IR 05000461/1986060
| ML20211D732 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/17/1986 |
| From: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211D712 | List: |
| References | |
| 50-461-86-60, NUDOCS 8610220257 | |
| Download: ML20211D732 (37) | |
Text
__
U. S. NUCLEAR REGULATORY COMMISSION
'
REGION III
Report No. 50-461/86060(DRP)
Docket No. 50-461 License No. CPPR-137
.
License No. NPF-55 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 i
Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Conducted: September 8 through October 6, 1986
'
Inspectors: T. P. Gwynn P. L. Hilend D. E. Keai.ing Approved By:
fC R. C. Knop, Chief f /0//7/eg Projects Section IB Date-Inspection Summary Inspection on September 8 through October 6, 1986 (Report No. 50-461/86060(DRP))
1 Areas Inspected: Routine, unannounced safety inspection by the resident inspectors of licensee action on previous inspection findings; licensee action on 50.55(e) items; licensee action on Three Mile Island action plan requirements; employee concerns; functional or program areas (including site surveillance tours, emergency procedure review, onsite review committee activity, startup test witnessing, and operational safety verification); and onsite followup of events at operating reactor Results: Of the ten areas inspected, no violations or deviations were identified in eight of the areas. Two violations were identified in the remaining areas (1) paragraph 2.n. - inadequate corrective action concerning the post maintenance testing (PMT). program; (2a) paragraph 2.0. - failure to follow procedures and identify and correct improperly installed instrumentation; and (2b) paragraph 6.a.(3) - failure to follow procedures for personnel access and material control. The first violation had some significance to plant operational safety in that PMT provides assurance that equipment will perform satisfactorily in service after completion of maintenance activities; the failure to evaluate maintenance work for required PMT leaves the maintained /
repaired equipment in an indeterminate status. The second violation was determined to be of minor safety significance although the potential for a more significant problem existe i 8610220257 861017 PDR ADOCK 0500 1
, _ , _ _ _ _ - _ . . _ . _ _ _ _ . . _ _ _ . . - _ _ , _ , _ _ _ _
DETAILS Personnel Contacted Illinois Power Company (IP)
- J. Brownell, I&E Interface, Licensing and Safety (L&S)
- R. Campbell, Manager - QA
,
- Connell, Manager - Nuclear Planning & Support
- J. Cook, Assistant Plant Manager
- R. Freeman, Assistant Plant Manager - Maintenance
- J. Greene, Manager - Nuclear Station Engineering Department (NSED)
- H. Lane, Manager, Scheduling and Outage Management
- F. Spangenberg, Manager - L&S
- J. Wilson, Manager - Clinton Power Station (CPS)
- Denotes those attending the monthly exit meeting on October 6, 1986.
The inspectors also contacted and interviewed other staff and contractor personne . Applicant Action On Previous Inspection Findings (92701) (92702) (Closed) Unresolved Item (461/85012-03): Plant staff procedures for document control were improperly classified and had not received an appropriate level of revie This item was previously presented to the inspector for review as documented in Inspection Report 50-461/86048, paragraph 2.s. At i
the time of that review, the inspector concluded that the specific procedural deficiencies identified in the original open item had been corrected by reclassifying the procedure and providing the required level of review and approval. However, the inspector identified additional examples of plant administrative procedures
>
that were classified as nonsafety related, no facility Review Group (FRG) review required. The applicant committed to reclassify all of their administrative procedures to a safety classification and performing a 10 CFR 50.59 review on procedures that had been or
- will be downgraded.
i
'
During this. report period, the licensee upgraded all (one exception, l CPS No. 1913.00 was removed from the Operating Manual) of their
l administrative procedures to safety-related status and performed the required FRG review. The controlling procedure, CPS No. 1005.03, Operating Manual Status Report was revised to require all administrative procedures to be safety classified.
I
'
A second item, detailed in Inspection Report 50-461/86048,
. concerned the ability of an individual department head to downgrade a procedures classification without FRG review and plant manager j approval. This authorization was permitted by procedure CPS i
e I
l 2
- - - _ _ - -_ _
-. . . _ No. 1005.03, paragraph 8.4.4. The licensee reviewed this item and identified four procedures that had been downgraded without FRG review. Three of the four identified procedures were evaluated by the licensee per 10 CFR 50.59 requirements and reviewed by the FR The one remaining procedure, CPS No. 8221.02, was removed from the operating manual. The inspector confirmed that CPS No. 1005.03, revision 9, dated August 13, 1986, revised paragraph 8.4.4 to require a class code change to receive the same level of review as a procedure revisio The inspector concluded that the licensee has complied with the intent of Clinton Power Station Technical Specifications 6.5. and 6.5.3 for the items discussed above. This item is close (Closed) Open Item (461/86017-05): Verify that a 2'6" high berm has been constructed around the Unit 2 excavation site and that the berm has been stabilized with vegetation, if necessary, to prevent soil erosion (Clinton SER-Supplement 5, paragraph 2.6.1.1).
' The licensee had previously presented this item to the inspector for closure (reference Inspection Report 50-461/86037, paragraph 2.f.).
As reported in Inspection Report 50-461/86037, a number of discrepancies were noted by the inspector and the licensee was considering a routine monitoring program for the Unit 2 excavation.
j Illinois Power letter U-600662 dated August 5, 1986, detailed the licensee's intent-to revise Figure 2.5-484 of the Final Safety Analysis Report. This revision would delete the specific 2'5" berm height requirement. The licensee stated the justification for deleting the berm height requirement was that the Clinton Unit 1 is designed for flooding in the Unit 2 excavation even if the berm fails. The inspector confirmed through the Clinton 1.icensing Project Manager that the NRC staff had found this revision acceptabl The licensee has implemented Nuclear Station Engineering Instruction (NSEI) CS-6, revision 0, dated September 16, 1986. This instruction detailed the monitoring program established by the-licensee for minimizing erosion of the Unit 2 excavation. The inspector noted this instruction provided a reasonable inspection frequency (monthly and after heavy rainfall) and specific criteria for performance of the inspection. The inspector reviewed the licensee's first monthly inspection report and the first inspection report after a heavy rainfall (greater than 2" in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). These reviews confirmed the licensee's monitoring program, as described in NSEI CS-6, were in effec Based on the staff's acceptance of the licensee's FSAR revision and the inspector's confirmation of an established Unit 2 excavation monitoring program, this item is close _ _ - - _ . _ - _ _ _ _ _ _ _ _ . .
__ (Closed) Open Item (461/86037-04B): IP must complete final walkdowns for plant systems declared operable under the CPS Technical Specification On September 27, 1986, the licensee notified the NRC resident inspector that all systems required to support plant operation in mode 4 (cold shutdown) and mode 5 (refueling) had completed walkdowns and had been declared operabl NRC inspection of the licensee's program for declaring plant systems operable in accordance with the CPS technical . specifications is documented in pangraph 2.g. of this Inspection Repor NRC inspection of the licensee's process for declaring plant systems operable in accordance with the CPS technical specification was documented in Inspection Report 50-461/86054, paragraph Additional verification was performed during this report period, as documented in paragraph 6.d. of this Inspection Report. This item is close (Closed) Open Item (461/86037-04D): Additional control room observation will be performed prior to fuel load to assure proper implementation of CPS No. 1401.01, Conduct of Operation Additional NRC observation of control room activities was performed, as documented in Inspection Report 50-461/86054 (paragraph 6.c.)
and paragraph 6.d. of this repor The inspector concluded that control room activities were being performed in accordance with the requirements of CPS No. 1401.0 This item is closed, (Closed) Open Item (461/86048-05): Inadvertent Start of Division I Emergency Diesel Generator (EDG). The licensee experienced an inadvertent start of the division I EDG on June 29, 1986. The cause for the inadvertent start was determined by the licensee to be a personnel error which resulted in an inadequate tagout. As documented in Inspection Report 50-461/86048, the licensee had defined a number of inspections that were to be performed to assure-the operability of the ED During this report period, the licensee provided results of the three remaining inspection activities to the inspector for revie (1) Emergency Diesel Generator Run On August 18, 1986, the division 1 Emergency Diesel Generator completed a 24-hour run in accordance with Surveillance Procedure CPS No. 9080.03, Diesel. Generator Operability. In addition, a Post Maintenance Test (PMT) was performed per Surveillance Procedure CPS No. 9080.01, Diesel Generator
l l . --- _ _ _ - _ _
. .. .
Operability, on August 21, 1986. The licensee concluded that the division I EDG successfully completed both the 24-hour run and the PMT requirement (2) Vibration Readings on the Generator On August 13, 1986, the licensee recorded division I EDG generator bearing vibrations. The recordings were evaluated by the licensee's Nuclear Station Engineering Department and the manufacturer of the generator, Ideal Electric Company. As documented in IP memorandum Y-82074 dated September 24, 1986, the licensee concluded that the vibration readings indicated no mechanical damage had occurred to the generator as a result of the inadvertent star (3) Comparison of Lead-wire Readings With Birth Records The licensee recorded the lead-wire readings (clearance measurement) on both the 12 cylinder and 16 cylinder engines for Division _I EDG u~nder Maintenance Work Request (MWR) C-23206 following the inadvertent start event. The current lead-wire readings were evaluated by the Plant Staff Technical Department cognizant engineer. The cognizant engineer compared the current lead-wire readings with the birth records and presented those results to the inspector for review. The results tabulated by the cognizant Technical Staff engineer indicated the lead-wire readings taken were within the specified acceptance criteria of 5 mils delta between the ends of the wire and a 30 mil delta between the current readings and the birth record The inspector concluded that the licensee had completed the inspections necessary to evaluate the operability of the ED The results of the licensee's inspections and post maintenance testing indicated to the inspector that the licensee had adequately reviewed the inadvertent start of the Division I Emergency Diesel Generator. This item is close f. (Closed) Open Item (461/86054-06): Review of work documents open against the High Pressure Core Spray (HP) system identified one document that could impact system operability. That document had not been closed prior to declaring HP operable under the CPS final draft technical specifications. This matter remained open pending additional revie The licensee presented this item.to the inspector for closure. The work document, maintenance work request No. C-18321, involved a required recalibration of the HP system flow transmitter,1E22-N00 That instrument was used during surveillance testing to establish HP system performance (flow) within the limits of the CPS Final Safety Analysis Report. The identified problem was related to the failure of measuring and test equipment (M&TE) (used in October,
-. - _ , - . - _ . - - - _ - - - - - . - - - --- ---- -,
1985, to calibrate 1E22-N005) to meet recalibration requirement The out of' calibration condition on the M&TE could have adversely affected the readings obtained from the HP system flow transmitte Investigation by the licensee revealed the following sequence of events related to this open item:
10/08/85 - 1E22-N005 calibrated using M&TE #1 12/14/85 - 1E22-N005 recalibrated using MhTE #2 03/13/86 . M&TE #2 calibration check was satisfactory 04/04/86 - M&TE #1 found out of calibration 05/27/86 - MWR .#C-18321 initiated based on inaccurate use history analysis which had not identified the recalibration of 1E22-N005 on 12/14/8 Based on the licensee's investigation, it was determined that MWR C-18321 did not affect HP system operability and that the MWR was not needed. The inspector concurred in this determination. This item is closed, g. (Closed) 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 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 inspected as documented in Inspection Report 50-461/86048. That inspection indicated that CPS No. 1401.01 and Operations Standing Order No. 49 provided a basis for declaration of initial system operability that appeared adequate to assure that each system required for operation was operable and that any inoperability items were adequately identified and tracke This item remained open pending responses to two questions, as follows:
(1) IP was to provide a listing of plant systems required to support plant operation, by milestone, for NRC revie (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."
Concerning question (1) above, the inspector reviewed an Operations Department document entitled " CPS System Support Requirements" dated July 28, 1986, which included a listing of plant systems required to support plant operation by milestone. That listing was verified against the CPS final draft technical specifications and found to be
. , - - ,.-. .- m ,___mmm.-, .,ym,_.,..-.,+,,_yw_, g y , , . . --, -
g..m_7- ,, . y , ... y,.,
consistent with draft technical specification requirement That listing was used by the plant operators as the basis for prioritization of work activities toward achievement of fuel loading and subsequent milestone Concerning question (2) above, the inspector reviewed IP memo JAM-86-354 dated August-8, 1986, which provided the requested information. In addition, the inspector interviewed-personnel involved in the review process and determined that established criteria were consistently applied in determining which work items were required to support each applicable mileston NRC review of the prioritization of work items for the High
>
Pressure Core Spray (HP) system was documented in Inspection Report 50-461/86054, paragraph 6.b.(2). One open item resulting from that inspection (461/86054-06) was closed during this inspection (see paragraph 2.f. of this report). No discrepancies were identified during those review Finally, during this inspection period the licensee performed a consolidation of their Sitewide Statusing System (SWSS). The SWSS was a centralized listing of all work items that might impact the operation of CPS. The consolidation was performed in order to demonstrate to NRC Region III management that the work load CPS had deferred beyond licensing was' reasonable with respect to their schedule and manpower constraints. The criteria used by the licensee to perform the consolidation were as follows:
Criterion N Criterion (1) The work to be performed was.being tracked under a high tier document that duplicated the lower tier work document. [ Remove duplicate items].
(2) The work to be performed did not impact the plant. [ Work documents to perform work on office equipment and similar items outside the protected area fence were removed from the list].
(3) The work to be performed was routine work that did not directly impact the plant (i.e.,
maintenance work on spare parts, repair and calibration of measuring and test equipment, preventive maintenance items, and similar items).
The inspector reviewed the criteria in detail and discussed the results with Region III management. No exception was taken to the criteria applie _ _ _ _ _ _ _ _ _ _ _ _ _ ~ _ _ _ . - .
The inspector then reviewed a computer listing of all maintenance work requests that were excluded from the SWSS count of " things" required by plant milestone. The computer listing, dated September 23, 1986, was reviewed to verify that the types of things excluded from the consolidated SWSS were consistent with the criteria documented above. The inspector identified no inappropriate applications of the criteria to types of thing The inspector reviewed IP memorandum Q-07249 dated September 25, 1986, SUBJECT: Assessment of " Things" List. That memorandum documented a-special assessment by the Manager - Quality Assurance and the Director - Nuclear Training Department of the process used to consolidate the SWSS. The results of the assessment were as follows:
(1) An'auditable trail to the specific " Things" affected exists in the Licensing and Safety department in the form of marked-up computer printouts and memos from the Nuclear Program Department (2) The decision process applied by Nuclear Program Departments in screening " Things" appears appropriate and reasonabl (3) Questions on specific " Things" asked during the assessment we answered by departmental persor.nel. Further, the questions raised by Mr. Schaller regarding MWRs in his memo, RFS-470-86 dated September 19, 1986, have been adequately addresse The inspector discussed the above results with the Manager - QA and the Manager - Licensing and Safety. The inspector concluded that there was a high degree of assurance that the consolidated SWSS provided a reasonably accurate listing of pending work then identified as being required to support plant operation. The following data summarize the SWSS count of " Things" by milestone as it existed on September 23, 1986:
Milestone Number of " Things" Fuel Load . . . . . . . . . . 27 Initial Criticality . . . . . 344 5% Power .......... 214 100% Power ......... 74 First Refuel Outage . . . . . 126 Not Milestone Related . . . . 1175 Total . . . . . . . . . . . . 1960 This item is closed.
.. - --. -- . _- .. -
. . . _ _ _ --
.. - ._ - .- . . _ _ _ _ . -
_ __ _ (Closed) Open Item (461/86054-07): Verify that commitments contained in IP letter U-600583 dated June 3, 1986 concerning control of deferred preoperational test activities are in place and effective. The inspectors requested that the licensee perform an audit of the management controls described in the referenced letter to assure their implementatio The licensee presented this item to the inspector for closur The licensee provided a Licensing and Safety Department (L&S)
Review Report entitled " Management of Activities Deferred Past Fuel Load" dated September 23, 1986. That report concluded that the commitments made by the licensee in-their letter U-600583 had been satisfactorily addressed for fuel load and that any outstanding commitments had been entered into the IP Centralized Commitment Tracking System to ensure their implementation at the appropriate mileston The inspector was assisted in this review by an Argonne National Laboratory contractor inspector. The inspector reviewed the IP letter and the L&S Review Report and verified that each reference letter commitment had been addressed by the licensee. However, the inspector noted that the licensee's Review Report had not addressed the effectiveness of the management controls contained in the referenced lette The inspector noted that the major concern being addressed related to the ability of the plant operators to control the licensed operation of the plant without being unduely burdened and/or distracted by nonroutine operations including completion of deferred activities. The management controls described in letter U-600583 appeared to provide a reasonable approach to the control of deferred activities. However, the management controls described had not been demonstrated to be effective in accomplishing their intended purpose. This matter was discussed with licensee management including the Vice President - Nuclear. In response to this NRC-concern, the Vice President - Nuclear directed the Manager - Nuclear Program Coordination to assess the effectiveness of the management controls, as follows:
"During the conduct of critical reactor operation, activities in the Control Room must be such that the routine safe operation of the reactor is not interfered with by othcr activities. To ensure that this goal is maintained, you are to conduct a minimum of two assessments of control room activities to determine the effectiveness of the programs in place to sustain this safe envircrfrent. This assessment should include monitoring such key indicators as late or overdue surveillances, operator attentiveness to plant operations, congestion in the control room and other items that can dctermine the ability of the Control Room Operators to safely cperate the reactor plant. The first of these
. -~ _ __ _- - _ _ _
assessments should be conducted approximately three days after Initial Criticality and the second should be conducted approximately three weeks after Initial Criticalit I request that you provide me a formal, written report summarizing the results of your assessments within two days af_ter their completion. You should use personnel who are knowledgeable and experienced in control of reactor operation and who are not directly assigned to the Plant Staff to assist you with thase assessments."
The inspector will review the results of the above assessments in a future inspection. Open item (461/86060-01). This item is close (0 pen) Open Item (461/85039-23): The public address system (Gaitronics) which includes the site-wide warning (siren) system must be completely installed and operational prior to fuel loa This item was previously inspected in Inspection Reports 50-461/86048 and 50-461/86059. Those inspections showed that, while the gaitronics system was completely installed and had~
been successfully tested using procedure PTP-CQ-01, a number of
,
'
gaitronics units remained inoperable. In addition, the audibility and intelligibility of voice announcements accompanying sitewide alarms ["All Page" function] was marginal in most plant area The normal " unit page" capability was fully functional in most plant area During this inspection period, the inspectors observed the performar.ce of two weekly siren surveillance tests performed under procedure CPS No. 3842.01, Plant Communications Alarm Tes The weekly tests were observed to judge the results of licensee corrective actions concerning marginal audibility and intelligibility of voice announcements accompanying the sitewide alarms observed during the previous inspectio The first weekly siren test observed on September 19, 1986, indicated that continuing audibility problems existed in numerous areas in the CPS power block. In particular, voice announcements could not be understood in the drywell, on the fuel handling floor in the fuel building, and in various areas of the control and auxiliary building. Observations by the inspector during the week of September 21 indicated that the ability to operate site-wide announcing and siren equipment at the remote shutdown panel had not been demonstrated. The licensee stated that CPS No. 3842.01 would be revised to include a routine check of that additional capabilit A second siren test observed on September 26, 1986 indicated that the equipment at the remote shutdown panel was capable of actuating the sitewide alarm sirens but that the paging / announcing capability was not operable. A maintenance work request had been initiated by the licensee to provide for correction of this deficienc _ _ - .. .. . -. . - _ _ _ _ _ - _ _ _ .-- _ _ _ _ _ _ .
.._
_
In order to provide interim guidance to site personnel concerning actions to be taken when announcements associated with site alarms could not be heard, the Manager - CPS promulgated instructions on Sepicmber 21, 1986 directing that all personnel hearing an alarm without an accompanying announcement were to assume the alarm was valid unless instructed otherwise. In addition, the licensee stated that a root cause analysis would be performed to determine a corrective action plan before reactor initial criticality to address observed reliability problems with the gaitronics communications equipment. This matter will be reviewed further during a subsequent inspectio (0 pen) Open Item (461/86054-01): Containment Purge 36" Ventilation
,' Valves. Illinois Power letter U-600672, dated August 8, 1986, identified four 36" containment ventilation isolation valves that did not meet the TMI action plan requirements for containment isolation dependability. The licensee committed to lock these four valves closed until completion of plant modification #VQ-0 Prior to fuel load, the inspector confirmed that valves IVR001A, IVR001B, and IVQ004A, and IVQ004B were tagged closed at their l
control switches in accordance with procedure CPS No. 1014.01, Safety Tagging Procedure. In addition, the inspector confirmed Test Change Notice (TCN) #1 was issued for Preoperational Test Procedure PTP-VQ-01~to assure the subject valves remain closed until completion of Plant Modification #VQ-02. This item remains open pending completion of Plant Modification #VQ-02 prior to the Clinton Power Station initial criticality, (0 pen) Open Item (461/86054-02): Electrical Penetrations. During a previous inspection, it was noted that minor installation work was
, _still remaining on numerous containment electrical penetration During this report period, the licensee wrote Condition Report (CR) 1-86-09-072 which documented material deficiencies on the containment electrical penetrations. As a result of this CR, the licensee conducted an. inspection of all containment penetrations and identified a number of discrepant conditions. Illinois Fower memorandum Y-82091, dated September 24, 1986, detailed the corrective actions the licensee planned for deficiencies identified during the above inspectio !
The inspector reviewed the results of the electrical penetration inspection performed by the licensee and concluded that the licensee's milestone for repair of the noted discrepancies by initial criticality was reasonable. However, the inspector i
questioned the licensee's initial criticality milestone for completing installation of the electrical penetration enclosure i
'
covers. The licensee subsequent to the inspector's questions, completed installation of all electrical penetration enclosure Cover . . - _ _ . _ - - _ - - - _ _- -
- .__ -
_ . _ . _ _ _ _ . This item remains open pending licensee completion and the inspector's review of all required corrective action taken before initial criticalit . (0 pea) Open Item (461/86054-05): Deficiencies related te watertight doors. During a previous inspection the watertight door s in the plant were observed to have numerous minor hardware deficiencies indicating inoperable status. Testing and maintenance programs had not'been established for these door The licensee presented this item to the inspector for closure. A maintenance and testing program had been prepared and implemented for all 18 watertight doors in the plant. Necessary maintenance (both preventive and corrective maintenance) had been completed and all doors were fully operable on September 24, 1986. However, during the course of establishing the operability of these doors, the licensee identified several weaknesses in the design of the door latching mechanism as documented in condition report (CR)
No. 1-86-09-082 dated September 10, 1986. The generic. corrective action under that CR was to implement a modification, No. HC-20,
-to improve reliability of door operation. That modification had not been completed at the time of this inspection. In addition, a maintenance procedure related to these doors had been prepared but was not approved at the time of this inspectio The plant staff operations department was provided operability criteria concerning these doors by the Nuclear Station Engineering Department (NSED) via NSED letter Y-81955 dated September 12, 198 Plant staff operations department issued a standing order (DOS 0-008, Watertight Doors, dated September 23,1986) based on the NSED letter to provide direction to the plant operators concerning control of watertight doors and actions to be taken in the event of door inoperability. The Supervisor - Plant Operations also issued Night Orders to all operations department personnel directing the plant operators to verify the correct position of watertight doors during their rounds on shift. Watertight doors were stenciled to direct l all personnel to maintain the doors closed.
<
The inspector reviewed the information presented by the licensee, observed the condition of several watertight doors at random, and j discussed inspection results with the licensee. No discrepancies were identified.
l The inspector concluded that the licensee had adequately established l
the status of each watertight door; had prepared a maintenance and testing program to preserve the operability of the doors; had established directions concerning door operability and measures to be taken when doors are inoperable; had provided direction to personnel to traintain the door closed; and had established a mechanism to verify proper door positioning. Those actions were ( sufficient to resolve this open item for fuel load.
i 12 l
l l
. . _ _ , . . _ , _ _ _ . . _ _ . . . _ . . _ , _ _ _ _ _ _ , _ _ _ _ _ . _ _ _ _ _ _ . _ . _ _ _ _ . . _ _ _ _ .
. . . .
Based on discussion with the licensee, modification HC-20 will be complete and the maintenance procedure-for watertight doors will be approved prior to initial reactor criticality. This item remains open pending verification that those actions are complete prior to initial criticalit (0 pen) Open Item (461/86054-14): Verify that the preoperational test deferred beyond fuel loading is completed in accordance with the schedule in the CPS Safety Evaluation Report Supplement 6 (SSER 6) Appendix The inspector reviewed the licensee's integrated milestone schedule and deferred testing schedule with Licensing and Safety department personnel. That review indicated that current licensee schedules for performance of deferred testing were in agreement with the schedular requirements of SSER 6, Appendix The inspector also reviewed the status of completion of deferred preoperational testing. As of September 25, 1986, the licensee reported that deferred preoperational testing was 49% complete overall. The following table presents the detailed deferred testing status presented to the inspector by the licensee:
Test Deferred System Activity % Complete Milestone Plant Process ATP-CX-01 75% Init. Cri Computer (CX) ATP-CX-02 73%
Turbine Electro- ATP-EH-01 70% Heatup Hydraulic Ctrl. (EH)
Traversing Incore PTP-TP-01 56% 5% Power Probe (TP)
OffGas System (0G) PTP-0G-02 61% Head Set XTP-00-12 80% prior to PTP-V0-01 100% Heatup PTP-00-01(V0) 100%
MSIV-LCS (IS) PTP-IS-01 0% Init. Cri Containment PTP-CM-01 49% Init. Cri Monitoring (CM)
Leak Detection (LD) PTP-LD-01 46% Init. Cri Solid Radwcste (WX) PTP-WX-01 29% Commercial Op Fuel Pool Cooling / PTP-FC/SM-01 0% 5% Power Cleanup (FC/SM)
Fuel Handling (FH) PTP-FH-01 0% 5% Power
=-- _ . . __ _ . . ._ _- - _ . - .
.
. __ - _ _ . _ _ -
I Aux. Bldg. HVAC (VA) PTP-VA-01 100% Heatup PTP-00-01 ~100%
Drywell Purge (VQ) PTP-VQ-01 25%' Heatup PTP-00-01 0%
i XTP-00-12 0%
Drywell Cooling (VP) PTP-00-01 41% Heatup Cntmt. Bldg. HVAC (VR) PTP-00-01 45% Heatup t
Turbine-Bldg. HVAC (VT) PTP-00-01 42% Heatup Radwaste Bldg. HVAC PTP-00-01 38% Heatup (VW) XTP-00-12 6%
Ctrl. Room Vent. (VC) XTP-00-12 53% Init. Cri Pressure Boundary PTP-00-02 16% Heatup and Testing 5% Power I
Area Temperature PTP-00-01(VH) 0% Commercial Op
- Surveys PTP-00-01(VX) 0%
PTP-00-01(VY) 0%
The inspector will continue to monitor the licensee's progress in this area in subsequent inspections.
!
n. (Closed) Unresolved Item (461/86023-05): Post Maintenance Testin During the conduct of Audit Q38-86-10, Illinois Power Quality Assurance identified an implementation deficiency (10-3) concerning the plant staff's control of post maintenance testing (PMT). The
audit finding stated that post maintenance testing requirements i were not being processed by plant staff in accordance with plant procedures. At the time of audit Q38-86-10 procedure CPS N .01, Maintenance Work Requests, was controlling post maintenance testing requirements for equipment under plant staff's jurisdiction.
'
(1) Background i
As reported in Inspection Report 50-461/86048, paragraph 2.1.,
the licensee revised the administrative controls for evaluating and processing PMT requirement In that report, the inspector concluded that the administrative controls were in place as described in procedure CPS No. 1401.01, revision 7, Conduct of Operations. The PMT requirements established in CPS No. 1401.01 replaced the PMT requirements previously defined in CPS No. 1029.01.
,
Alimitedscopeaudit(Q38-86-35) was performed by the licensee ( on June 27 through July 2, 1986, to verify corrective action
,
for audit finding Q38-86-10-ID3. The results of this audit
,
_ _ . . _ . _ . . . _ . _ . _ . . - _ _ _ _ _ , _ _ . . _ . _ , _ . _ . . _ _ _ _ _ _ _ _ . _ _ . _ _ _ _
- _ _ _
indicated.that corrective action was not completed since eight out of ten sampled maintenance work requests (MWRs) did not receive a post maintenance test (PMT) evaluation as required by the revised administrative controls detailed in the procedure
' CPS No. 1401.0 In addition to the above audits (Q38-86-10 andQ38-86-35), the licensee had identified PMT program deficiencies in IPQA surve~illance finding M-86-005, dated February 13, 1986. The surveillance finding was similar to the audit implementation deficiency Q38-86-10-ID3, in that it clearly identified the inadequacy of procedure CPS No. 1029.01 in the processing of PMT evaluations, On August 1, 1986, IPQA Audit Finding Q38-10-ID3 was closed on the basis of a sample audit which verified PMT evaluations were
performed in accordance with CPS No. 1401.01. The closure of this_ audit finding was documented in IP memorandum Q-01017, dated August 1, 1986. IPQA Surveillance Finding M-86-005 was closed via IP memorandum Q-07787, dated July 29, 1986. The basis for closure of this surveillance finding was the issuance of procedure CPS No. 1401.01, revision 7; the training provided to Operations personnel involved in processing PMTs; and the commitments detailed in IP memorandum DMA-0102-86, dated July 17, 198 (2) NRC Review On September 5,1986, the inspector attempted to verify that PMT evaluations had been completed on a random sample of 23 MWRs completed between March and July, 1986. That ' inspection effort, as documented in Inspection Report 50-461/86054, paragraph 2.e., identified two MWRs (C-24375 and C-25145) that had not received the required PMT evaluation. The licensee, subsequent to the inspector's findings, reviewed all MWRs closed since July 1, 1986, that were in the vault without a PM The licensee identified approximately 400 MWRs that were
missing their required PMT evaluations. Of these 400, the licensee determined that 59 required some post maintenance testing. The licensee concluded that a breakdown in their evaluation process had occurred between July 1 and July 16, 1986, which resulted in the identified discrepancie On September 18, 1986, the inspector selected another random sample of 24 MWRs that were completed between April and August, 1986. The purpose of this sample was to verify that required PMT evaluations were being performe In addition, the inspector attempted to verify corrective action in response to the inspectors findings for the sample inspection performed on September 5, 1986, described above. The inspector identified one MWR (C-06503) that had not received the required PMT evaluation. The licensee, subsequent to the inspector's findings, reviewed an additional 578 MWRs that had been outside the scope of the review (MWRs which were
.
--- __ ___ _ _ _ _ _ _ __ _
__ _. _ _ _ _ _ _ _ _ _ _ .
vaulted) performed following the inspector's September 5, 1986 inspection. The licensee stated that a total of 228 MWRs (including the 59.MWRs from above) required post maintenance testing. The licensee reported on September 26, 1986, that 181 of these 228 MWRs had the required testing complete For the above MWRs that the licensee stated post maintenance testing was not required to be completed before Fuel Load (228 - 181 = 47), the inspector randomly selected 37 of the 47 for review. The inspector reviewed the PMT requirements with a Clinton Power Station Shift Supervisor in order to determine the adequacy of the decision process made for these post fuel load test requirements. The inspector concluded the evaluations were correct in that the required tests were for systems not required to be operable in mode 5 or the tests were visual inspections that could only be performed after the system was placed in normal operatio On September 26, 1986, the inspector selected another random sample of 46 MWRs that were closed between March and September, 1986. The purpose of this sample was to verify corrective actions to the inspector identified discrepancies noted abov MWR C-05302 was missing its required PMT evaluation. This MWR was written for the purpose of vacuuming (cleaning) the inside of electrical junction boxes. The licensee concluded that this MWR had been evaluated based on the work description contained within, and that post maintenance testing was not require The inspector concluded that this was an isolated case and that the licensee had adequately reviewed all MWRs requiring PMT evaluatio (3) Conclusion The licensee's corrective actions in response to IPQA Audit Q86-38-10 and IPQA Surveillance Finding M-86-005 were not effective as evidenced by the inspector reviews conducted September 5, 18, and 26, 1986. The licensee's review of the inspector's findings identified 978 MWRs that required additional evaluations for post maintenance testing requirements. This~is a violation of 10CFR50, Appendix B, Criterion XVI, as implemented by IP Operational Quality
,
'
Assurance Manual, Chapter 16 which states in part that each IP organizatiu shall have a documented corrective action system which assures that conditions adverse to quality are corrected to preclude recurrences (50-461/86060-02).
o. (Closed) Unresolved Item (461/86054-03): Differential Pressure Transmitters Low Side Vent Plugged. During the conduct of an NRC walkdown of the Clinton Power Station (CPS) Shutdown Service Water System (SX), the inspector identified a Barton Differential pressure transmitter (1PISX017) that was installed for use as a direct pressure reading instrument with the low side vent plugged. This i
condition could cause the direct reading to be inaccurate due to the low side not being vented to atmcsphere.
'
__
_ _ _ . _ _ ___- _ _ , .__ _- _ _ . _ ..
___ ._ .
The licensee initiated Condition Report No. 1-86-08-171 in order to investigate and take corrective actions in response to the inspector
' identified condition. The licensee's review identified 252 instruments that could have been impacted by failure to properly vent the low side. The licensee conducted a field inspection of each of the 252 instruments under Maintenance Work Request (MWR)
C-19932. Results of this field inspection identified two additional instruments with the low side vent plugged (IPS-IA084 and 1PS-IA085)
which were subsequently reworked and recalibrated under MWR C-3345 Prior to initiating the above inspection effort, the licensee had identified two additional instruments (0PSVC093 and OPSVC193) that had been calibrated with plugs in the low side vents. MWR C-20099 was initiated by the licensee to remove the installed plug and recalibrate the instrument In summary, a total of five instruments were found with the low side vent plugged. These instruments and a brief description of their function follows:
IPSIA084 - Automatic Depressurization System (ADS) air supply header. overpressure alarm for Division PSIA 085 - Automatic Depressurization System (ADS) air supply header overpressure alarm for Division I OPSVC093 - Chiller Pressure Switch for the Control Room Ventilation system chiller OVC13C OPSVC193 - Chiller Pressure Switch for the Control Room Ventilation system chiller 0VC13C IPISX017 - Local pressure indication for Shutdown Service Water Pump 1B discharg As noted above, the licensee failed to identify the improperly ~
installed differential pressure instrumentation during the routine conduct of CPS.No. 8801.01, Instrument Calibration. This is a violation of 10 CFR 50, Appendix B, Criterion V, and CPS No. 8801.01, paragraph 8.1.5 which requires an inspection of the instrument being calibrated for process fittings (86060-03A).
The inspector's review of Condition Report 1-Co-08-171 and Maintenance Work Request C019932 indicated that the licensee had conducted a thorough review to identify all instruments that could have a potential for a required low-side vent being plugged. The licensee conducted a field inspection of all 252 instruments with the potential problem and corrected all identified deficiencie Based on the licensee's review and the results presented to the inspector, no additional response from the licensee was require This item is close _ . -- . _ - - . _ -. . _-- . - _ - - - - (0 pen) Unresolved 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 requirement This item was previously reviewed in Inspection Reports No. 50-461/85045, 85057, and 86048. At the conclusion of the inspection documented in Inspection Report No. 50-461/86048, the licensee had not explicitly reviewed their procedures to-the requirements of ANSI N18.7-197 The licensee presented this item to the inspector for closur The source document index required by ANSI N18.7-1976, paragraph 5.1 had been reviewed by the licensee, updated, and procedures reviewed to assure that the applicable requirements of the ANSI standard had been incorporated. Necessary (minor) changes to plant procedures resulting from the procedure review had been complete During their review, the licensee identified five ANSI N18.7-1976 requirements that were being met by standing orders rather than requirements of the station procedures manua A centralized commitment tracking (CCT) system item (CCT #043179)
was issued on September 17, 1986, to require revision of affected procedures to incorporate the ANSI N18.7-1976 requirements prior to initial criticalit The condition report (CR) identified in Inspection Report 50-461/85012 that was tracking the licensee's actions to complete an independent technical review (ITR) of station procedures had been completed for all procedures required for fuel load. However, additional actions were required to complete the ITR for plant procedures required to support subsequent milestone The inspector reviewed the information provided by the licensee; verified the status of plant procedures through a random check of the plant procedures manual; and discussed the information provided with cognizant licensee personnel. The inspector noted that the ANSI N18.7-1976 matrix did not reflect the procedures that departments other than plant staff relied upon to meet the ANSI N18.7-1976 requirements. The licensee stated that those procedures had been identified and verified that the matrix required updating to reflect the correct information. The inspector concluded that those activities necessary to support plant operation prior to initial criticality had been adequately addressed by the license However, this item remains open pending receipt and review of the completed ANSI N18.7-1976 matrix; completion of actions required to close CR #1-84-09-053; and completion of CCT #043179. (Closed) Violation (461/86048-02): Maintenance supervision failure to evaluate corrective action and work completion. While attempting to verify installation of loss of voltage alarms prior to fuel load (SSER2, paragraph 7.4.3.2), the inspector identified a'n improperly
_ _. _
closed maintenance work request (MWP.). The MWR had been signed off as completed by the assigned maintenance technician and the maintenance superviso '
The licensee responded to the violation in a timely manner. The work omitted from the original MWR (C-06466) was performad during this report period under MWR C-22363. A successful operational test of the loss of voltage alarms was performed during the report period with the inspector presen The maintenance technician and the supervisor responsible for the original MWR were both counseled by the Control and Instrumentation (C&I) supervisor on the proper completion and review of an MWR. In addition, the licensee conducted training of all C&I field personnel who work MWRs. The purpose of this training was to stress the importance of following MWR job steps. The inspector reviewed training records and interviewed the C&I supervisor responsible for the original wor '
The inspector confirmed the licensee's corrective actions were complete. This item is close (0 pen) Violation (461/86037-02): Procedure CPS No. 9052.02, Low Pressure ~ Core Spray Valve Operability Checks, did not provide sufficient detailed instructions and/or appropriate acceptance criteri.a for determining that important activities had been satisfactorily performed.
.
The applicant responded to the violation in letter U-600689 dated August 25, 1986. The actions taken by the applicant appeared to be responsive to the violatio The inspector reviewed CPS No. 9052.02, revision 21, dated July 31, 1986, and found that the specific matters addressed in the Notice
of Violation had been correcte The inspector reviewed a sample of the procedures the applicant
! hac identified as being required to support fuel load. Each of l the procedures reviewed had been revised to address the matters t
addressed in the Notice of Violatio ~
The inspector reviewed CPS No. 1011.05, Surveillance Procedure Guidelines, and determined that the procedure was under revision to address the matter concerning reporting of all failures to meet acceptance criteria to the Shift Supervisor. The applicant stated that this revision was scheduled for completion by October 20, 198 The inspector reviewed CPS No. 1887.00, Inservice Inspection Program, and determined that the program did not presently meet the ASME Code,Section XI, IWV-3417(a). The inspector also noted that the implementing procedures reviewed did not provide a mechanism to accomplish IWV-3417(a) requirements. In addition, the inspector
,
.
- - _ - - - _ - - , _ -__ _ __ m y. _ _ _ _ . - . . . _ _ . _ _ . . _ _ _ . , . _ . _ _ . . - _ . . . ~ , _ . ._.-. ., ,,,,a _ , - .- --_ m - _ , . - , _ . - _ .
_ =_
noted that the basis for establishing valve stroke time acceptance criteria contained in CPS No. 1887.00 was not consistent with information contained in Attachment B to the applicant's letter U-600689. This matter was discussed with the applicant who stated that CPS No. 1887.00 was under review for revision. Questions concerning the adequacy of the applicant's inservice testing program were referred to a Region III specialist inspector for followup under unresolved item (461/86037-03). These matters will be reviewed further at a subsequent inspectio The inspector noted that additional procedures required revision to support plant operation which the applicant had identified as bein required to support initial criticality. This violation will be reviewed further in a subsequent inspection to assure that the applicant's actions are complete prior to initial criticalit (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 This violation was previously inspected as documented in Inspection Report 50-461/86054, paragraph 2.j. Due to the potential for escalated enforcement action concerning this violation, a Notice of Violation and the licensee's response had not been issued at the time of this' inspection. This inspection was undertaken to determine the status of the licensee's actions taken and to establish what impact, if any, the results of the licensee's
investigation may have on issuance of an operating license for CP The inspector met with the licensee on September 20, 1986, to review actions being taken to resolve this violation and the status of implementation thereof. The following actions were identified by 4 the licensee and were reviewed by the inspector:
(1) Concerning the specific deficiencies related to floodproofing of the CPS screenhouse identified in Inspection Reports
!
50-461/86048 and 86054, the inspector verified that the observed deficiencies had been corrected. The licensee completed a substantial walkdown program for the screenhouse and the CPS power block to assure that floodproof seals, watertight doors, and similar flood-protection features were properly installed. Four minor plant modifications were required to fully demonstrate compliance to applicable i
requirements. Those plant modifications (Nos. A-47, A-67, A-71, and A-73) were either completed or had been evaluated by the licensee as not impacting fuel load. All four required modifications were scheduled to be completed prior to reactor initial criticalit The inspector reviewed the scope of each modification and verified that the licensee had appropiately determined the required completion mileston _ _ _ - . _ _ _
-
_ _ _ - _ __ - - _ - _ _ - _ _ _ _ _ _ _
-- . _ . -
For additional information concerning the status of plant watertight doors, see paragraph 2.1. of this report. For additional information concerning the status of containment electrical penetrations, see paragraph 2.k. of this repor (2) Concerning other interfaces between CPS Unit I and the cancelled Unit II, IP-Quality Assurance (QA) performed an extensive walkdown inspection of Unit I/ Unit II interfaces during the period August 27-29, 1986. Their results were
documented in QA Surveillance Report No. CQ-01863 dated September 8, 1986.
'
The inspector reviewed the results of the IPQA walkdown and found that no significant deficiencies were identified during the walkdowns. Some. inaccessible items were appropriately verified by document review.
,
I (3) Concerning the adequacy of the commodity turnover program, the licensee's Nuclear Station Engineering Department and the CPS architect engineer, Sargent and Lundy, performed a detailed review of the commodity turnover process and reviewed the results of other quality programs to determine if credit could be taken for those programs to assure quality of specific commodities (i.e., the IP Overinspection Program, BA Field Verification, etc.) after turnover. The licensee reported that their review in this area was complete and that there were no deficiencies identified that would restrain the issuance of an operating licens Based on the review of the information presented by the licensee, interviews of cognizant personnel, and direct observation by the
!
inspector, the inspector agreed that there were no deficiencies apparent that would restrain the issuance of an operating licens This matter will be reviewed further in a subsequent inspection, t. (0 pen) Violation (461/86054-04): Unauthorized modification installed around the body of Low Pressure Core Spray (LPCS) outboard containment isolation valve 1E21-F005. A steel plate used as a
>
temporary security barcier was installed around the LPCS isolation valve without proper controls. Although the licensee identified this condition during a macagement walkdown, no action had been taken to determine the cause of the condition and to preclude recurrenc During this report period, the licensee provided the inspector with informal results of their investigation into the subject violation.
The licensee's formal response was to be prepared after receipt of the Notice of Violation contained in Inspection Report 50-461/86054.
-_. . - - _ - -. . _ _ _ . _ . , - - - . _ _ _ - _ _ - - - - - -. _ - - _ _ .
The licensee wrote Condition Report (CR) 1-86-09-083 which described the above condition. The root cause was identified to be personnel error by the maintenance contractor (Stone & Webster) and Illinois Power. The maintenance contractor was replacing temporary wood barriers with temporary steel barriers on openings to the fuel handling floor of the Fuel Building. These barriers were used by the licensee as security barriers in accordance with the licensee's security plan for their Special Nuclear Material licens Contrary to the requirements of procedure CPS No. 1029.01, Maintenance Work Requests, the maintenance _ contractor (S&W) acted on verbal direction from the licensee when installing the steel barriers. Maintenance Work Request (MWR) C-09903 was prepared and the steel plate surrounding the LPCS containment isolation valve was remove IP memorandum J. F. Palchak to F. A. Spangenberg, dated September 16, 1986, documented the plant staff walkdown of all penetrations being closed with a metal plate in the Fuel Building and the initiation of temporary modification #86-284 for those plates that were still in plac Actions taken by the licensee to prevent recurrence include:
(1) the issuance of maintenance standing order (MS0)-028 which provided direction concerning activities which have a potential impact on component, system or plant operability, and (2) applicable Stone & Webster management and supervisory personnel were trained on " Quality of Work" as documented in S&W letter RPR-471-86, dated September 15, 198 At the conclusion of the report period, the inspector had not received the ' licensee's formal response to this violation. This item remains open pending receipt and review of the licensee's formal respons Two violations were identified.
3. Followup on Construction Deficiency Reports (92700) (0 pen) 10 CFR 50.55(e) item (461/86007-EE): Broken tack welds on Anchor Darling Globe Valve On August 28, 1986, the licensee reported a potentially reportable deficiency concerning broken tack welds on Anchor Darling globe valves. The specific valves reported were valves 1G33-F042A and F042B in the reactor water cleanup (RT) system. The adverse condition identified related to tack welds between the valve disc and disc nut which were found broken after 1G33-F042A had failed in service. The broken tack welds allowed the valve disc to disengage from the valve stem resulting in inoperability of the valv In addition, for valve 1G33-F042A, the valve stem retaining ring broke and had to be retrieved from the system pipin . - - _ - - - - . .. . _ -. -. . ._ . , _ -. - . _ - -
The licensee's preliminary analysis of this condition. indicated that the tack weld failure was caused by excessive vibration which occurred under extreme throttling conditions (i.e., valve throttled to less than 20% open).
The licensee performed a review to identify valves of similar design in use at CPS. Their review identified 60 valves in various plant
,
systems which may be susceptible to failure under extreme throttling conditions.
a The inspector met with the licensee on September 20, 1986, to review the status of the licensee's actions with regard to this potentially reportable deficiency and to determine what, if any, impact the
,
condition had on issuance of an operating license for CP l The licensee reported that General Electric Co. and Sargent and Lundy had both performed a single and common-mode failure analysis of the deficiency and its potential impact cn the plant. Their analysis indicated that there was no potential impact on plant operations prior to reactor initial criticality. However, 27 of the 60 valves that may be susceptible'to failure under extreme throttling conditions were required to operate to assure nuclear safety for one or more analyzed events after initial criticalit :
The affected systems inc.luded the control rod drive hydraulic system, residual heat removal system, low pressure core spray system, high pressure core spray system, and the main steam isolation valve leakage control syste The licensee stated that the two valves that had failed (1G33-F042A, B) had been repaired by welding the valve disc to disc nut using a 360 degree circumferential weld. Additional
,
review, evaluation, and analysis was required in order to determine the final corrective actions required for this l deficiency. The licensee s.tated that valves affected by the deficiency would be repaired prior to reactor initial criticality j
and that operating procedures would be changed, as necessary, to assure proper throttling operation of the affected valves.
, The inspector requested that the plant operators review the current i status of this item to determine the need for administrative l
t controls to preclude degradation of potentially affected valves until this deficiency has been corrected. The plant operators
- identified 18 valves for which caution tags were issued to preclude
, valve operation throttled less than 20% open in Tagout No.86-541 '
The inspector verified by direct observation and interview of
control room operators that the required tags had been hung and that the plant operators knew the purpose of the caution tag The licensee's analysis, evaluation, and the administrative controls implemented by the plant operators, provided a sufficient basis for conclusion that this deficiency did not restrain the issuance of a low power license for CPS. The need for administrative control over l
!
I
l
,
i
. . - . . _.- _ _ _ - -
the 18 potentially affected valves and the requirement to resolve this matter prior to initial reactor criticality was confirmed as'a condition of the operating license (License No. NPF-55, Condition C.(1), Attachment 1, item 2.d).
This matter will be. reviewed further in a subsequent inspection, (0 pen) 10 CFR 50.55(e) item (461/86006-EE): Floodproofing of the CPS Screenhous See paragraph 2.s. of this Inspection Report for detail This matter will bc reviewed further in a subsequent inspectio . Applicant Action on Three Mile Island (TMI) Action Plan Requirements (25401)
The NRC Office of Inspection and Enforcement issued Temporary Instruction (TI) 2514/01, revision 2, dated December 15, 1980, to supplement the Inspection and Enforcement Manual. The TI provides TMI-related inspection requirements for operating license applicants during the phase between pre-licensing and licensing for full power operation. It is divided into two parts. Part 1 lists requirements that must be closed prior to fuel load. Part 1 of the TI was used as the basis for inspection of the following TMI item found in NUREG-0737, " Clarification of TMI Action Plan Requirements."
(Closed) Item I.A.2.1: Immediate Upgrading of R0 and SR0 Training and Qualification. The licensee was to implement the requirements for Reactor Operator training and licensing detailed in the letter from H. R. Denton to all power reactor applicants, dated March 28, 198 As noted in the Clinton Power Station (CPS) Safety Evaluation Report (NUREG-0853), Illinois Power Company was an operating license applicant and, as such, was not subject to the one year experience requirement for cold-license SR0 candidates. Likewise, the requirement for three months onshift experience for control room operator and SR0 candidates as an extra person on shift was not required for the cold-license candidate License Condition 2.C.8 requires that Clinton shall have a licensed i senior operator on each shift who has had at least six months of hot i operating experience on a same type plant, including at least six weeks I
at power levels greater than 20% of full power. Illinois Power Company personnel meet this license conditio The inspector selected a sample of 20 recently licensed individuals and reviewed training records to determine if requirements for experience, training, and facility certification (items 1, 4 and 5 of I.A.2.1) were in accordance with the CPS Final Safety Analysis Report (FSAR), section 13.2. The inspector concluded that the training records reviewed met l the requirements as stated in section 13.2 of the FSAR.
I
.
'
The inspector reviewed the CPS Operator Training Program Description, dated January 2, 1986. Section 2.0, Operator Practices Training, defined
!
__ _ _ . _ __ _-
. -. _ _ _ - - - - . . .- -. - - - - . . _ _
requirements for Thermodynamics, Fluid Flow, and Heat Transfer (item 4 of I.A.2.1). The inspector's review of the CPS Nuclear Training Department's training session record for Lesson Plan #72915, dated July 23, 1986, confirmed the ongoing training conducted for these topic l The. inspectors review confirmed the licensee's compliance with TMI Action Plan Requirement I.A.2.1. This item is close . 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 perio No violations or deviations were identifie . Functional or Program Areas Inspected Site Surveillance Tours (71302/60501)
Surveillance tours of selected areas of the site were performed
-
at periodic intervals throughout the report period. Those surveillances were intended to assess: cleanliness of the site; storage and maintenance conditions of plant equipment and material; potential for fire or other hazards which might have a deleterious effect on personnel or equipment; storage conditions of new fuel; and to witness maintenance and'preoperational activities in progres (1) New Fuel Storage
- Several random tours of the new fuel storage area identified no deviations from the special nuclear materials license requirements for security, fire protection, and environmental controls for new fuel storag (2) Housekeeping and Cleanliness Control During frequent tours of the facility throughout the inspection period, the inspectors observed actions taken by the licensee to continue to upgrade and maintain general plant housekeeping
- and cleanlines The licensee completed a thorough walkdown/sweepdown/wipedown of the dr3vell on September 20, 1986. That action resulted in a substantial improvement in overall drywell cleanlines Except as discussed in paragraph (3) below, the inspectors identified only minor housekeeping deficiencies during the inspection period; each was promptly corrected by the license ._ __ _ _ . _ _ _ ___ _ ._ , _ _ _ _ -
_ . _ _ _ _ _ . _ _ _ . . . = . _ . . . - - _ . .
Some specific plant areas, such as the lower elevations of the control and diesel generator buildings, were still in need of attention in order to achieve a level of cleanliness equivalent to that established in other plant areas. The licensee acknowledged the need for painting and additional cleaning in those area The inspectors will continue to monitor the licensee's activities in this area.
l (3) Personnel Access and Material Control - Upper Containment Pools The licensee designated a portion of the refueling floor (elevation 828' containment building) and the upper containment pools (steam dryer and steam separator pits, the reactor cavity, and the inclined fuel transfer tube pit) as cleanliness Zone II. CPS No. 1019.01, Housekeeping and Cleanliness Control, paragraph 8.1.1_ states"
" Cleanliness requirements for hou::ekeeping activities shall be established on the basis of the following zone designations ,
(see Table 1)."
Table 1 identifies that four restrictions apply for cleanliness Zone II, as follows:
(a) Clean gloves, shoe covers, head covering (b) Material accountability (c) Personnel accountability (d) No use of tobacco or eating CPS No. 1019.01, paragraph 8.1.2 states:
"For Zones I, II, and III a written record of the entry and exit of all personnel and material shall be established and maintained. Appropriate additional control measures shall be provided through utilization of such items as tethered tool This record shall become a part of the work package."
CPS No. 1019.01, paragraph 8.2.1, Control of Facilities, states in part,
"Where large accumulations of material occur on a nonroutine basis, the material shall be promptly removed or stored neatly.
'
Oily rags, paint rags, and oil mops shall be disposed in suitable waste cans with tightly closing covers. Personnel
! working in an area are responsible for maintaining the cleanliness of that area."
Plant Manager's Standing Order (PMS0)-023 was issued by the licensee to provide instruction to personnel to implement the above requirement . . . - . --- -- ___._._- - _ _ - , . - -
- . - - -
, On September 26, 1986, at 6:30 a.m., the inspector identified numerous violations of the above requirements during observation of preparations for fuel handling on the 828'
elevation of the containment building. The area had been previously designated cleanliness zone II to protect the open reactor vessel and new fuel to be stored in the are Violations observed included failure of personnel to wear required clothing (head covers, shoe covers, and/or gloves);
failure to use lanyards to tie off small tools and equipment; personnel wearing personal items (jewelry, watches, rings, and similar items); failure to restrain dosimetry being worn in the area; and inadequate implementation of the tool and material control log such that there was no direct verification that items taken into the controlled area had been remove In addition, the inspector noted large accumulations of tools, equipment, protective clothing, and similar items that were not l -
well controlled or neatly stored, as required. These examples of violations of 10 CFR 50, Appendix B, Criterion V (failure to follow procedures for personnel access and material control)~
were brought to the attention of the Manager - CPS at 6:55 that date. He immediately directed personnel take corrective actions. This is a violation (461/86060-03B).
IP QA verification of corrective actions was documented in surveillance report Q-07850 dated September 29, 1986. That surveillance report ir.dicated that the violations observed by the inspector had been correcte On September 29, 1986, the inspector toured the 828' elevation of the containment building and verified that personnel and material accountability was being controlled in accordance with the applicable procedures. In addition, the accumulated tools, equipment and protective clothing, and similar items had been either removed or neatly stored in the work area. This observation was sufficient to indicate that the violation had been corrected. The resident inspectors will continue to i monitor the licensee's activities in this are One~ violation was identified.
! b. Emergency Procedures Review (42452)
This inspection continued a review (reference Inspection Reports 50-461/86048, paragraph 6.c and 50-461/86054, paragraph 5.b) 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 l indicated.
't i
i
. - - -- .. __ _ _ . . -. . -_
(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 Pequirements 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 (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, resision 3, dated February 6,198 (d) CPS No. 4301.01, Earthquake, revision 3, dated March 3, 198 (e) CPS No. 4303.02, Abnormal Lake Level, revision 0, dated March 3, 1986.
(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 (a) The inspector reviewed the scope of the procedures available in the applicant's operating manual against the requirements and recommendations of Regulatory Guide 1.33, Appendix A, and the CPS FSAR. The applicant had prepared a sufficient number of procedures to address the applicable requirement The inspector reviewed the format of the CPS Off-Normal procedures and found that, with one exception, the procedures were in the required format. One procedure, CPS No. 4969.01, Chlorine Leak Response, was identified by the CPS FSAR, Table 13.5-5, as an Emergency Off-Normal procedure. The inspector observed that this procedure was not in the format prescribed for Emergency Off-Normal procedures. The applicant stated that the procedure was
not intended to be an Emergency Off-Normal procedure and was in the correct format. An FSAR change was initiated to correct the erroneous information. This action was sufficient to correct the identified deficienc (b) Review of the procedures identified in (2)(a)-(2)(d) above identified only one discrepancy which was resolved during the course of the inspection. That discrepancy related to the identification of " symptoms" in paragraph 1 of the Reactor Scram procedure. Each of the procedures reviewed, except as previously noted, were in compliance with the requirements noted above and appeared technically adequate to accomplish its stated purpos Review of the procedure identified in (2)(e)'above was documented in Inspection Report 50-461/8605 (4) Results Based on the above, the inspector concluded that the applicant's program for preparation, reviev:, and approval of Off-Normal Procedures was adequately implemented to provide procedures to control safety-related functions when a system or component malfunction is indicate Review of the' CPS Emergency Off-Normal procedures will be completed prior to initial criticality.
c. Onsite Review Commi.ttee 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 minutes are as follews:
86-141 through 86-149 86-151,86-164, 85-155 These reviews included verification of FRG membership, availability of meeting quorum, and verification that the FRG was meeting its charte No violations or deviations were identified, d. Operational Safety Verification (71707)
This inspection was conducted in two parts; the first part was performed prior to issuance of the operating license to assure readiness of the plant operations department to load fuel; the second part was performed after issuance of the operating license in order to verify that operating activities were conducted within the limits of the operating licens . _ -- ___
,
(1) Prior To Operating License Issuance The inspectors performed a detailed walkdown of the 'B' train of the residual heat removal (RH) system (major system valves, components, breakers, switches, and instrumentation) to verify that the system was aligned in accordance with the system operating procedure; verified that work activities in progress in the plant were being controlled by the shift supervisor; verified that the control room was manned in accordance with technical specification requirements; observed the conduct of shift turnover activities in accordance with the applicable procedure; reviewed administrative controls for the-RH system and verified that the current system status was known to the plant operators (including the safety tag log, the temporary modification log, the outstanding radiation work permit log, the maintenance work request log, the system status file, the master surveillance schedule, the component abnormal configuration log, the limiting conditions for operation (LCO)
log, and the main control room journal); and verified that the shift supervisor had control over sensitive keys (standby liquid control keylock switch keys and the key for the communications. equipment box at the remote shutdown panel).
The inspector noted that the temporary modification log had not been audited by the operations department as required. This condition had previously been observed by the NRC (see Inspection Report 50-461/86054, paragraph 6.c). During that inspection, the licensee stated that the required audit was scheduled for the week of August 18, 1986. The Assistant Supervisor - Plant Operations directed operations department personnel to perform the audit which was completed on September 25, 1986. The inspector will continue to monitor the licensee's performance in this are The inspectors observed the conduct of the shift crew in the main control room and observed the performance of routine surveillance activities. No discrepancies were noted. The shift crew's conduct and performance was appropriate for plant condition The inspectors observed the condition of control room panel internals and discussed questior.s with the control room supervisor. Two discrepancies were noted as follows:
(a) Inside panel IH13-P877 (the division I and II diesel generator control panel) the inspectors found cover plates for several isolated sections of the panel wiring to be
,
removed and lying in the bottom of the pane _ -. . _ . _ .
- __ __ - . , . _ _ _ _ . - _ _ _ _ -
_ .
.
<
(b) Inside panel IH13-P877, a small amount of insulation material (debris) was lying in the bottom of the pane These discrepancies were promptly. corrected by the shift cre The inspector noted that the shift crew inspected-all other
.'
control room panels for similar. discrepancies with no additional discrepancies identified. The action of the shift crew was sufficient to correct the minor discrepancies
- identified by the inspecto On September 29, 1986, the inspector reviewed the status of plant systems and LCOs with the Director - Plant Operation All systems required for fuel load had been declared operable under the CPS final draft technical specifications with five outstanding LCOs. Several of the LCOs were self-imposed (i.e.,
diesel generator control switch in " maintenance" position and ECCS punp breakers racked out to prevent inadvertent pump actuation) and were cleared to support operation in Mode 5 (initial fuel load). No restraints to issuance of an operating license were noted. The inspector notified NRC Region III at 8:15 a.m. on September 29, 1986 that CPS was ready to receive a low power operating licens (2) Post Operating License Issuance The inspectors observed control room operation, reviewed applicable' logs, and conducted discussions with control room operators during the inspection perio The inspectors verified the operability of selected emergency systems, reviewed control room logs, and verified tracking of LCOs. Routine tours of the_ auxiliary, fuel, containment, control, diesel generator and turbine buildings and the screenhouse were conducted to observe plant equipment conditions including potential for fire hazards, fluid leaks, and operating conditions (i.e., vibration, process parameters, operating temperatures, etc). The inspectors verified that maintenance requests had been initiated for discrepant conditions observe The inspectors verified by direct observation and discussion with plant personnel that the physical security plan and radiation protection (RP) ccntrols were being properly implemented. Several minor discrepancies concerning the implementation of RP controls were discussed with the Director - Radiation Protection.
l .The inspectors observed plant housekeeping / cleanliness conditions. No discrepancies were note . . .. -
- - - _ _ - - - _ . .. _ ...-_- -- . - -
The above reviews and observations were accomplished to verify that facility operations were conducted in conformance with the CPS technical specifications and the conditions of the operating licens No violations or deviations were identified.
e. Startup Test Witnessing And Observation (72302/72524)
The inspectors witnessed the conduct of portions of the following startup test procedures to ascertain through direct observation and record review that startup testing was performed in accordance with approved procedures and requirements of the CPS operating license:
(1) STP-03, Initial Fuel Loading Witnessing (72524)
(a) Purpose The inspectors witnessed initial fuel loading activities being performed by the licensee in accordance with test procedure STP-02-0, Fuel Load. For the portions of the test and fuel load activities witnessed, the inspectors verified the Clinton Power Station (CPS) Technical Specification requirements and license conditions were met; the nuclear instrumentation was calibrated and operating with a measurable count rate; prerequisites and initial conditions were met; staffing requirements and communications were in accordance with Technical Specifications; proper procedures were in use and being-followed; 1/M plots were maintained in accordance with the procedure; shutdown margin and control blade operability were verified at required frequencies; shift turnovers were conducted; control of personnel access to refuel floors was adequate; refuel status boards were maintained; personnel at each refuel station understood responsi-bilities; overtime limits were observed; " master" copy of procedure STP-03-0 was maintained; changes to fuel load procedures were technically adequate and in accordance with approved CPS procedures; corrective actions for deficiencies or problems were adequate; data sheet entries were legible, traceable and permanent; and reviewed control room log to assure pr_oblems or deviations from the fuel load procedure were adequately documente (b) Discussion At approximately 2:00 p.m. on September 29, 1986, Illinois Power Company was issued Facility Operating License N NPF-55 for Clinton Power Station. The licensee declared operational mode 5 and commenced initial fuel loading activities at approximately 2:30 p.m. on September 29, 1986. At the conclusion of the report period, the
-_ . - , .
licensee had completed loading one-third (208 of 624 fuel bundles) of the initial core ~ load. The inspectors had monitored the fuel loading activities on essentially a continuous basis during the first one-third core loa (c) Results The inspectors noted that all fuel loading activities were being controlled in accordance with the plant Technical Specifications and the governing procedures; CPS No. 3007.02, Preparation For and Recovery From Refueling Operations For Initial Fuel Load; and startup phase test procedure STP-03-0, Fuel Load. The inspector noted that the Shift Supervisor and other personnel directly responsible for fuel load activities adhered to procedural requirements and halted core alterations whenever the procedures or Technical Specifications required a halt in core alteration One particular item of interest occurred on October 4, 1986, when two fuel bundles of the wrong enrichment were placed into the reactor. The 141st and 142nd bundles loaded into the reactor were not the required high enrichment types. An error was made by the Nuclear Engineer on shift who had erroneously specified the lower enrichment type. The licensee (Nuclear Engineer)
identified the error after placement of the 142nd bundle and suspended core alterations. The licensee wrote Condition Report 1-86-10-054 and corrected the error by removal of the incorrect fuel bundles and replacenent with the correct type. In addition, the licensee reverified by direct visual inspection that all fuel bundles in the reactor were in the proper location and of the proper enrichment before resuming core alterations. The inspector concluded that the licensee had self-identified this error; the licensee took immediate corrective action and took immediate measures to prevent recurrence (i.e.,
the Shift Test Engineer reviewed subsequent fuel movement checklists prepared by the onshift Nuclear Engineer);
l the error fits into a Severity Level IV or V violation; it was not a reportable event; it was not a violation that could have been prevented by' corrective action to a previous violation. Based on the above, the inspector determined a notice of violation for this procedure violation was not warrante Upon completion of loading the 144th bundle, the licensee conducted a Partial Core Shutdown Margin Test in accordance with STP-03-0, Section 7.2. The purpose of the partial core shutdown margin test was to demonstrate that the core was subcritical by at least 0.38% delta K/K with the core loaded and with the analytically determined
-_ - - - _ - - . _
highest worth rod fully withdrawn. After partial loading of the core with 144 fuel bundles, nine control rods were withdrawn to demonstrate subcriticality. The inspector verified the' procedure in use was the most recent revision; that the shift crew was knowledgeable of the test requirements; recording and evaluation of test data was in accordance with the procedure after each of the
~ nine control rods were individually notched out to their fully withdrawn position (notch 48). Results of the Partial Core Shutdown Margin Test met the established acceptance criteria and the licensee continued with initial fuel loadin (2) STP-05-0, Control Rod Drive System Test Witnessing (72302)
The inspectors witnessed portions of procedure step 7.1, Individual CRD Functional Tests, performed in conjunction with STP-03. For the portion of the test witnessed, the inspector verified that the procedure in use was the most recent revision; that the test crew was adequate, knowledgeable of the test. requirements, and observed the requirements of the procedure; that test data was recorded as required using calibrated test equipment; and that prelimi. nary test results were evaluated against appropriate acceptance standards. The inspector observed that coordination between the two tests (STP-03 and STP-05-0) was good and that the interface with the control room operators was well established and properly controlle No violations or deviations were identifie . Onsite Followup of Events at Operating Reactors (93702) General The inspector performed onsite followup activities for events which occurred during tha *u pection period after issuance of the low power operating lie.nse on September 29, 198 Followup inspection included reviews of operating logs, procedures, condition reports, direct observation of licensee actions, and interviews of licensee
- personnel. For each event, the inspector reviewed the sequence of actions, reviewed the functioning of safety systems required by plant conditions, reviewed licensee actions to verify consistency with plant procedures and license conditions, and verified the nature of the event. Additionally, where possible, the inspector verified that licensee investigation had identified root causes of equipment malfunctions and/or personnel errors and were taking or had taken appropriate corrective actions. Details of the events and licensee corrective actions noted during the inspector's followup are provided in paragraph b. belo .. . - _ - . .- _ - . _ . .- -. _ _ _ - . . _ _ _ _ - . . . - Details (1) Reactor Water Cleanup System Isolation (No. 6394).
At about 8:15 a.m. on September 30, 1986, while operating in mode 5 (initial fuel loading), the reactor water cleanup (RT)'
system isolated due to a " Pump Room C High Temperature" signa The licensee investigated the cause and determined that the isolation was not due to an actual high temperature conditio The RT system was subsequently returned to service and a maintenance work request (No. C-28021) was initiated to trouble shoot the proble The licensee notified the NRC Operations Center of above event via the Emergency Notification System (ENS) at 9:50 a.m. A Condition Report (CR) No. 1-86-09-233 and Licensee Event Report (LER) No. 86-001-00 were initiated to document the investigation and to provide appropriate reporting of the event. The licensee's investigation was still in progress at the completion of the inspection. The LER will be reviewed when it is issue (2) Control Room Ventilation Shift to Chlorine Mode (Nos. 6398 and 6430).
At about 3:00 p.m. on September 30, 1986, while operating in made 5 (initial fuel loading), the control room ventilation (VC) system automatically shifted to the chlorine protection mode. The shift was caused by the failure of a chlorine detector cartridge tape. At the time of the event, the VC system was not required to be operable by the plant technical specification The licensee notified the NRC Emergency Operations Center of the above event via the ENS at 6:49 p.m. CR No. 1-86-10-004 and LER No. 86-003-00 were initiated by.the licensee. The licensee replaced the broken chlorine tape and returned the VC system to its normal operating mod This event was repeated at about 9:50 a.m. on October 2, 198 The inspector verified that appropriate reporting and immediate corrective' actions were carried out. The licensee was investigating the cause of the broken detector tapes to determine the need'for generic corrective action to prevent recurrence. The LER will be reviewed when it is issue (3) Temporary Loss of Secondary Containment Integrity (No. 6399)
At approximately 5:00 p.m. on September 30, 1986, while operating in mode 5 (initial fuel loading), secondary containment integrity (as indicated by a negative secondary containment pressure on control room instruments) was los Core alterations were suspended in accordance with the plant technical specifications. Prompt investigation by the plant operators indicated that the loss of secondary containment integrity was caused by several contractor craftsmen who had overridden an interlock on two airlock doors arc propped both doors open simultaneously to remove scaffolding from secondary containment. The plant operators promptly restored the airlock doors to their normal condition and verified the reestablishment of secondary containmen The unauthorized actions of the craftsmen resulted in termination of their enployment. In addition, the event was discussed in departmental meetings and during shift briefings to assure that all personnel understood the event, its cause, and the potential consequences of unauthorized override /
operation of plant design features. The resident inspector attended two of the shift briefings and one of the departmental meetings to verify the licensee's corrective action The licensee notified the NRC Emergency Operations Center of
,
'
the above event via the ENS at 5:40 p.m. CR No. 1-86-10-001 and LER No. 86-002-00 were initiated by the licensee. The LER will be reviewed when it is issue '
(4) Standby Gas Treatment System Actuation Due to High Radiation Signal (No. 6413).
At approximately 6:15 p.m. on October 1,1986, while operating in mode 5 (initial fuel loading), both trains of the Standby Gas Treatment (VG) system actuated in response to a high radiation signal from the containment fuel transfer vent plenum radiation monitor. The resident inspector observed the plant operators' response to this event in the CPS control roo The licensee suspended core alterations. The VG system was operated in accordance with the applicable procedures. The licensee's prompt investigation revealed that no radiation levels existed and that the VG actuation was caused by surveillance testin Further investigation-by the licensee indicated that an actuation sipral to the VG existed prior to commencement of the surveillance test (channel functional test) even though the control room annunciators had cleared. The surveillance testing activities resulted in the initiation of a second actuating signal which caused VG to start. This matter was still under review by the licensee at the cor.clusion of the inspection.
The licensee notified the NRC Emergency Operations Center of the above event via the ENS at 7:30 p.m. CR No. 1-86-10-007 and LER No. 86-004-00 were initiated by the licensee. As an interim measure pending completion of their investigation of
.-- - _ _ - _ _ . -_ - .. _ _ . -.-, .. - . . _ . - . _ _ _ _ .-_
this event, the licensee initiated a checklist to be performed for each surveillance test to assure that the potential implicatfonsofthetestperformanceforplantoperating conditiops are clearly understood and to assure that actuating logics are reset before and after test performance. Briefings were provided for operations, maintenance, and radiation protection department personnel to advise them of the event and the interim measures to be taken to prevent recurrence. The licensee was considering the need for hardware modifications to provide annunciation in the control room whenever the actuating logic is trippe The licensee's investigation was still in pragress at the conclusion of the inspection. The LER will be reviewed when J it is issue No violations or deviations were identifie . 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. One open item disclosed during the inspection was discussed in paragraph . Exit Meetings (10703)
)
The. inspector met with applicant representatives (denoted in paragraph 1)
throughout the inspection and at the conclusion of the inspection on inspection activities. The applicant acknowledged the inspection findings and the inspector's suggestion The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during.the inspection. The applicant did not identify any i such documents / processes as proprietar The resident inspectors attended exit meetings held between Region III based inspectors and the applicant as follows:
Inspector (s). Date Wohld, DuPont, Hasse 9/12/86 Ulie 9/18/86
!
.- -. - ---. .. ---. - -- ... - - - - - - - -