IR 05000461/1987010
| ML20147C525 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/27/1988 |
| From: | Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20147C476 | List: |
| References | |
| 50-461-87-10, NUDOCS 8803030101 | |
| Download: ML20147C525 (23) | |
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U. S. NUCLEAR REGULATORY COMMISSION.-
REGION III.
-1 ReportNo.!50-461/87010(DRP)
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. Docket No.' 50-461 License-No-NPF-55-
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Licensee:
Illinois Power Company 500 South 27th Street Decatur; IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Conducted:
March 2 through March 7, 1987, March 30'through April 2, 1987, and~ February 7-17, 1988 Inspectors:
J. M. Hinds 8. H. Little R. A. Kopriva J. S. Wiebe H. A. Walker M. P. Huber M. L. McCormick-Barger R. M. Lerch w
Approved By:
W.
orney, e
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Reactor Projects Branch 1 Date Inspection Sumary Inspection on March 2 throug_h March 7, 1987, and March 30 through April 2, 1987, and a followup inspection' os Febriiaiy 7-17,~1988, (Report No.
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50-461/87010(DRP))
Areas Inspected: Special announced team inspection by Region III supervision, resident, and region based inspectors to perform a pre-full power license operational readiness inspection of the Clinton plant. Areas reviewed included: operations, surveillance testing, maintenance, LERs, radiation controls, chemistry controls, nuclear engineer activities, training, employee adverse work actions and allegation review.
In addition to the above review, an inspection of the licensee's Operational Quality Assurance Program was conducted during December 1986, and January 1987, as documented in Inspection Report (50-461/86076(DRS)). The Operational Quality Assurance Program inspection is considered a part of this pre-full power license operational readiness inspection.
Results: Within the contents of this inspection report there are several areas in which the licensee did not meet regulatory recuiteuents but no notice of violation (NOV) was issued because NRC management wanted the licensee to concentrate on correction of program weaknesses rather than NOVs.
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DETAILS
'1.
. Personnel Contacted Illinois Power Company (IP)
x+$**#K. Baker, Supervisor I&E Interface x$*#R. Campbell, Manager - QA -
- W. Conn' ell, Manager - Nuclear Planning & Support x$ *#J. Cook, Assistant Plant Manager
- E. Corrigan, Director - Quality Engineering & Verification xC$ *#D. Hall, Vice President, Nuclear-
$ *#D. Hillyer, Director - Radiation Protection
$**#W. Mullins, Supervisor - Chemistry
$**#J. Perry, Manager - Nuclear Program Coordination
- R. Richey,. Director - Plant Maintenance
$*#R. Schaller, Assistant Manager'- POPS
$*#R. Schultz,-Director - Planning & Programming
- E. Schweitzer, Supervisor - Nuclear
- J. Taylor, Supervisor - Nuclear Records
- E. Till, Director - Nuclear Training x$*#J. Weaver, Director - Licensing
$ *J. Greenwood, Manager - Power Supply Soyland/WIPCV x$ *T. Camilleri, Acting Manager - SOM x$*J. Wilson, Plant Manager, Clinton x$*R. Freeman, Assistant Plant Manager - Maintenance
$*D. Sykes, Supervisor - RW
- E. Bush, Director, Nuclear Program Scheduling
$*J. Palchak, Supervisor, Plant Support Service
- K. Graf, Director, Operations Monitoring 5 R. Wyatt, Director, NPAG x$*R. Spangenberg, Manger, Licensing and Safety D. Antonelli,. Supervision, Operations Training
- J. Hays, Assistant Supervisor, Operations c$W. Kelley, President and Chairman of the Board C$W. Gerstner, Executive Vice President
$W. Connor, Manger, NSED
$D. Holesinger, AIM, Startup x5J. Miller, Assistant Manager, NSED CSG. Edger, Attorney
$W. Baer, Attorney
$P. Telthorst, Supervisor, Licensing Operations Nuclear Regulatory Commission - Region III CC. Norelius, Director, Division of Reactor Projects, RIII
- E. Greenman, Deputy Director, Division of Reactor Projects, RIII CR F. Warnick, Chief, Reactor Projects Branch 1 CR. C. Knop, Chief, Reactor Projects Section IB cs**#W. Forney, Chief, Reactor Projects Section 1A, Region III
$6*#J. Hinds, Senior Resident Inspector, Byron
$ *#J. Wiebe, Senior Resident Inspector, Duane Arnold
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$#R. Kopriva, Resident Inspector, LaSalle o-5**#H. Walker, Reactor Inspector, DRS, Region III
- M. Huber,-Reactor Inspector, DRS, Region III xc5 *#P. Hiland, Senior Resident Inspector, Clinton C+M. McCormick-Barger, Project Inspector, Region III R. Lerch, Project Inspector, Region III.
$ N. Dasic, Yugoslavian Institute of Nuclear Sciences
$*B. Little, Senior Resident Inspector, Callaway CSA..B. Davis, Acting Regional Administrator, RIII-
$J. Sniezek, Deputy Director, Office of Nuclear Reactor Regulation c$R. Bernero, Director, Division of BWR Licensing
$D. Muller, Director, BWR Project Directorate No. 2'
c5B. Siegel, Clinton Licensing Project Manager, NRR cJ. Partlow, Director, Division of Reactor Inspection & Safeguards
- Denotes those attending the entrance meeting on March 2, 1987.
- Denotes those attending the exit meeting on March 6, 1987.
c Denotes those attending the management meeting on March 13, 1987.
+ Denotes those on a telephone conference call March 13, 1987.
Denotes those attending the entrance. meeting on March 30, 1987.
$ Denotes those attending the exit meeting on April 2, 1987.
x Denotes those attending the exit meeting on February 17, 1988.
The inspectors also contacted and interviewed other licensee and contractor personnel.
2.
General The team inspection was conducted to help determine whether or not the Illinois Power Company should receive a recommendation from Region III to proceed beyond 5% reactor power.
Licensee activities were closely monitored to ensure the facility was being operated safely and to ascertain the licensee's readiness to operate at power levels up to 100%. The inspection included examination of the interface between the operations department and other on-site organizations to assess the effectiveness of the entire station organization.
The team consisted of the leader who was a Section Chief in the Division of Reactor Projects, three Senior Resident Inspectors from other operating reactor facilities in Region III, a Resident Inspector from another operating reactor facility in Region III, and two regional based inspectors.
During the inspection performed March 2 through March 7, 1987, the team identified areas of strength and weakness.
The areas of strength were (1) the performance of licensed and non-licensed personnel. Particular strengths in this area were knowledge level, adherence to operating procedures, response to off-normal conditions, control room decorum, and interdepartmental communications and (2) the technical knowledge of Radiation Protection Technicians and Chemists.
The areas of weakness were (1) administrative procedure adherence,
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(2)_ failure of the Quality Assurance Department to identify areas of weakness, (3) excessive backlog of overdue preventive maintenance program items, (4) the size of the corrective maintenance backlog, (5) use of daily activity schedule, (6) coordination and management of the Prever-tive Maintenance / Surveillance / Maintenance Work Request activities, (7)
overall knowledge and experience level of Nuclear Engineers, (8)
communication of management policies and direction down through the ranks, (9) in plant training for Contractor Radiation Protection Technicians, (10) activity level in the control room, and (11) excessive number of out-of-service annunciators in the control room.
Based on these areas of weakness the' licensee committed during a management meeting.in the Region III office, Glen Ellyn, Illinois on March 13, 1987, to initiate corrective actions to resolve the weaknesses before a full power license would be recommended by the Regional Office.
During the inspection performed March 30 through April 2, 1987, the team reviewed licensee actions initiated or completed to resolve the weaknesses.
The team identified the need for additional management emphasis in the areas of (1) procedure adherence to administrative procedures, (2)
management of the Preventive Maintenance / Maintenance / Surveillance programs, (3) control room decorum, (4) reducing the backlog of maintenance, (5)
excessive use of Administrative Practice procedures for areas that may involve safety related activities.
The team identified positive trends in the areas of (1) team work, (2)
Quality Assurance Department involvement, (3) preventive maintenance program, (4) use of the daily activities schedule, (5) Preventive Maintenance / Surveillance / Maintenance Work Request coordination and management, (6) in plant training for Radiation Protection Technicians, (7) out-of-service annunciators in the control room, and (8) the Licensee Event Report Evaluation Program.
The team concluded during this phase of the Operational Readiness Inspection that the licensee had initiated or completed actions to resolve the weaknesses, and the team no longer had concerns about the licensee's ability to safely operate the Clinton plant during full power operations.
3.
Operational Safety Verification and Engineered Safety Feature Walkdown (71707, 71715, 72701)
a.
During the period March 2-7, 1987, the inspectors observed control room operation, reviewed applicable logs and conducted discussions with control room operators.
During these discussions and observa-tions, the inspectors ascertained that the operators were alert, cognizant of plant conditions, attentive to changes in those conditions, and took prompt action when appropriate.
The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components.
Tours of the auxiliary, turbine, and rad-waste buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations, and to verify that maintenance requests had been initiated for equipment in need of maintenance.
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The inspectors verified by observation and direct interviews that the physical security plan was being implemented in accordance with the station security plan.
Facility operations observed were verified to be in accordance with the requirements established under Technical Specifications, 10 CFR, and administrative procedures.
The inspectors reviewed the administrative procedures governing the conduct of operations.
No major deficiencies were found, however some concerns-were identified.
Operators performed inspections and tours according to the following procedures:
CPS No. 1005.07 Temporary Changes to Stai. ion Procedures CPS No. 1401.01 Conduct of Operations CPS No. 3800.02 Unit Attendant Daily Logs CPS No. 9000.01 Control Room Operator Surveillance Log CPS No. 9000.02 Unit Attendant Surveillance Log The transfer of plant status turnover information was done according to CPS No. 1401.01,F002, Shift Turnover and Relief - Status Report.
The plant parameters identified in the procedures were either recorded or checked and determined to be acceptable or unacceptable. Non-conformances were identified in the methodology of identifying data that did not meet the specified acceptance range criteria for the existing systems condition. CPS No. 1401.01 item 8.4.4.7 requires that recorded data, not meeting the acceptance criteria, be red circled and the reason for the unsatisfactory data be recorded in the comments section of the applicable document, Contrary to this requirement, virtually all of the unsatisfactory data recorded in the documents reviewed, were not red circled nor were the reasons identified.
Erroneous entries, whether clerical or technical in nature, entered in the logs, records, and checklists that were subsequently corrected, were not corrected in accordance with CPS No. 1401.01 item 8.4.4.3.
The errors were crossed out with a single line, but none of the corrections, in the documents reviewed, indicated the time of the correction as required by procedure.
These concerns were identified to the licensee and the senior resident inspector. A followup inspection of these concerns was conducted during the week of February 7, 1988. The inspector reviewed the previous three months of operating shift records to ascertain if the licensee had taken corrective action.
The following records were reviewed:
CPS No.1401.01F002, Shift Turnover and Relief-Status Report CPS No.9000.010001, Control Room Operator Surveillance Log-Mode 1, 2, 3 Data Sheet CPS No. 9000.01D002, Control Room Operator Surveillance Log-Mode 4, S Data Sheet CPS No. 9000.020001, Unit Attendant Surveillance Log Data Sheet
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In addition to the above record review, the inspector had conducted daily reviews of control room logs and records as part of the routine Operational Safety Verification (71707)
The inspector noted general compliance with CPS No. 1401.01 in that data identified as' not meeting the acceptance criteria was circled in red and the reasons noted.
Errors were corrected properly in almost all cases although a few corrections lacked the date and several lacked the time.
Based on the followup inspection,_the inspector concluded that the licensee had adequately addressed the Concern.
Surveillance procedures submitted for revision were reviewed and it was determined that the review process was completed according to CPS No. 1005.07 with all necessary approvals obtained.
(1) Adequacy of Shift Turnovers Pre-shift briefings were monitored on all 3 shifts by the team resident inspectors.
It was determined that the crew briefings were informal, provided required information, covered plant status, discussed plant problems and reviewed shift plans.
It was noted, however, that the Shift Supervisors elected to use multiple pages of hand written notes during shift briefings and turnovers in lieu of Clinton Power Station (CPS) No.
1401.01F005, Shift Supervisor Relief / Briefing Form as provided for in CPS 1401.01, Conduct of Operations, 8.4.3.3.
This concern was identified to the licensee.
Followup inspections performed by the Clinton Senior Resident Inspector noted that
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the licensee had taken action in response to this concern. A licensee review of the shift turnover process determined that the Shift Supervisors' Relief Form (1401.01F005) was not required to convey the plant status to the oncoming shift (i.e.
it duplicated information being provided). CPS No. 1401.01 was revised and paragraph 8.4.3.3 required the Shift Supervisors'
Journal to be the means of communicating to the relief Shift Supervisor the plant status.
Routine observations by the resident inspectors indicated that relief Shift Supervisors were informed of current plant status by using the Shift Supervisors' Journal.
In addition, the inspector noted that oncoming shift briefings have been conducted by the Shift Supervisor using the "Master" daily activity schedule to l
convey plant status and planned evolutions.
Based on the followup inspections performed, the inspector concluded that the licensee had adequately addressed the concern.
Operator turnovers were, for the most part, very good including detailed panel walkdowns, log reviews and operator discussions.
An area of weakness was, however, identified as operator interruptions during turnover.
Improvements can be made by prohibiting any form of interruption during operator turnover discussions from personnel such as middle managers, status
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keepers,' log reviewers, work schedulers and planners, etc.
The control room horseshoe area'should be inviolate during
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shift. change.
Overall,-the pre-shift briefings and. turnovers conducted by shift. supervisors were evaluated as tentative and weak, appear schedule oriented (vice operations), and demonstrate the lack of command and direction required from'the operating staff for adequate start *Jp testing and Critical operations.
(2) Attentiveness to Indication The inspectors monitored the Control Room Operators (CRO)
attention to indication on all shifts. Changes to plant conditions, controls, and indications were closely monitored by the CR0s and Line Assistant Shift Supervisors (LASS) in a highly professional manner appropriate to the current evolution in progress.. CR0 and LASS responses to alarms were considered excellent and the operators followed applicable procedures and took appropriate action for all off-nomal situations encountered.
It was noted, however, that the high number of nuisance alarms illuminated on the control panels required extra operator effort in responding to alarms.
(3) Communication between Operators Comunications were observed during shift briefings and turn-overs; routine control room operations; performance of surveillances; and balance-of-plant operations and evaluations including plant tours. The inspectors noted good comunication practices and skills between the operators in the performance of their assigned duties.
During 9080.01 Monthly Surveillances
- Diesel Generator 1A(IB) Operability - Manual, the crew-experienced a problem with the governor oil level for cylinder 12. The LASS contacted the Mechanical Maintenance Department (MMD) for assistance to resolve the problem. The MMD response was prompt and effective in providing the necessary assistance to continue the surveillances.
(4) Awareness of Plant Status Operators, both in and out of the control room, demonstrated l
an adequate level of awareness of plant status on all shifts l
observed. CR0s and LASSs demonstrated a good knowledge of
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system problems, technical specification requirements and I
integration of plant conditions with scheduled upcoming events.
(5) Procedural Compliance Overall, procedure compliance was determined to be adequate.
The operators demonstrated a good knowledge and proficiency in the use of operating procedures during both nomal and
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' unplanned events.: During an off-normal event. related to a Rod 44-13 Accumulator Low condition, the operator evaluated the alarm,'made prompt notification to the LASS, and proceeded with immediate and followup corrective actions as specified
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.in the applicable procedures. With the exceptions of. thel concerns identified in previous paragraphs related-to log keeping and turnover reports, procedure compliance was
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acceptable.
(6) Control Room Congestion The inspectors detennined that traffic in the control room.
horseshoe area, for the most part, was too busy.
Excessive numbers of people were in and out, conducting business and comunicating with operators in a manner which the inspectors determined could be accomplished by other means and without distracting the CR0s. Exclusion signs were posted at two of the entrances to the control panel areas.
The inspectors observed a number of unauthorized personnel making ingress and egress via these passages in violation of the signs.
Improvements can be made in the access control to reduce the command atmosphere of the "at-the-controls" areas. A need exists to establish an inviolate atmosphere 100% of the time in the areas critical to reactor plant control to improve operator effectiveness and reactor plant operations.
(7) Completeness and Accuracy of Logs The inspectors determined that, with the exceptions noted previously, the log keeping on the part of CR0s, LASSs, Unit Attendants, and Auxiliary Operators, was good. Logs contained the required detail of entry, complied with required formats, provided sufficiently detailed narratives and were, in general, good logs.
(8) Performance During Abnormal Conditions The inspectors observed all or portions of the following events:
- Reactor Cleanup System Isolation
- Drywell Chiller Tripped Out
- Control Rod Notch Problem
- ESF Actuation-Manual Start of Standby Gas Treatment
- Spurious opening of the Main Steam Bypass Valves
- Rod 44-13 Accumulator Low Level
- Diesel Generator 1B governor oil level low Operator response to off-normal events and indications was excellent. Alarms were acknowledged, reported, and evaluated in a timely and professional manner. Operating procedures were consulted and the conduct of operations was performed in compliance with operating procedures and Technical Specifica-tions.
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(9) Communications Between Departments
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The inspectors determined _that the communications between departments directly related_ to reactor plant op(erations and.
testing including the example in paragraph 3.a. 3) was
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excellent. Communications in'these areas and between these groups were, for the most part, clear and concise with objectives and commitments being exchanged with clear under-standings.
Evaluation of communications outside the areas described were limited due to the close relationship of the
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(10)IndependentVerificationEffectiveness The inspectors observed this activity in connection with surveillances and system tagout procedures. Operators were in compliance with procedural requirements and no concerns were-identified.
'(11)EffectivenessandInvolvementSupervisor/ Manager This area was evaluated as good overall and excellent during abnonnal events. The management involvement in the rod notch problem resulted in prompt response from supporting departments including General Electric Representatives, the Startup Manager, the Nuclear Engineer and the System Engineer. The management involvement also resulted in providing direction, not control, and implemented hold points in the problem resolution which was a positive indicator.
(12) Workload of Operating Crew
The inspectors evaluated this area in terms of routine and off-normal operating requirements, routine surveillance requirements, and maintenance demands placed on the operating crews. The inspectors determined that a "Spare" crew of CR0s were providing support to the regular day shift crew. Based on the observed activity during the inspection period, it appeared that normal crew shift manning would have been inadequate to keep up with the day-to-day manpower requirements.
Improvements must be made in this area prior to attempting to proceed with further comp 1Ex integrated power plant testing and operations.
(13) Event Followup The inspectors determined that the followup of the events discussed in previous paragraphs was adequate, thoro T and provided timely and appropr ute corrective actions,
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(14) LC0 Time Clocks Inspection in this area indicated an adequate knowledge of the Technical Specification LCOs by the operators, however, improvements can be made tracking LCOs by providing a more conver.ient recognition method (i.e. easel or flip-chart type device in the horseshoe). During followup inspections, the resident inspector noted that the licensee had placed an easel in the control room to provide higher visibility and tracking of LCOs.
(15) Effectiveness of Plant Tours During a plant walkdown on March 3, 1987, the inspector observed a temporary cable connected to IJB657K (RCIC Governor Valve Relay Panel). The panei was tagged with a Nonconforming Material Report (NCMR), Tag No. 2-0942, however, the cable was not tagged with a Temporary Modification (TM) tag as required by IP Procedure CPS No. 1014.03 (Temporary Modifications).
The inspector discussed this matter with the Shift Supervisor (SS). The SS issued Condition Report (CR) No. 1-87-03 docu-menting the condition as a violation of IP procedure.
During a followup review, the inspector determined that the above temporary cable had been identified as TM No.86-152, but had been closed through issuance of the NCMR. On February 10, 1987, the licensee's Quality Assurance (QA)
Department issued CR No. 1-87-02-088, by which this and other TMs had been converted to NCMRs. The CR noted that the practice of converting TMs to NCMRs was not in accordance with IP procedure. CPS No. 1014.03 provided two conditions for ciecring TMs; (1) The equipment be restored to its original condition and (2) The TM be replaced by a permanent plant modification. CR No. 1-87-02-088 had not been dispositioned at the close of this inspection.
The inspector determined that NCMRs are "tracked" and receive
"operability" review by the licensee, however, NCMRs do not receive the frequent / routine review as specified for TMs.
Crew supervisory personnel were required to review all open TMs as part of their shift turnover process.
Followup inspection of this item was performed by the resident inspector. The inspector reviewed completed CR No. 1-87-02-088 to determine if the licensee had identified the root cause and taken appropriate corrective action. The root cause of the identified condition was determined to be the misapplication of the TM program to track equipment deficiencies that should have been documented as NCMRs. Generic corrective action was completed by revising the Temporary Modification procedure CPS No. 1014.03 to state in paragraph 6.4 that the Temporary Modi-
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fication procedure shall not be used on components containing non-conforming caterial.
Based on the review performed, the inspector concluded that the licensee had taken adequate corrective action as detailed in the dispositio1 of CR 1-87-02-088.
Sunmary Based on the observations by the inspectors of the integrated plant operations activities including; failure to comply with administrative controls in log keeping and data recording; excessive activity and distractions in the control room; the demonstrated attitude of the entire operations department that operations was not in charge; excessive workload demarids on the Operating Crews; high levels of balance-of-plant testing activities still in progress; excessive levels of power plant maintenance activities in progress and scheduled resulting in the maintenance departments being t.::ed M their performance limitations; tentative and weak pre-shift briefs and shift turnovers; control room decorum and control; high numbers of control room nuisance alarms; and other findings, it was concluded that the Clinton Power Station was not ready to perfonn continued reactor plant testing and power operations above the levels for which CPS was already licensed in a manner which would ensure the health and safety of the general public.
On a positive note; it was concluded that the licensed and non-licensed operators were probably CPS's greatest strength at this point in reactor plant testing and operation.
b.
During the inspection conducted from March 30 through April 2, 1987, the following items were identified.
(1) During a plant walkdown on April 1,1987, the i spector observed that the RCIC pump room cooler inlet 11 W r scre a was approxi-iaately 40% clogged by insulation debris. lne Hcesee had documented this condition on wintenance Work Reque:t No. 36628 dated February 17, 1987 Howc er, correcting the deficiency had not been timely as the existing condition had adverse impact c1 the room coolers operability.
(Shortly after the end of this inspection, the deficiency was corrected.)
(2)
It was also noted during this inspection period that the licensee had initiated action (s) to resolve the weaknesses identified during the earlier inspection period. Log keeping and data recording had improved; control room activities were kept to a minimum commensurate with safe plant operation; activities that were considered to be distractions in the earlier inspection were being conducted outside the horseshoe; the operations department exhibited control over plant
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operations and activities of-other departments with potential
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to_ impact safe operations; balance _of plant testing activities
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and maintenance activities were minimized and appropriately controlled;Lpre-shift briefings and shift turnovers were comprehensive-and conducted in accordance with administrative
. procedures; nuisance alarms _had been reduced-and the licensee
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had a program to reduce and control nuisance alarms over-continued plant operation. The team determined sufficient progress was made, and programs were established such that the-team no longer was concerned with the licensee's ability to perform continued reactor plant testing and operation at power levels'above 5% reactor power.
4.-
Monthly Surveillance Observation-(61726)
During the inspection from March 2 through March 7, 1987 and March 30 through April 2, 1987, station surveillance activities of the safety-related systems a1d components listed below were observed / reviewed to-ascertain that they were conducted in accordance with approved procedures and in conformance with Technical Specifications.
The following items were considered during this review: the limiting conditions for operation were met while affected components or systems were removed from and restored to service; approvals were obtained prior to initiating the testing; testing was accomplished in accordance with approved procedures; test-instrumentation was within its calibration-interval; testing was accomplished by qualified personnel; test results conformed with Technical Specifications and procedural requirements and were reviewed by personnel other than the individual directing the test; and any deficiencies identified during the testing were properly documented, reviewed, and resolved by appropriate management personnel.
The following surveillance testing activities were observed / reviewed:
Procedure No.
Surveillance / Test Activity CPS No. 9031.12 APRM Channel Functional CPS No. 9038.63 MSIV-LC Inboard Dilution Air Flow-Channel Functional CPS No. 9080.01 Diesel Generator IA (IB) Operability-Manual CPS No. 94?l.14 IRM-C51-K601A (B-H) Channel Calibration CPS No. 9432.06 CRVIS-RCIC Line Flow Channel Calibration C11-N054(A)
Rod Pattern Controller-Channel Calibration CPS No. 9072.01 Steam By-Pass Valve Test
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1 CPS No'. 9920.74 Standby Gas Treatment Exhaust Process Radiation Monitor Channel Functional
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CPS No. 9432.15D001 RHR Heat Exchanger Room Delta T Channel L
Functional / Calibration ij
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CPS No. 9431.14 JRM "A"' Calibration
' CPS'No' 9031.14
'IRM "A" Channel Functional
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CPS No.19071.01 Diesel Fire Pump Surveillance CPS No. 9432.16 RHR Heat Exchanger Room Temp. Channel Calibration and Functional Test CPS No. 8629.01 TIP System Channel Calibration (Partial' Sect.
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CPS No. 9054.06 RCIC System Flow Path and Flow Control Alignment Checks CPS No. 9030.01 RCICOperability(Steam 1.ineLowPressure)
-CPS Ho, 9432.18C001 RWCU Vent Delta T Channel Functional / Calibration CPS No. 9067.01 Standby Gas Treatment System Train Flow / Heater Operability CPS No. 9432.13C001 RCIC Equipment Area Temperature Cha,nnel Calibration and Functional CPS No. 9563.020001 Suppression Pool Water Level Channel Calibration and Functional The inspectors detennined that station personnel performed surveillance activities using approved procedures and calibrated instruments.
Appropriate restoration and functional checks were performed and Technical Specifications requirements were satisfied.
The instrumentation and controls (I&C) technicians demonstrated good work practices. The I&C surveillances were perfonned by two te hnicians; one would read the procedure steps and the other would repeat the step and perform the action. The I&C technicians maintained good comunications with the control room operators regarding coninencement and restoration of surveillance activities. The surveillance activities were closely supervised by the !&C supervisor.
Deficiencies were observed as follows:
a.
The personnel performing weekly surveillance on the Diesel Fire Pump (Procedure No. 9071.01) did not have the tools necessary for the task; additionally, the operator had to support his weight by holding on to a pipe while performing the venting operation.
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The work load placed on the control room operators during the evening shifts of March 5-6, 1987, seriously impacted the operators'
ability to perform routine and specified control room walkdowns and surveillances. Control room operators' actions were dictated by unplanned events, plant problems and necessary alarm response.
c.
The Surveillance Impact Matrix specified in Plant Managers Standing Order PMSO No. 30 had not been completed prior to performing Surveillance No. 9030.01 (RCIC Operability) and No. 9031.12(APRM Channel Functional).
The matrix was intended to ensure shift supervision was informed of possible/ actual impact of tests on plant operations.
Licensee's failure to complete the matrix for the RCIC Operability Surveillance was a contributor to RCIC wrbine trip and
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isolations experienced during the performance of that surveillance.
Followup inspection of the above RCIC turbine trip event resulted in the issuance of a Notice of Violation (NOV) (461/87011-03(DRP)).
The inspector's review of the licensee's corrective action to that NOV was documented in Inspection Report 50-461/87031, paragraph 2.d.
5.
Monthly Maintenance Observation (43574, 62700, 62702, 62703)
Station maintenance activities of the safety-related systems and i
components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, and industry codes or standards, and in conformance with Technical Specifications.
The following items were considered during this review:
the limiting conditions for operation were met while components or systems were removed from and restored to service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; retivities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemented. Work requests were reviewed to determine the status of outstanding jobe and to assure that priority is assigned to safety-related equipment maintenance which may affect system performance.
The following maintenance documents / activities were observed / reviewed:
Maintenance Work Request C09262 Maintenance Work Request C30540 Maintenance Work Request C15376 Following cortpletion of maintenance the inspectors verified that the systems had been returned to service properly.
a.
Corporate nuclear procedure CNP 1.10, Revision 0, "Nuclear Program Priorities" and Clinton power station procedure CPS No. 1029-01, Revision 15, "Preparation and Routing of Maintenance Work Requests" were reviewed.
In reviewing these documents the inspector noted that paragraphs 2.1.9 and 8.3.2 of CPS No. 1029.01 allowed work to be performed on maintenance classified as Priority 1 prior to
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issuing the maintenance work request (MWR). The MWR contained the required approvals as well as instructions for performing the activity.
Paragraph 3.1 of CNF 1.10 defined a Priority 1 item to include problems that pose a significant delay in critical path work or on plant operation. Other items were also included which did not appear to pose an itriediate nuclear safety issue.
10 CFR 50, Appendix B, Criterion II " quires control of activities affecting the quality of safe,y related systems and structures to an extent consistent with their importance to safety.
During the second week of the inspection conducted between March 30 through April 2, 1987, the inspector reviewed the action taken by the licensee to resoive the weaknesses identified above. The licensee had issued revision 16 to procedure CPS No. 1029-01 to prohibit work to oe performed on Priority 1 items prior to issuing the
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required MWR except in cases where personnel safety or safe plant shutdown are involved. Revision 16 was reviewed and is considered acceptable, b.
The inspector observed maintenance work being performed on mechanical MWR C06041 and instrument and control MWR C2787b.
In both cases maintenance personnel appeared to be knowledgeable and performed the work acceptably.
In working the instrument and co5 trol MWR (C2787b) the maintenance technician noted that required data could not be calculated from a formula contained in the data tables.
The technician returned the package to planning where the error was corrected.
No other work instruction problems were noted in the work observed or in packages reviewed and the inspector has no further concerns in this area, c.
The inspector noted that on March 5, 1987, 2935 MWRs were open.
MWR status and coordination meetings were conducted each weekday to expedite critical and high priority MWRs. Based on earlier data reviewed the number of open MWRs did not appear to be declining.
Illinois Power management was aware of this backlog and the numbers were included in reports to the resident NRC inspector.
During the second week of the inspection the inspector noted there were about 2300 MWRs open. This number was still considered high; however, the licensee had established management initiatives to continue to reduce the maintenance backlog.
The maintenance backlog had been reviewed on a continuing basis by the Clinton Resident Inspectors and Region III management.
The licensee reported in monthly meetings with Region III management the progress being made on reducing that backlog. As of February 9, 1988, the total backlog of open MWRs was about 1075. The licensee had scheduled about 300 of these to be worked during their next outage scheduled to begin on March 19, 1988.
d.
The inspector reviewed completed MWR packages C15775, C20927, C28883, C30353, C31526, C31540, C34071, C40027, and C49479. All packages appeared to contain adequate work instructions.
Procedure
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O 1029.01 did not require a sign off'as each step was completed but required that work performed be described in a narrative form on a MWR continuation sheet. This narrative description of work performed sometimes covered as'much as 10 or more pages and it was extremely difficult to determine if all work instruction steps had been performed. This matter was discussed with licensee personnel but there was no agreement that action would be taken in this area, however, although considered cumbersome the method was acceptable.
Followup inspection by the Clinton Resident Inspector noted that CPS No. 1029.01 had been revised and paragraph 8.2.19 required the Repairman / Technician to initial each step to the left of the job step as it was completed, e.
During the first week of this inspection, the inspector reviewed administrative procedure CPS No. 1034.01, Revision 9, "Preventive Maintenance". The computer listing of Preventive Maintenance Past Due Items issued February 27, 1987, and the CPS Past Due Preventive Maintenance Report were also reviewed. Approximately 500 preventive maintenance (PM) items were past due. The computer system that was in use required manual searching in some areas due to limited search capability. CPS No. 1034.01 had provisions such as requiring an liWR for each PM item which made it difficult to use.
The inspector was informed that approximately 7000 items were currently in the PM program which was considerably smaller than other comparable large reactor plants.
In discussing this matter with licensee personnel the inspector was informed that the licensee was aware of the problem and the following actions were being taken:
(1) Procedure CPS No. 1034.01 was being revised to provide a better and more workable procedure.
(2) The PM tracking system was being transferred to another computer system which had larger storage and greater search capability.
(3) Emphasis was being placed on overdue PM items to reduce the backlog of past due items.
(4) An effort was being undertaken to review all plant component, systems and hardware for possible inclusion in the PM program.
During the second week of this inspection, the inspector noted censiderable improvement in the preventive maintenance area.
The following observations were made:
a.
The number of late safety related Pil items had been reduced from 43 the first week of inspection to 4 by the end of the second week of inspection. (As of February 9, 1988, the number of late safety related FM itent was 0)
b.
The number of past due PMs had been reduced from 512 to 244 by the end of the second week of inspection. (As of February 9, 1988, the late-beyond grace PMs was 32)
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The revision to Procedure CPS 1034.01 was in final approval and expected to be issued early in April 1987.
(Revision 10 to CPS No. 1034.01 was issued May 15,1987)
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Seventeen maintenance personnel had been assigned primary responsibility in the preventive maintenance area, e.
Staffing authorization had been approved for 10 engineers to evaluate PM items for adequate maintenance and to evaluate items not currently in the PM program to determine if the item should be included.
(This evaluation was being tracked by a Region III specialist as Open Item 461/87035-05)
f.
Change over to computer tracking of PMs was expected to be accomplished by April 30, 1987.
(Changeover to the licensee's IBM computer was accomplished in coordination with revision 10 of CPS No. 1034.01 issued May 15,1987.)
Based on these actions, the licensee had demonstrated considerable management interest and emphasis in the PM program. Attention needs to continue in this area and the changes need to be monitored closely to ensure the desired improvements continue.
The team concluded that licensee management had initiated program controls to ensure that PM items would be accomplished when required; to reduce the existing backlog, to give appropriate consideration to reducing the backlog of safety significant items on a priority basis, and to dedicate the necessary management and personnel to conduct the program in a manner which meets regulatory requirements.
6.
Licensee Event Report Review and Followup (90712)
The inspector reviewed the licensee event reports for 1986 and 1987 for trends.
It was noted that a large fraction of the reports were caused by personnel error and a large number were associated with lifted leads.
The licensee appeared to be adequately responding to the personnel errors and also had a program for reducing the numbers of lifted leads that were required for routine testing.
During the inspection period March 30 through April 2, 1987, the team reviewed the licensee's procedure for evaluating events, preparation of Licensee Event Reports (LERs), and trending program for determining corrective actions. The team determined the licensee's program appeared to be procedurally controlled, a single individual was assigned responsibility for quality of LER preparation, and a mechanism was in place for trending LERs and determining appropriate corrective actions.
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7.
Radiation Protection (71707,83726,83524)
a.-
'During the inspection period March 2 through March 7, 1987,-the inspector observed radiological protection practices during plant tours and while accompanying radiation protection technicians conducting routine work activities.
The radiologically controlled zones were adequately posted and generally well configured and controlled.
The access to a clean area in the radwaste building
'had the potential for, spreading contamination since after exiting a monitor, personnel must cross a potentially contaminated passageway to enter the clean area. The licensee had plans to charge this arrangement.
(The licensee removed this access point subsequent to this inspection.)
It was apparent that not all personnel _ were following proper radio-logical practices. An individual who twice alarmed the personnel monitor, frisked himself rather than notifying Radiation Protection as required by Procedure CPS 1029.40.
In another case, a guard within the radiologically controlled area was observed placing his badge in his mouth in order to pass through a door with his other arm full of material. The licensee was instituting a notification program consisting of printed material and meetings to remind personnel of the requirements.
Two contract radiation protection technicians were observed while performing routine duties. They were very knowledgeable of funda-mental radiological practices but were extremely unfamiliar with
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the facility layout and systems.
Further review revealed that the
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contractor technicians do not normally attend the licensee's two-week facility and systems training.
Some systems and layout training appeared to be needed for contract technicians to ensure their effective utilization.
The shift turnover was monitored.
Sufficient information was-exchanged to ensure that plant status was known, ongoing work was continued, and new work was assigned, b.
During the inspection period March 30 through April 2, 1987, the inspector verified the licensee had initiated action to improve the in plant knowledge of contractor technicians. All technicians received a pl:'nt walk through with a Shift Supervisor to familiarize the personnel with the various plant areas which contained potential hazards.
The licensee was developing a 4-hour BWR-6 plant system /
icyout training course to be given to all contractor technicians; and long-term contractor personnel were to receive licensee employee
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radiation technician training.
Region III specialist inspectors (DRSS) planned to review the adequacy of the training program
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provided to contractor personnel.
Results nf that review will be provided i. a subsequent inspection report.
The licensee had also initiated a Radiological Improvement Report for documenting small problems.
If trends were observed a Condition Report was to be issued identifying the problem, and appropriate management action was to be taken, including progressive discipline,
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The licensee had also initiated actions t'o improve the flow of information to personnel, such as Radiation Protection Shift Supervisor briefings to other departments, a news. letter, use of video tape presentations on radiation work permit procedure changes, frisking methods and barrier controls.
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8.
Chemistry (71707,81064,79501)
The inspector observed chemistry activities while accompanying technicians on routine work activities. The technicians exhibited extremely good radiological practices, chemistry techniques, and knowledge of procedures. The shift chemistry supervisors were aware of their responsibilities and plant cond?tions, and were in control of shift activities. Shift turnovers were well conducted and were generally accurate and included sufficient information.
Some confusion was evident concerning the status of certain plant instruments.
The inspector observed portions of activities related to discharge of water with the discharge monitor out of service..It wat noted that the discharge procedure did not clearly address or make provisions for the technical specification required independent verification of the discharge lineup. The licensee intended to revise the procedure to resolve this concern.
Followup inspection performed by the Clinton
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Resident Inspector noted that Operating Procedure CPS No. 3908.01, revision 7, dated July 15, 1987, "Discharging From the Station",
contained a "NOTE" in paragraph 8.1.4 directing at least two technically
. qualified members of the plant staff to independently verify the discharge valve lineup when the liquid radwaste discharge monitor was not providing alarm and automatic termination of discharge.
9.
NuclearEngineersActivities(41400)
Inspection of the Nuclear Group was performed by two regional based inspectors and consisted of interviews with members of the group, review of training and qualification records of group members, and the review of both administrative records and procedures completed by the Nuclear Group. The specific plant records and procedures reviewed were:
Training records for the Nuclear Group Supervisor and the individuals assigned to the Nuclear Group.
- CPS Procedure No. 1302.03, "Station Nuclear Engineer Training".
- Standing Order TS0-026, "Review of Startup Test Procedure Test Results for Possible Incorporation into Plant Staff Procedures and Technical Specifications," Revision 0, dated August 14, 1986.
CPS Procedure No. 9811.01, "Shutdown Margin Determination,"
performed on February 26-27, 1987.
CPS Procedure No. 9812.01, "Reactivity Anomaly," performed on
February 27, 1987.
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CPS Procedure No. 2202.04 F001, "Reactor Operator Instructions for Criticality," completed February 24, 1987, February 27, 1987, March 1, 1987 and March 3, 1987.
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CPS Procedure No. 2202.04 D001, "Point ECP Calculation Data Sheet,"
completed February 27, 1987, March 2, 1987 and March 3, 1987.
The training records indicated that the minimum requirements of ANSI /ANS 3.1-1987, Section 4.4.1, "Reactor Engineering," were met by the Nuclear Group Supervisor.
The Nuclear Group training program comprised two qualification levels, fully qualified nuclear engineers and interim qualified nuclear engineers. At the time of this inspection, the only fully qualified nuclear engineer was the Nuclear Group Supervisor.
Four nuclear group members were interim qualified nuclear engineers.
Prior to being eligible to become fully qualified, these individuals require actual plant operating experience in the area of nuclear station engineering activities. To be an interim qualified nuclear engineer, the licensee's program required, as a minimum, a Bachelor's Degree in Engineering or the Physical Sciences, two years of nuclear power plant experience, six months of operating experience, and completion of an NSSS systems course, a Balance of Plant systems course and the General Electric Station Nuclear Engineer Course. The training records for the four individuals currently designated as interim qualified nuclear engineers indicated that each of them had met these requirements.
Three of the four satisfied the operating experience requirements via testing or naval reactor experience.
The fourth interim qualified nuclear engineer had three and one-half years of experience at a commercial boiling water reactor.
The Nuclear Group Supervisor, with three years of commercial boiling water reactor experience, was the only other individual in the group with commercial nuclear power plant experience.
Steps that had been taken to compensate for the lack of commercial power plant experience for three of the four interim qualified nuclear engineers included:
(1) sending each of the three to an operating commercial boiling water reactor plant for several weeks of observations, (2)
holding seminars to provide practice exercises pertaining to potential operating power plant concerns, and (3) the first time that complicated nuclear group tasks such as power shaping and preconditioning monitoring are performed, the nucicar group supervisor intended for those tasks to be handled by himself or the interim qualified nuclear engineer having previous commercial nuclear power plant experience.
There were two clearly established methods for transfer of startup testing experience to the nuclear group.
First, a member of the nuclear group reviews all startup test changes and startup test results as part of his responsibilities as a member of the Joint Test Group.
This individual stated that either he or the Nuclear Group Supervisor review all startup test changes and startup test results that affect the nuclear group; review assistance is requested from other technical staff members for items outside of the nuclear group's domain.
Second, Standing Order TSO-026 "Review of Startup Test Procedure Test Results for Possible Incorporation inte Plant Staff Procedures and Technical Specifications," assigned two members of the nuclear group to review all
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.g-completed Startup Test-Procedures to ensure that important plant operating data and setpoints were incorporated into Plant Staff Procedures and-Technical Specifications. Additionally, three members of the Nuclear Group (the supervisor and two others) had spent time working in-the startup group.
Thorough assessment of procedure implementation was not possible because, at the time of the inspection, the Nuclear Group had performed only a few procedures.
10. Training (41400 & 41701)
The effectiveness of trainnig programs for licensed and nonlicensed -
personnel were reviewed by the inspectors during the witnessing of the licensee's performance of routine surveillance, maintenance, radiation chemistry, nuclear engineering and operational activities and during the review of the licensee's response to events which occurred during-the Clinton plant startup team inspection. The personnel observed were knowledgeable and confident in the activities they were assigned.
Training effectiveness was evident in that activities performed were done correctly, in a timely manner, and without any unnecessary actuations of components, systems or subsystems.
One weakness revealed during the inspection period from March 2 through March 7, 1987, was a basic lack of knowledge of the plant layout by a contract radiation / chemistry technician. He was technically competent on the subject of radiation / chemistry but lacked understanding of the plant and plant layout. There were sufficient personnel on site that were knowledgeable of the plant to compensate for the technician's deficiency.
During the inspection period March 30 through April 2, 1987, the inspectors verified that all contractor personnel were provided plant familiarization training. The technicians received a plant walk-thru with a Radiation Protection Shift Supervisor who identified the major equipment in the different rooms and the potential radiological hazards which might exist or occur.
The licensee was also preparing a BWR-6 plant system / layout training course which was to be provided to all contractor employees.
Long term rad-chem contractor personnel were to be required to complete licensee employee radiation technician training.
11. Employee Adverse Work Action Procedure Review (92709)
The inspection consisted of a review of licensee procedures to determine that the licensee has prepared contingency plans covering an imminent, impending, or wildcat strike, so as to ensure that a minimum number of qualified and proficient personnel would be available to ensure plant operation and safety, plant security would be maintained at a level
consistent with plant integrity and operation, and that strike plans were consistent with regulatory requirements and that these requirements were met.
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During the first week of inspection, licensee Administrative Practice Procedure No. 18 "Work Action Contingency Practice," was reviewed. The inspector determined the procedure contained sufficient guidance and information in the event that too few licensed or non-licensed operators reported to the plant to fill designated shift positions required by Technical Specifications. Additionally, security contracts covered strike activities.
12. Allegation Review Allegation No. RIII-87-A-0005 (Closed) A maintenance worker was not allowed to review the maintenance work request (RdR) prior to starting a job.
Findings: The inspector performed a review of Administrative Procedure CPS No. 1029.01, revision 13, dated October 3, 1986, "Preparation and Routing of Maintenance Work Requests".
Section 8.2 of that procedure detailed the responsibilities for performance of a Maintenance Work Request (KdR).
Upon issuance of an KdR to the "field" for work the responsibility to review the KdR package for scope of work and completeness was assigned to the Maintenance Group Supervisor in paragraph 8.2.16.
Responsibility for reviewing the work being performed for accuracy and completeness was assigned to the job Foreman / Assistant Supervisor in paragraph 8.2.24.
Responsibilities of the Repairman / Technician were defined in paragraphs 8.2.18 and 8.2.23 and included responsibility for completing the necessary maintenance and documenting the work performed in the remarks section of the original KdR.
A specific review of the RdR was not required to be performed by the Repairman / Technician. As stated above, specific review responsibility was delegated to the job Foreman / Assistant Supervisor (paragraph 8.2.24)
and the Maintenance Group Supervisor (paragraph 8.2.16).
Conclusion:
The allegation could not be substantiated since review of the MWR by the Repairman / Technician was not a procedural requirement.
However, the inspector noted that the specific work activity was relatively simple and direct supervision was provided by the job foreman.
For more complex or unsupervised job assignments, clear direction including review of the KdR by the assigned Repairman / Technician would be a reasonable expectation.
13.
Exit Meetings (30703)
The inspectors met with licensee representatives (denoted in paragraph 1)
throughout the inspection and at the conclusion of the inspection on March 6, 1987 and April 2, 1987.
In addition, the Clinton Senior Resident Inspector met with licensee representatives (denoted in paragraph 1) on February 17, 1988. The inspectors summarized the scope and findings of the inspection activities.
ThG 11censee acknowledged the
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o inspection findings.. The inspectors highlighted the need for management -
attention to internal comitments and the CPS emergency off-normal
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TheIinspectors'alsodiscussedthelikelyinformationalcontentofthe inspection report'with regard to documents or processes reviewed by-the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary.
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