of MHB), Illinois Atty. Gen' $ J. Jenkins, Accounts & Finance, ICC <z

$ Johnson, Attorney (Schiff Hardin) . .

$ *E. Kant, Assistant Manager, Nuclear Station Engineering Departmen $ W. Kelley, President & Chairman of the Board -

$ R. Kerester, Director - Field Engineering

$ P. Lancaster, Supervisor - Labor Relations

$ B. Lillyman, Public Affairs n

$ J. Marshall, Accounts & Finance;'ICC

$ G. Miller, Director - Fiscal Management J

$ J. Miller, Assistant Manager - Startup ,_ >

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$ R. Morgenstern, Director, Technical

$ D. Morris, Director - Nuclear Program Scheduling J. Palchak, Supervisor - Plant Support Services

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! $ J. Palmer, Director, Configuration Management '%

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$ K. Patterson, Director, Materials Management ' "

$# *J. Perry, Manager - Project Control Center

! $ P. Raysircar, Assistant Director - NSED . +

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$ R. Richey, Director, Plant Maintenance .

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$ T. Riley, Supervisor - Licensing 0perations

$ A. Ruwe, Director, Design Engineering - NSED

$ * Schaller, Director - Nuclear Training

$ F. Schwarz, Director, Outage Maintenance & Support -

$#+*F. Spangenberg, Manager - L&S

$ E. Till, Supervisor, Emergency Response

$ E. Vaughan, Director, Reliability Engineering ,

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$ *J. Weaver, Director - Licensing

$ N. Williams, Director - Support Services

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

$# R. Wyatt, Director - Nuclear Program Assessment

$ + S. Zabel, Attorney for Illinois Power Sargent and Lundy

+ Heider, Project Manager, Sargent & Lundy

+ Shewski, Mechanical Project Engineer, Sargent & Lundy

+ Wattelet, Project Director, Sargent & Lundy Soyland/Wipco

$#J. Greenwood, Manager, Power Supply U. S. NRC

$#+*T. Gwynn, Senior Resident Inspector - Operations

$P. Hiland, Resident Inspector

1. +C. Norelius, Director, Division of Reactor Projects, Region III

$+B. Davis, Deputy Regional Administrator, Region III

$#+R. Warnick, Chief, Reactor Projects Branch 1, Region III

$+R. Knop, Section Chief, Projects Section IB

+M. Ring, Chief, Test Programs, Region III

1. C. Paperiello, Director, Division of Reactor Safety, Region III

+J. Grobe, Director of Enforcement, Region III

+B. Stapleton, Enforcement Specialist, Region III

+ Berson, Region Counsel, Region III

• Denotes those attending the monthly exit meeting on September 8, 1986.

+ Denotes those attending the Enforcement Conference on August 29, 198 $ Denotes those attending the monthly management meeting on August 7, 198 # Denotes those attending the monthly management meeting on September 8, 198 The inspectors also contacted and interviewed other staff and contractor personne . Applicant Action On Previous Inspection Findings (92701) (92702) (Closed) Open Item (461/85005-41): SSER2, paragraph 7.4.3.2 -

Verify installation of loss of voltage alarms prior to fuel loa This item was previously reviewed for closure in Inspection Reports 50-461/86023, paragraph 2.c., and 50-461/86048, paragraph Each of those inspections identified violations related to the adequacy of maintenance department actions taken to make the five loss of voltage alarms operational. The corrective actions taken by the applicant for those violations will be reviewed separatel At the conclusion of the previous inspection, one of the five loss of voltage alarms was not fully operationa _ _ _

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During this inspection, the inspector observed the performance of an operational test performed by the plant operating staff to demonstrate that each of the five loss of voltage alarms would result in activation of an annunciator in the control room. That test was successful. This item is close (Closed) Open Item (461/85039-12): Emergency Sampling and Analysis-Procedure During a previous inspection, it was identified that-neiht er t eh " normal" nor the " emergency" procedure for sampling and analysis had been complete The applicant presented this item to the inspector for closur Refer to Inspection Report 50-461/86048, paragraph 2.t. That report indicated that this item remained open pending approval of draft procedures used to demonstrate stack effluent sampling and analysis procedures. The applicant provided evidence that the draft procedures used during the demonstration had been approve This item is closed, (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 operabilit The applicant stated that the procedure, CPS No. 1401.01, Conduct of Operations, revision 7, would be revised to impose minimum requirements for the initial declaration of technical specification operabilit This item was previously reviewed in Inspection Report 50-461/86048, paragraph 2.w. At the conclusion of that inspection, two questions remained open as follows:

(1) IP was to provide a listing of plant systems required to support plant operation, by milestone, for NRC revie t (2) CPS No. 1401.01, paragraph 8.5.10.1.2. required "The Fuel Load Milestone Coordinator (FLMC) shall coordinate a review of the lists in Appendix B by the appropriate departments. The departments shall ensure that the review verifies that open items associated with the lists are correctly coded as non fuel load restraints".

The inspector requested that the FLMC identify the appropriate departments for each item listed in Appendix B and identify the criteria to be used to make the required determinatio During this inspection, IP provided a comprehensive list of plant systems required to support plant operation (by milestone) in response to (1) above. This list, dated July 28, 1986, identified each plant system, categorized by operating mode / milestone, and identified if it had to meet technical specification requirements

for the applicable mode / milestone.or if it had to be operational to

- support a technical specification system requiremen The inspector

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reviewed the. list with respect to the applicant's preoperational test deferral request (which was accepted by the NRC in Supplement 6

'to the CPS Safety Evaluation Report) and with respect to the final

' draft CPS technical specifications. The inspector found that the-system list, in conjunction with the provisions of CPS No. 1401.01, Conduct of Operations, and other CPS procedures provided a viable approach to achieving system operability to support the applicable milestones. This portion of the open item is close At the conclusion'of..the inspection, the applic~ ant had not provided the information requested in (2) above. This-item remains open pending receipt and review of the requested information and additional inspectio (Closed) Open Item (461/86004-01): Safeteam weaknesses. The following employee concerns were reviewed by the Safeteam as described in NRC Inspection Report 50-461/86004, paragraph The inspectors observed a program weakness in the investigative procedures questioning the adequacy of these reviews. The inspectors acknowledged that the Safeteam investigation records were not intended to meet regulatory requirements for records or to provide evidence of quality. The actual impact of the weaknesses on plant hardware, if any, was not determined during the course of that inspection. Because the investigation' record did not adequately address the identified concern, there was some potential that hardware could be affected. This was identified as an open item 461/86004-0 The applicant responded to the concerns addressed in Inspection Report 50-461/86004. The applicant has prepared and implemented a corrective action plan to resolve these concerns. To assure these corrective measures were adequate the inspector selected a representative sample of hardware-related quality concerns, including.the two examples addressed in the 461/86004 repor This inspection included review of the Safeteam investigative report numbers 10028A, 12023C, 10270A, 10490A, 11676A, 12099A, j- 12704 Three of the Safeteam reports were chosen which dated

! from before the 86004 inspection as a measure of adequacy of the Safeteam backfit program, and two reviews from after the NRC inspection as a evaluation of the current Safeteam program.

l Based on the sample reviewed the inspector concluded that the Safeteam had satisfactorily addressed the concerns expressed, and evaluated their safety significance. The inspector reviewed the appropriate Safeteam files, reviewed backup documentation on file in the licensee's QA Vault and performed field verifications where appropriate. No hardware deficiencies were apparent. This item is close (0 pen) Unresolved Item (461/86023-05): Post maintenance testing (PMT) program / implementation deficiencies. An IPQA audit identified deficiencies in the applicant's program for PM S t - . . _ . _ _ - - _ - - - - - - - - - - - - - - _ _

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This unresolved item was previously inspected as documented in Inspection Reports 50-461/86023, paragraph 9.e. and 50-461/86048, paragraphs 2.1. and 2.v. During the last inspection, this item remained open pending NRC review of the resolution of additional IPQA audit findings in the PMT program implementatio The inspector attempted to verify that PMT evaluations had been completed for a random sample of 23 maintenance work requests (MWRs) initiated between March and July,1986. Of the 23 MWRs selected, PMT evaluations were available in the CPS central file for only Those 4 PMT evaluations had been processed in accordance with the applicable procedur The inspector requested that the applicant locate 5 of the 19 PMT evaluations which were not in the central file. Those PMT evaluations were applicable to systems that had been declared operable under the CPS Final Draft Technical Specifications. The applicant was able to determine the location of three of those evaluations; they were still being processed in accordance with the approved procedur The other two PMT evaluations could not be located by the applican This review was still in progress at the conclusion of the inspection period. This item remains unresolved pending demonstration by the applicant that the program for PMT activities is being accomplished in accordance with the approved procedur f. (Closed) Violation (461/86013-02): Cleaning and preservation of safety-related station batteries. An inspection of the general maintenance condition of the station's safety-related batteries identified numerous examples of an inadequate battery maintenance progra The applicant responded to the violation in a timely manne Two related items (open item 461/86013-06 and unresolved item 461/86013-07) concerning the applicant's battery maintenance procedures and the batteries preoperational test data were previously reviewed and closed in Inspection Report 50-461/8604 The applicant performed an inspection of the station batteries and battery rooms. As a result of that inspection, numerous maintenance work requests were initiated to correct identified deficiencie In addition, the applicant provided training to their electrical maintenance personnel and contracted an outside consultant (Brand Industrial Products) to evaluate the battery maintenance practice During this report period, the inspector conducted an unannounced inspection of the safety-related station batteries (IDC01E, 1DC02E, 1DC03E, and 1DC04E). The inspector observed the general cleanliness of the battery rooms was being properly maintained; that electrolyte level was being maintained within acceptable band; no spilled electrolyte was observed; all terminals were free of corrosion I

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products; and access to the battery rooms was controlled. The inspector reviewed the applicant's preventive maintenance (PM)

schedule with the cognizant electrical maintenance supervisor and noted required PMs were completed and being maintained up to dat The inspector confirmed the applicant's corrective action was adequate. This item is close g. (Closed) Violation (461/86023-01): Maintenance work requests not performed in accordance with written instructions, procedures, and drawings. An inspection of maintenance activities being performed by the plant staff maintenance department and the maintenance contractor, Stone and Webster (S&W), identified a number of examples where written instructions were not adhered t During the last report period (reference Inspection Report 50-461/86048), the applicant formally responded to the violation and stated that full compliance would be achieved by July 30, 198 At the conclusion of the last report period, the inspector was still reviewing the applicant's response to item "c." of the Notice of Violation (N0V). The applicant's response to items "a.", "b.",

and "d." of the NOV were previously found to be adequate as documented in paragraph 2.b. of Inspection Report 50-461/8604 Item "c." of the NOV identified a MWR where work was performed without routing the MWR back to planning when a change in scope was required. The applicant initiated a condition report (CR No. 1-85-05-006) to address the specific example identified in the NOV of failure to follow MWR job steps. In addition, the applicant issued a memorandum to the job supervisor and craftsman involved reiterating requirements to follow MWR job step Since the applicant's response indicated that they considered this an isolated event, the inspector requested additional information to support the applicant's conclusion. The applicant reviewed their Corrective Action Tracking System for the period January 1 through June 30, 1986, and searched for trend codes that identified a MWR not followed (code 686-040), MWR signature out of sequence / hold point by passed (code 686-055), and a MWR with unauthorized work (code 686-510). The applicant identified two additional instances where the scope of a MWR was exceede The inspector reviewed the Nuclear Training Department's lesson

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plan, MWR Training For Craft Personnel, Lesson Plan 10106, revision 0 dated July 31, 1985, and revision 1, dated June 18, 1986. The lesson plans reviewed provided clear instructions on adherence to

, MWR job steps. The inspector noted that all craft persons were I provided the above MWR training. In addition, the inspector l reviewed " Gang Box Training" lesson plans 008, 009, 010, and 011 l which provided supplementary training on adherence to procedures.

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The inspector noted, through review of attendance records, that the gang box training had been provided to essentially all craft personnel.

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Based on the corrective action taken by the applicant for the specific example identified, the applicant's review which indicated this item to be an isolated example, the initial MWR training provided to all craft persons, and the continued " Gang Bcx Training" provided to the craft, the inspector concluded that the applicant's response to item "c." was adequate. This item is close (Closed) Open Item (461/84030--03): Final reports submitted by the applicant under 10 CFR 50.55(e) did not indicate that all corrective actions were complete. The inspector was concerned that the applicant had provided no docketed basis for assurance that safety significant deficiencies reported under 10 CFR 50.55(e) had been correcte This matter was reviewed further by the inspector as documented in Inspection Report 50-461/86023, paragraph 2.d. That report identified an IP audit that had found the corrective actions to construction deficiency report 55-80-10 (461/80010-EE) incomplete after that report had been closed by the applicant and the NR In this inspection, the inspector reviewed the results of a statistical sampling plan completed by IPQA concerning completion of corrective actions to previously closed construction deficiency reports. The sampling plan was based on 37 reportable deficiencies identified during the construction of Clinton Power Station and focused specifically on those construction deficiencies which had the largest potential hardware impact. Ten of the 37 total items were reviewed and corrective actions reverified on a sampling basis to provide a high degree of confidence that all reportable deficiencies had been adequately corrected. The reverification results identified no case where the corrective actions to a previously closed construction deficiency report had not been adequately completed. These results indicated that the IPQA audit finding documented in Inspection Report 50-461/86023 did not have generic applicability to the applicant's corrective action program-for reportable construction deficiencie In addition to the reverification documented above, the applicant made some changes in 1984 to the information included in their reports under 10 CFR 50.55(e) to address the inspector's concer In particular, information concerning the completion or the schedule for completion of corrective actions has been included in each of their reports since that tim The inspector reviewed the applicant's licensing procedure for handling construction deficiency reports, 10 CFR 21 reports, and similar matters. The procedure provided that one of three methods were to be employed to assure that corrective actions were complete prior to submittal of the report to Region III inspectors for closure. Those procedural controls should provide an added measure of assurance that the condition identified in the IPQA audit will not recu v .. ..

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When construction is completed and after CPS receives an operating license, IP will'no-longer be required to report under 10 CFR 50.55(e).

This. item is close (Closed) Deviation (461/85060-03(DRS)): The applicant used a test methodology for the preoperational Type A test that was not consistent and was contrary to the test methodology that had been committed to in the Clinton Final Safety Analysis Report (FSAR).

The applicant presented this item to the inspector for closur The resolution to the Deviation was to incorporate the test methodology (Bechtel Topical Report,,BNTOP-1, revision 1) used in the Preoperational Type A test into the FSAR. Specifically, FSAR section 6.2.6.1 was revised in Amendment 36 to include a reference to the Bechtel Corporation Topical Report BNTOP-1, revision The issue and the applicant's resolution were discussed between-the Region III inspector, the Clinton Senior Resident Inspector and the Licensing Project Manager prior to the performance of the Preoperational Type A test. There was agreement that the applicant's use of the test methodology was acceptable and their resolution to this issue was satisfactory. This deviation is close (0 pen) Violation (461/86048-03): The CPS screenhouse was not floodproof as required. The applicant's quality assurance program implementation had not identified this violatio Additional inspection was undertaken during the report period to better determine the extent and potential consequences of the above violation. The inspection included a review of the status of watertight doors (see paragraph 6.b.), a review of the status of containment electrical penetrations (see paragraph 6.a.),' review of the CPS flooding procedure (see paragraph 5.b.), additional observation of the CPS screenhouse installation, and verification ,

of the applicant's review and evaluation of this violatio l The inspector observed the installed condition of the CPS screenhouse accompanied by applicant personne That observation indicated that six penetrations through the 699.0' elevation of the cancelled unit II portion of the screenhause had not been adequately protected'from the effects'of flood. Those penetrations included the construction opening and manway discussed-in Inspection Report

'50-461/86048, paragraph 6.a.(3), and four piping penetrations that had not been properly sealed. The safety-related equipment that

would have been directly affected in the event of a flood included

two shutdown service water (SX) system valves located in the piping L tunnel (ISX011A and ISX01111, the division I & II header cross-l connect valves which are rormally shut) and SX division II equipment located in the SX pump cubicle. That cubicle was physically

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separated from SX divisions I and III by watertight doors.

Assuming the.. watertight doors were shut and operational at the

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time of a postulated flood, only division II equipment and the division I cross-connect valve would have been directly affecte .

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On August 5, 1986, the inspector requested that the applicant provide a copy of the condition report (CR) generated to document the abcve violation and to provide for appropriate corrective action. The applicant provided CR 1-86-08-020 dated August 5, 1986 (that same day). The violation had been identified by the inspector to the applicant on July 25, 1986 and had been the subject of an exit meeting held with IP management on July 28, 1986. The documentation identified that the violation was referred to the Nuclear Station Engineering Department for evaluation for reportability under 10 CFR 50.55(e)/10 CFR 2 The inspector reviewed the applicant's safety-significance evaluation, 86RE32 dated August 14, 1986. That evaluation did not consider the possibility that a single failure could occur concurrent with the postulated flood. The inspector suggested that the applicant reconsider their safety significance evaluation to include the possibility of a concurrent single failure in the division I SX syste The applicant stated that they did not believe it was appropriate to postulate a single failure in addition to the identified deficiency in evaluating its safety significance. However, on August 28, 1986, the applicant notified Region III by telephone of a potentially reportable deficiency (55-86-06) pending further investigation and evaluation of the deficienc This violation was the subject of an enforcement conference held in the Region III office on August 29, 1986. Attendees at the enforcement conference are designated by (+) in paragraph 1 of this repor This violation will be reviewed further in a subsequent inspection repor (0 pen) Open Item (461/86037-04C): Out of service (faulty or defeated) annunciators were not being controlled in accordance with CPS No. 1401.01, Conduct of Operation The inspector observed that faulty or defeated annunciators were being administratively controlled in accordance with CPS N .01, paragraph 8.5.4.4 and that plant operators were generally aware of the cause of alarmed, faulty, or defeated annunciators.

l The applicant stated that the administrative controls in place were difficult to use and that alternate methods were being considered for control of out of service annunciators. This matter will be l reviewed further in a future inspection.

l No violations or deviations were identified.

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3. Applicant Action on 10 CFR 50.55(e) Item (92700)

(Closed) 50.55(e) (461/82009-EE): Small bore / instrumentation pipe support design calculations. The final report for_this item was submitted to Region III dated June 15, 1984. Th_is item was identified by the applicant as a potential reportable item dated September 2, 198 The design calculations were performed by Sargent & Lundy (S&L)

Engineer A review by Illinois Power Nuclear Station Engineering Department (NSED) of these design calculations revealed many discrepancies contained in the design calculations. A hold was placed by S&L on the release of small bore pipe support design documents until corrective actions were implemented. The corrective actions listed below have been established and implemented by the applicant and S& S&L procedures for small bore / instrumentation support design were corrected, expanded, and clarified. These included instituting a checklist to be used by the independent reviewer of calculations to assure an adequate review, locating analysts on site to review and concur with procedural interpretations, and locating piping stress reports at the site for referenc S&L personnel responsible for preparing and reviewing small bore pipe support calculations were given training in the requirements of the revised procedure Calculations which contain non-conservative errors or legibility problems were being reconciled or revised. Affected design documents and hardware were being revised and corrected as necessary to assure that affected piping systems meet the requirements of the procedures and the ASME cod Technical reviews by NSED were being performed on an on going sampling basis to monitor technical adequacy of design calculations performed by S&L.

I The licensee's NSED and QA were expanding their technical review /

audit activities to monitor S&L's desig The inspector reviewed the final report and the supporting docu1entation j with respect to the above concerns. The inspector noted that the actions taken by the applicant were found to be acceptable. This item is closed.

I No violations or deviations were identifie . Employee Concerns (99014)

The inspectors reviewed concerns expressed by site personnel from time

to time throughout the inspection period. Those congerns related to l regulated activities were documented by the inspectors and submitted to l

Region III. One concern was transmitted to the regional office during l this report perio I

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Allegation 86-0135 (Closed)

In addition, on August 5, 1986, the inspector received an unmarked envelope in the plant mail which contained a copy of Condition Report (CR) No. 1-86-07-056. The CR identified that a former IP Startup Lead Test Engineer had unverifiable education included in his resume which was a part of the basis for his certification. The unverifiable education consisted of a Bachelors degree from one college in Texas and a Masters degree from a Texas Universit The inspector reviewed the CR with the Assistant Power Plant Manager -

Startup and interviewed additional Startup employees. The results of this review indicated that IPSU had adequately addressed both the specific and generic significance of the CR for Clinton Power Statio However, there was some concern that the individual in question may still be using the same resume to support his certification at other nuclear facilitie In particular, personnel interviewed stated that the individual in question had worked at the Waterford plant in Louisiana and was currently known to be working at the Nine Mile Point plant in New York. The inspector notified the Region III Office Allegation Coordinator who subsequently notified the affected Regional offices of this matter. This item is close No violations or deviations were identifie . Functional or Program Areas Inspected Site Surveillance Tours (71302/60501)

Surveillance tours of selected areas of the site were performed at periodic intervals throughout the report period. Those surveillances were intended to assess: cleanliness of the site; storage and maintenance conditions of plant equipment and material; potential for fire or other hazards which might have a deleterious effect on personnel or equipment; storage conditions of new fuel;

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and to witness maintenance and preoperational activities in progres (1) New Fuel Storage During this report period, the applicant identified a

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violation of their security plan for the storage of Special

! Nuclear Materials (SNM). On August 16, 1986, at approximately

[ 11:00 a.m., a posted security guard was observed sleeping on l the fuel handling floor of the fuel building. The guard was

providing a compensatory measure for an open equipment hatch

onto the fuel handling floor in accordance with the l

applicant's SNM security plan. New fuel was stored in the immediate vicinity of the open equipment hatc ._ . _ _ _ _ _ _ _ - _ _ _ . _ . _ __ _ . _ _ _ . . _ .

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The applicant notified the resident inspector of the event and notified the NRC Operations Center in accordance with 10 CFR 73. The applicant relieved the sleeping security guard and conducted a security sweep of the fuel floor elevations. No unauthorized personnel were identified as being present. The inspector toured the new fuel storage area immediately following notification of this violation and noted the required number of security personnel were on duty and aler The inspector noted that at least three additional security guards were posted on the fuel handling floor at the time in accordance with the applicant's security pla Several additional random tours of the new fuel storage area identified no additional deviations from the special nuclear materials license requirements for security, fire protection, and environmental controls for new fuel storag (2) Polar Crane-Maintenance The inspector observed maintenance activities being performed on the polar crane by the Clinton Power Station's maintenance contractor Stone and Webster (S&W). The containment polar crane's main cable was being replaced in accordance with Maintenance Work Request (MWR) B-3144 The inspector noted the MWR package was present at the jobsite along with necessary reference material to perform the replacement activity. However, the inspector requested additional information from the applicant concerning their compliance to ANSI B30.2.0-1976, Overhead and Gantry Crane Specifically, it was not apparent to the inspector that paragraph 2-1.11.2.c of ANSI B30.2.0 was incorporated in the MWR job steps or the referenced procedure, CPS No. 8106.03, Crane Inspection, Maintenance and Testing. Paragraph 2-1.11.2.c of ANSI B30.2.0-1976 requires that "1) No less than two wraps of rope shall remain on each anchorage of the hoisting drum..." and "2) The rope clamps shall be tightened to the manufacturer's recommended torque".

The applicant responded to the inspector's questions by stating a procedure change would be implemented to address the minimum number of wraps required. The applicant further stated that in the absence of vendor recommended torque values for the hold down clamp, a " snug tight" value was appropriately applie Prior to the applicant's response, the inspector had noted by direct observation that more than two wraps of rope remained on each anchorage of the hoisting drum when the hook was in its extreme lower positio In addition, the inspector noted through discussions with the maintenance crew foreman that a " snug tight" value had been applied to the hold down

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clamps. .Thus no hardware problems resulted from the apparently inadequate procedure. The applicant's corrective actions were sufficient to correct the procedur ,

'(3) Control and Instrumentation Maintenan'ce

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The inspector' observed the performance of a loop calibratio check performed by plant staff Control and Instrumentation

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Maintenance Work Request (MWR) C-11384 on a Residual Heat Removal injection valve pressure transmitter (1E12-N0588).

The inspector noted the assigned C&I technicians had the MWR package at the job site. The referenced procedure in use, CPS No. 8634.02, revision 6, RHR Injection Valve Pressure Channel Calibration, was current. The Heise Gage being used at the-local instrument rack was within its calibration due dat The inspector observed.the C&I technicians established communications between the local instrument rack and the control room. In accordance with the procedure in use, the C&I techniciar received permission from the Shift Supervisor

.to start the activit The inspector noted that sufficient

information was provided to the Shift Supervisor by.the C&I, technician. At the conclusion of the calibration check, the inspector reviewed the results and observed the C&I

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technician's discussion of those results with his superviso The inspector concluded that the activity observed was conducted in accordance with approved procedure (4) Housekeeping and Cleanliness Control

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The inspectors 'noted that the applicant's actions to upgrade

-the cleanliness of the CPS suppression pool (see Inspection

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Report 50-461/86048, paragraph 6.a.(3)) were completed and

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appeared effective. The applicant has been generally

successful in maintaining the improved level of cleanliness l both in the suppression pool and in the drywell weir area.

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The inspectors will continue to monitor the applicant's activities in this are (5) Containment Isolation For 36" Ventilation Valves The NRC closed TMI action plan item II.E.4.2, Containment Isolation Dependability, in Inspection Report 50-461/86049, ,

paragraph 3.b. On August 8, 1986, IP provided a letter, U-600672 to the NRC Office of Nuclear Reactor Regulation concerning containment isolation for 36" ventilation valves in the containment purge system. Their letter identified that (4) 36" containment ventilation isolation valves did not

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meet the TMI action plan requirements. To compensate for this deficiency until plant modification #VQ-02 is completed to correct it, the applicant committed to lock the valves closed. The inspector will verify that the affected valves are locked closed prior to fuel load and that administrative controls require they remain locked until the modification is completed. This is an open item for fuel load (461/86054-01).

b. Emergency Procedures Review (42452)

This inspection continued a review (reference Inspection Report 50-461/86048, paragraph 6.c) 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 indicate (1) Applicable Requirements, Applicant Commitments, and Guidance Documents (a) 10 CFR 50 (b) Regulatory Guide 1.33, revision 2, " Quality Assurance Program Requirements" (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 Approval of Station Procedures" (f) CPS Final Safety Analysis Report (FSAR), Chapter 1 (g) CPS Final Draft Technical Specifications (h) NUREG-0853, Safety Evaluation Report, and Supplements

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(2) Procedures Reviewed (a) CPS No. 4001.01, Reactor Coolant Leakage, revision 4 dated February 2,198 (b) CPS No. 4004.01, Instrument Air Loss, revision 3, dated February 6, 198 (c) CPS No. 4100.01, Reactor Scram, revision 3, dated February 6, 198 (d) CPS No. 4301.01, Earthquake, revision 3, dated tlarch 3, 198 (e) CPS No. 4303.02, Abnormal Lake Level, revision 0, dated March 3, 198 (3) Discussion This inspection was to verify that the applicant had prepared the required procedures, that each of the procedures had been prepared in the appropriate format, and that the procedure was technically adequate to accomplish its stated purpos . _ _ _

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Concerning CPS No. 4303.02, Abnormal Lake Level, the inspector found that the portion of the procedure related to a high lake level (flood) was not technically adequate to accomplish its stated purpose. In particular, the inspector noted that the procedure writer-assumed that the plant could be operated at full power up to a lake level of 713.5 feet MS The CPS screenhouse is designed to protect the Shutdown Service Water system pumps and related equipment from the effects of floods up to that elevation. However, the circulating water pumps, which provide the condenser cooling water for CPS, will fail when the lake level exceeds approximately 699.0 feet MS Circulating Water pump failure will result in a plant trip on loss of condenser vacuu This procedure was discussed in detail with the Director - Plant Sperations who. stated that the procedure would be revised to provide an adequate approach for coping with flood Review of the procedures scope and technical review of the additional procedures identified in paragraph (2) above was still in progress at the conclusion of the inspection perio (4) Results Results will be reported in a subsequent inspection repor One minor security violation was identified by the applican . Independent Inspection Effort Review of Electrical Penetration Status (92701)

The inspector conducted an independent inspection to determine the current status of containment electrical penetration During a previous inspection (reference Inspection Report 50-461/86037, paragraph 6.c), the inspector noted that a number of maintenance work requests were in progress to correct deficiencies identified by the applican At the inspector's request, the applicant's cognizant engineer accompanied the inspector on a tour of containment to answer the inspector's questions concerning the observed conditions of electrical penetrations. The cognizant system engineer provided the inspector adequate responses to questions on installation techniques referenced in the applicable design drawings reviewed by the inspector (E27-1310, revision D and E05-1006, sheet 6, revision E). However, during the plant tour it was apparent that minor installation work had not been completed. The remaining work noted included installation of penetration covers, assuring that the penetrations were pressurized and that low pressure alarms were functional, assuring breather caps and drains were open, and at least one penetration (nonsafety-related) had a grounding cable i

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that was not connected outside the penetration. Additional questions were developed late in the report period concerning the portion of the electrical penetrations extending between the gas control boundary and the outer containment building wall. The observed conditions which appeared to be temporary modifications and construction debris, were discussed with cognizant IP personne The applicant was not able to provide the inspector an adequate response concerning the program used to assure the installation of these "non-system" related commodities would be complete at the time of fuel load. "Non-system" related equipment and the method used by the applicant to assure readiness of these types of equipment to support plant operation is the subject of violation (461/86048-03). The applicant's resolution of these specific work items will be reviewed in a subsequent inspection (461/86054-02).

b. ESF System Walkdown (71710)

(1) Introduction An NRC inspection team conducted an independent inspection of the applicant's system walkdown program for initial declaration of system operability. The applicant began the process of establishing proper valve and electrical lineups necessary to declare systems in service and operable per the requirements of the Clinton Power Station Technical Specifications in late July, 1986. The objective of this inspection was to evaluate t'e n effectiveness of the applicant's walkdown program in identifying operability restraints. The following paragraphs provide the details of this inspectio (2) Details The applicant had defined the reviews necessary for declaring a system " Tech. Spec.. Operable" in procedure CPS No. 1401.01, Conduct of Operatiso.5, revision 9 dated July 24, 1986. Section 8.5.10 of CPS No. 1401.01 detailed the specific steps to be performed by the Clinton Power Station Operations Department in determining when a plant system was ready to be declared

" Tech. Spec. Operable". Implementation of those requirements along with the requisite management review was the basis for the applicant's determination that a system was " Tech. Spe Operable". The following systems were selected as a representative sample of the applicant's program implementatio (a) High Pressure Core Spray (HP)

(b) Low Pressure Core Spray (LP)

(c) Shutdown Service Water - Division 2 (SX-2)

(d) Screen House HVAC - Division 1, 2, & 3 (VH-1,2,3)

(e) Essential Switchgear Heat Removal - Division 1 (VX-1)

(f) Diesel Generator Air Start - Division 1 (DG-1)

(g) Diesel Generator Fuel Oil - Division 1 (D0-1)

(h) Diesel Generator Ventilation - Division 1 (VD-1)

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A detailed walkdown of each of the above systems was performed by five NRC personnel; the SRI-Operations, the RI-Operations, the SRI-Construction, one Regional based inspector, and the NRC Licensing Project Manager. For the systems inspected, the following attributes were observed:

(a) System configuration matched the applicable control room drawin (b) Valve and electrical switch / breaker positioning agreed with the current lineup in the Operation's Department system configuration fil (c) Valves were locked when require (d) Equipment conditions appeared correct with no evidence of damag (e) Equipment and components were properly identifie (f) Interiors of electrical and instrumentation cabinets were free of debris, loose material, uncontrolled jumpers, with no evidence of rodent (g) Instrumentation was properly installed and functionin (h) Lubrication was provided, where observabl (i) Temporary modifications were properly controlle (j) Plant areas were observed during the walkdown process to identify any area / commodity items which could impact system operabilit (k) Deficiencies identified by the applicant (tags observed)

were annotated and subsequently verified to be properly controlle In conjunction with the above, the inspectors reviewed the applicant's completed walkdown packages to verify the applicant's implementation of their established program (i.e.,

CPS No. 1401.01). In addition, the inspectors reviewed outstanding maintenance work requests (MWRs) for the High Pressure Core Spray system to evaluate the categorization of outstanding work documents by plant operating mode / mileston The system walkdowns resulted in a number of questions which were referred to the applicant for resolutio In general, the questions resulted from observed discrepant conditions with minor significance to system operabilit Examples of identified discrepancies included missing vent / drain caps; missing identification labels for minor valves and major equipment; local pressure indicator not functioning properly; and minor drawing discrepancies. Each discrepant condition was reviewed with Operation's Department personnel who provided information to indicate that the discrepancies either had been or were being addresse The following items identified during the system walkdowns appeared to be of more than minor significance:

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(a) A Barton differential pressure gage used to measure the discharge pressure of 1SX01PB (the division II Shutdown Service Water pump) was installed with the low side vent capped. The installation of the cap could have resulted in inaccurate readings that varied with environmental conditions and system pressure. The applicant reviewed other similar applications and identified additional similar examples. Condition report 1-86-08-171 was initiated on August 29, 1986 to document the condition and provide for appropriate corrective actio This condition report will be reviewed further in a subsequent inspection. This is an unresolved item (461/86054-03).

(b) A steel plate was installed as a security barrier for new fuel storage around the body of valve 1E21-F005, the Low Pressure Core Spray (LPCS) outboard containment isolation valve. The plate was not shown on the applicable design drawings and was not identified as a temporary modifica-tion in accordance with the applicable CPS procedur This item had been identified by the applicant in their management walkdown of the syste A maintenance request was initiated by the applicant to remove the steel plat However, no action had been taken to determine the cause of the condition and to preclude recurrenc The inspector was concerned that the steel plate, which was installed very close to the valve body, had not been considered in the seismic design of the LPCS system. The matter was identified to the Operation's Department for review but the installed hardware had been removed before Operations could investigate the identified conditio On August 29, 1986, the inspector requested that the applicant determine (1) how the plate had been installed and under what controls, and (2) how and why the plate was removed. The applicant responded that the plate had been removed under the maintenance request initiated as a result of the management walkdow However, no installation documentation was availabl Procedure CPS No. 1014.03, Temporary Modifications, paragraph 8.1.1 requires that a Temporary Modification Permit be used to initiate a temporary modificatio CPS No. 1029.01, Preparation and Routing of Maintenance Work Requests, paragraph 3.4 requires the use of a maintenance request to identify work to be_ performed by the maintenance department. Paragraph 4.1 prohibits the installation of any temporary or permanent modification without approved design documentation. The installation of a steel plate around the body of the low pressure core spray outboard containment isolation valve was a violation

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of the above requirement The applicant failed to write a condition report upon identification of the installed condition, as required by CPS No. 1016.01, Condition Reports, to provide for evaluation and appropriate corrective actio This is a violation of 10 CFR 50, Appendix B, Criterion XVI, and CPS No. 1016.01,- paragraph 3.4 which requires that a condition report be initiated for conditions that are known to be in violation of safety-related procedures. Initiation of a maintenance request provided for correction of the specific deficiency but did not address the cause of the condition or determine the need for generic corrective actio (461/86054-04).

(c) Watertight door 1-12 separating the division I and II Shutdown Service Water pump cubicles appeared to have loose and missing hardware; the locking mechanism did not engage; a paper test of the door seal indicated that the seal was not watertight; and the door appeared to have incomplete installation of a limit switch assembl Observation of other similar watertight doors had indicated similar deficiencie Preliminary discussion with the Operation's Department indicated that the watertight doors were scoped under the HC (Hoists and Cranes) system; that the HC system was not yet operable; and that testing and maintenance programs were being developed for these doors. The inspector observed that the Shutdown Service Water system was not declared technical specification operable pending resolution of the above deficiencies. This is open pending receipt of additional information from the applicant. Open Item (461/86054-05).

Upon completion of the system walkdowns, the inspectors reviewed a computer printout of open change documents for the High Pressure Core Spray (HPCS) system. The list included 2 condition reports, 56 maintenance work requests (MWRs), and 4 nonconforming material reports. Each document had been reviewed by the applicant and had been determined not to impact HPCS system operability. The purpose of the NRC review was to verify the adequacy of the applicant's categorization. Each of the documents listed were discussed with operation's department personnel and were determined to be properly categorized. One open question concerning the calibration of a HPCS system flow transmitter remained open at the conclusion of the inspectio Open item (461/86054-06).

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(3) Results This inspection involved an extensive effort by the NRC. Two ESF systems and eight ESF support systems were reviewed in detail and the results compared with the results of similar reviews performed by the applicant's Operation's Departmen The inspection found that the applicant's program for determining system status in preparation for declaration of system operability was being performed in accordance with approved procedures and that the procedures were generally effective in establishing the system statu One violation was identifie c. Control Room Observations (71715)

An inspection in this area was performed by the NRC Senior Resident Inspector (Callaway Nuclear Plant) to assess the applicant's conduct of operations. The inspection was performed during off shift periods and focused on overall control room discipline, adherence to administrative and plant procedures, and operator attentiveness to plant parameters and conditions. This inspection also included interviews with shift crew personnel and observations of portions of the following plant activities:

Procedure N Activities RH1E12F011A M0 VATS Testing CPS No. 3408.01 Containment Building /Drywell HVAC Flow Balance Test PTP-VG-02' Secondary Containment Leak Test CPS No. 3506.01 Operation of Diesel Generator 1A (Troubleshooting and subsequent post maintenance test)

CPS No. 908 Diesel Generator 18 Operability Test CPS No. 9431.14 Intermediate Range Monitor Channel Calibration CPS No. 9431.12 Average Power Range Monitor Channel Calibratio (1) Control Room Conduct The applicant recently implemented a twelve-hour shift rotation. This action was taken to enhance control / continuity of work activities and to provide additional on-shift personnel. Although the control room "at the controls" traffic 21 I

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appeared heavy, personnel entry into this area was in response to ongoing plant testing and surveillance activitie The

" work process" window in the shift supervisor's (SS) office was effective in reducing control room traffic for the processing of work requests. The work processing activity levels were very high in both the SS office and control room. While the activities in both areas were performed in a businesslike manner, the work processing kept the SS, assistant SS, and the

"A" reactor operator at their desks for considerable periods during their shifts which detracted from supervision / operator oversight function In Supplement 6 to NUREG-0853, Safety Evaluation related to the Operation of Clinton Power Station, Appendix N, the NRC has withheld final approval of the applicant's preoperational test deferral requests pending the applicant's demonstration of their capability to satisfactorily control activities associated with deferred testing. The applicant, in letter U-600583 dated June 3, 1986, detailed specific actions they planned to take to manage activities deferred past fuel load

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to assure that those activities do not place an undue burden on startup personnel and the plant operator This matter is open pending the applicant's demonstration that the management controls discussed in letter U-600583 are in place and are effective in controlling deferred activities such that the plant operators may properly carry out their safety-related activitie Open item (461/86054-07).

A businesslike atmosphere was maintained in the control roo Except for two occasions, SS/ operator permission was obtained prior to personnel entry into the "at the controls" area. The inspector noted the appropriate absence of non plant discussions and material Applicable plant operating and test procedures were utilized and adhered to for the activities being controlled from the control room. Operational control / communication within the control room and communications between station operators and control room operators were businesslike. The SS and assistant SS provided direct supervision of operation of the 1A and 1B emergency diesel generators.

I Shift turnover and relief was thorough and businesslike. Crew supervisors, in addition to their own turnover, conducted detailed briefings with the oncoming crew. Control room station turnovers included the appropriate plant discussions, panel walkdowns, log reviews, and annunciator checks prior to turnove Control room operators were attentive / responsive to plant parameters and conditions. The inspector observed that approximately 310 control room annunciators were in an alarmed condition. The frequent recurrence of several nuisance alarms was distracting to

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the operators. The operators frequently had difficulty in promptly identifying an incoming alarm because of the large number of existing alarmed annunciator (2) Plant Logs and Records Plant logs and records were generally well maintained and very legible. System / equipment deficiencies were logged and appropriate followup action initiated, e.g. , condition reports, and maintenance work requests were processe Performance deficiencies noted in this area were as follows:

(a) The control room strip chart recorders for the suppression pool level instrument Nos. ILRCM031 and 32 had not been annotated during the preceding 24-hour perio Administrative procedure CPS No. 1401.01 (Conduct of Operations) specified that the charts be initialed, dated, and timed each shif (b) Deficiencies relating to the administrative control of Temporary Modifications (TM), CPS No. 1014.03, as follows:

1 The specified, " Estimated Date of Removal", had not been entered for eleven TMs listed in the TM Inde One TM issued April 12, 1986, had the required managers approval TMs in place greater than 30 days but lacked the specified quarterly tag reverificatio The specified quarterly audit of TMs had not been performed / documented for the period May through July 198 The applicant was responsive in the above matter. The strip charts were promptly annotated and appropriate entries were made to the TM Index. The inspector was advised that the quarterly audit of TMs had been scheduled for the week of August 18, 198 No violations or deviations were identifie Onsite Review Committee Activity (40700)

The inspectors reviewed the minutes of the following CPS Facility Review Group (FRG) meetings which were conducted prior to and during the inspection period to verify conformance with CPS procedures and the draft technical specifications. The numbers of these meeting

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minutes are as follows:

86-064 86-080 through 86-082 86-084 through 86-086

.86-088 through 86-089

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~86-09 through 86-099 86-100 through 86-109

,86-110 through 86-119 86-120 through 86-125

86-127 through 86-128 86-130 through 86-140 86-150 86-152 through 86-15 ! These reviews included verification of FRG membership availability of meeting quorum, and verification that the FRG was meeting its

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charter. The inspector noted that-the timeliness of.FRG meeting minutes preparation and distribution had improved:substantially over

! past practice. FRG meeting frequency was relatively high but

consistent with the workload. One condition report from meeting N (No. 1-86-07-009), related to performance of work without

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approved procedures, was referred to an NRC contractor inspector for

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detailed review. The results of that review will be included in Inspection Report 50-461/86059.

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.No violations or deviations were identifie , Safety Evaluation Report Review and Followup (92719)

The following items from NUREG-0853, Safety Evaluation Report related

to the Operation of Clinton Power Station, Supplement 6 (SSER 6) were

referred by the Office of Nuclear Reactor Regulation, Division of F Licensing, to Region III for confirmation of applicant action SSER 6, paragraph 6.2.7, verify that any equipment enhancements to meet the requirements of the final rule on hydrogen control are i implemented before startup following the first refueling outage.

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Open item (461/86054-08). SSER 6, paragraph 7.2.3.3, verify that the design modifications to

, correct the STS design so that upon detection of a . fault the correct NSPS division will be annunciated as containing the fault are

, implemented before startup after the first refueling outage. Open l item (461/86054-09).

~ SSER 6, paragraph 7.4.3.1, verify that design modifications to eliminate the need for using jumpers, rewiring, or disconnecting circuits when effecting shutdown from outside the control room using Division II equipment are implemented before startup after the first refueling outage. Open item (461/86054-10). SSER 6, paragraph 7.5.3.2, verify that changes to the main control room isolation valve group annunciator display tiles and primary containment isolation valve regrouping into 13 valve groups, which include 47 additional valves, is completed before exceeding 5% of rated power. Open item (461/86054-11).

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. . . SSER 6, paragraph 7.5.3.2, verify that field wiring of the 4 additional primary isolation valves to the SPDS has been completed before startup from the first refueling outag Open item (461/86054-12). SSER 6, paragraph 9.1.3(1), verify that spent fuel pool pump motors capable of operating in the post LOCA environment have been installed and tested before plant is permitted to restart from any shutdown involving fuel off-loading. Open item (461/86054-13). SSER 6, paragraph 14 and Appendix N, verify that the preoperational test deferrals, for which schedular exemptions have been granted in the low power license, are completed in accordance with the schedule given for each exemption in Appendix N. Open item (461/86054-14).

The inspector reviewed SSER 6 to assure that all open items were adequately dispositioned. The results were discussed with the NRC Office of Nuclear Reactor Regulation Licensing Project Manager for CPS. One additional open item identified during review of SSER 6, Appendix N, is

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discussed in paragraph 6.c. of this repor The above items are open and will be reviewed in subsequent inspection No violations or deviations were identifie . Inspection of Title 10 Requirements (91300)

This inspection was undertaken to ascertain the applicant's conformance with selected requirements of the Code of Federal Regulations, and to assure that the applicant was prepared to meet requirements that become effective upon low power license issuance. The following paragraphs detail the scope and results of this inspectio CFR 50.7 Posting Requirements 10 CFR 50.7 requires, in part, that

"(e) Each licensee, permittee and each applicant shall post Form NRC-3, " Notice to Employees", on its premises. Posting must be at locations sufficient to permit employees protected by this section to observe a copy on the way to or from their place of work."

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copy of NRC Form-3 in a sufficient number of conspicuous locations ( that employees could observe a copy on their way to or from their place of work.

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"(a) Each entity subject to the regulations in this part, shall post current copies of the following documents in a conspicuous position on any premises (1) the regulations in this part, (2)

section 206 of the Energy Reorganization Act of 1974, and (3)

procedures adopted pursuant to the regulations in this par (b) If posting of the regulations in this part or the procedures adopted pursuant to the regulations in this part is not practicable, the licensee or firm subject to the regulations in this part may, in addition to posting section 206, post a notice which describes the regulations / procedures, including the name of the individual to whom reports may be made, and states where they may be examined."

The inspector observed that the applicant had posted section 206 of the Energy Reorganization Act and a notice, in accordance with 21.6(b). The inspector observed that the posted notice contained outdated information and did not state where the regulations and procedures adopted could be examined. This matter was discussed with the applicant's Licensing staf The licensing representative acknowledged the out of date information and stated that a revision to the notice had been initiated by IP several weeks earlier. The licensing representative stated that the notice would be revised to state where the regulations and procedures could be examine CFR 19.11 Posting Requirements 10 CFR 19.11 requires, in part, that

"(a) Each licensee shall post current copies of the following documents: (1) The regulations in this part and in Part 20 of this chapter; (2) the license, license conditions, or documents incorporated into a license by reference, and amendments thereto; (3) the operating procedures applicable to licensed activities; (4) any notice of violation involving radiological working conditions, proposed imposition of civil penalty, or order issued pursuant to Subpart B of Part 2 of this chapter, and any response from the license (b) If posting of a document specified in paragraphs (a) (1), (2)

or (3) of this section is not practicable, the licensee may post a notice which describes the document and states where it may be examine (d) Documents, notices, or forms posted pursuant to this section shall appear in a sufficient number of places to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed activity location to which the document applies, shall be conspicuous, and shall be replaced if defaced or altered."

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. . e The inspector could find no evidence that the applicant had posted or planned to post the documents specified in 10 CFR 19.11(a).

This matter was discussed with the IP Director - Licensing who stated that the matter would be reviewed and appropriately corrected. This is an unresolved item (461/86054-15). CFR 21 Reporting Procedures The inspector briefly reviewed the applicant's procedure for reporting under 10 CFR 21 and noted that the procedures did not interface with the applicant's procedures for reporting under 10 CFR 50.73, Licensee Event Reporting (LER). The inspector observed that it is common practice for utilities to report under 10 CFR 21 using the LER as an "other" report referencing 10 CFR 2 The applicant acknowledged this observatio In addition to the above reviews, the inspector discussed the Licensing Department's involvement in the LER process and in making changes to the technical specification The inspector noted that the Licensing Department had no procedures for controlling LERs although CPS N .04, CPS Licensee Event Reports, revision 1 identified that IP Licensing had responsibility for processing the reports. The Director -

Licensing acknowledged this observation. The inspector also noted that the Licensing Department procedures for processing changes to the CPS technical specifications did not provide for making prompt changes in a nonroutine situation (i.e., emergency changes). The Director - Licensing also acknowledged this observatio No violations or deviations were identifie . Site Activities of Interest Fuel Load Schedule (94300)

On June 17, 1986, the applicant notified the NRC by letter that CPS would be ready for issuance of a low power license on or about July 15, 1986. At the conclusion of the inspection period (September 8, 1986), there were 32 of 62 required plant subsystems declared operable under the CPS final draft technical specifications to support fuel load. That activity was in progress. The applicant believed that CPS would be ready to load fuel on or about September 23, 198 Readiness For Fuel Load Meeting (30702)

On August 7 and September 8, 1986, NRC management met with IP management at CPS to discuss the current state of readiness of CPS to load fuel. These were the seventh and eighth of a series of such meetings to be held with IP management on a routine (monthly) basi Key personnel attending the meetings are identified by ($ and #,

respectively) in paragraph 1 of this repor .

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The meetings each included discussions of: the status of preoperational testing; the status of test deferrals; status of the conduct of surveillance testing for credit; status of system readiness to support operation under the CPS technical specifications; plant procedures completion status; CPS " Things" list; and the status of management actions to facilitate the transition from construction to plant operation IP Management Change (71302)

On September 8, 1986, the applicant announced that a new position had been created within the CPS plant staff management structure:

Assistant Power Plant Manager - Maintenance. That position was intended to provide additional management overview of site maintenance activitie IP Labor Negotiations (92709)

On August 14, 1986, the applicant notified the resident inspector

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that the four unions representing IP workers voted to accept the company's contract proposa The new two year contract was effective immediatel . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Two unresolved items disclosed during this inspection were discussed in paragraphs 6.b(2), and . 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. Twelve open items disclosed during the inspection were discussed in paragraphs 5.a(5), 6.a, 6.b(2), 6.c, and . Exit Meetings (30703)

The inspector met with applicant representatives (denoted in paragraph 1)

throughout the inspection and at the conclusion of the inspection on September 8, 1986. The inspector summarized the scope and findings of the inspection activitie The applicant acknowledged the inspection 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 inspection. The applicant did not identify any such documents / processes as proprietar The resident inspectors attended exit meetings held between Region III l based inspectors and the applicant as follows:

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o a. s Inspector (s) Date Wohld 8/14/86 Neisler 8/21/86 Pirtle 9/05/86 29