IR 05000461/1987019

Oversight Team Insp Rept 50-461/87-19 on 870615.No Violations or Deviations Noted.Major Areas Inspected:Ler Analyzing & Reporting Program,Including Review of Licensee/Industry Feedback Program & Specific LERs

ML20235T198
Person / Time
Site:	Clinton
Issue date:	07/07/1987
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235T144	List: IR 05000461/1987019 ML20235T142
References
50-461-87-19, NUDOCS 8707220065
Download: ML20235T198 (15)

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y U.S. NUCLEAR REGULATORY COMMISSION

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REGION III'

i Report No. 50-461/87019(DRP)' I Docket No. 50-461 License No. NPF-62 ;

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

Facility Name: -Clinton Power Station Inspection At: Clinton site, Clinton, IL Inspection Conducted: June 15 through 19, 1987 Inspectors: J. McCormick-Barger

, B. Siegel V. Thomas D. Becker C. Schulten M. Harper G. Grant Approved By:

fC W~g R. C. Knop, Chief 77b

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Reactor Projects Section IB Date Inspection Summary Inspection on June 15 through 19, 1987 (Report No. 50-461/87019(DRP))

Areas Inspected: An announced oversight team inspection consisting of resident, region, and headquarters based inspectors to perform an assessment of the licensee's event reporting and corrective actions program by focusing primarily on the Licensee's Event Report (LER) analyzing and reporting program. Areas reviewed included: attending a presentation by the licensee of it's LER program; review of the licensee's industry feedback program; review of the licensee's performance trending programs; review of the licensee's events reporting / notifications administrative program; an assessment of specific LERs and Condition Reports (CRs); a review of the surveillance testing and calibration control program; and an assessment of the field problem report progra Results: No violation of regulatory requirements or deviations from commitments were identified in the areas inspected. The inspection team determined that the licensee has an effective corrective actions program that takes extensive event related input from both internal and external sources, performs detailed analysis of these events, and initiates appropriate corrective actions to improve plant performanc l[O DON b [

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DETAILS 1. Persons Contacted W. C. Gerstner, Executive Vice President, Illinois Power Company (IPC)

D. P. Hall, Vice President, IPC J. Greenwood, Manager, Power Supply, Soyland Power /WIPC0 R. E. Cam) bell, Manager, Quality Assurance J. G.' Coo (, Assistant Manager W. Connell, Manager, Nuclear Safety Engineering Department J. S. Perry, Manager, Nuclear Programs Coordination R. A. Schultz, Director, Planning and Programming F. Spangenberg, Manager, Licensing and Safety E. A. Till, Director, Nuclear Training R. E. Wyatt, Director, Nuclear Program Assessment The above persons attended the exit meeting held on June 19, 198 The inspectors also contacted other individuals during the inspectio . Licensee's Presentation of its LER Reporting and Analyzing Program (30703) .

In a letter from Region III to the licensee, dated May 28, 1987, the licensee was requested to prepare a presentation of its event reporting and analyzing program, to be presented during the oversight team inspection entrance meeting. On June 15, 1987, the oversight team attended this presentation. The licensee discussed its organization, management involvement and philosophy, reportable event process, industry feedback program, quality assurance program, and examples of problem areas identified and actions taken to resolve these problem This presentation combined with the team's pre-inspection review of Clinton Power Station (CPS) procedures for review of operating experiences, condition report initiation and processing, and LER processing, provided useful information to the team members in preparation for the indepth review of the licensee's reportable events, corrective actions, and lessons learned programs. Management programs for obtaining, reviewing, and taking actions associated with lessons  :

learned from other plants and organizations such as INDO and NRC were l also reviewed by the oversight team and are addressed belo . Review of the Licensee's Industry Feedback Program (92720)

, The inspectors performed a detailed review of the licensee's program for obtaining, reviewing, and acting on information provided from other plants'

LERs, INP0's information network, and NRC Bulletins, Circulars, Information Notices, and Generic Letter ,

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The inspectors reviewed CPS procedure 1006.04 " Review of Operating Experiences", dated September 15, 1986, and Licensing and Safety (L&S)

procedures L.1 " Feedback Program", dated May 5, 1986, and 1.6 " Review of CPS and BWR/6 Plant Licensee Event Reports", dated March 6, 1987. These

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E procedures-provided instructions and assigned responsibilities for

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meeting the intent of NUREG-0737,. Item'I.C.5, which specifies that each licensee'shall assure that. operating information pertinent to plant safety originating within and external to the utility organization, is reviewed and appropriately supplied to plant. operators and incorporated into training program ' The licensee's program'for reviewing operating information included:

NRC Bulletins, Circulars, Information Notices, Generic Letters, and other regulatory documents; INP0 documents including Significant Operating Experience Reports (SOERs),'Significant Event Reports (SERs), Operations and Maintenance Reminders (0&MRs), Industry Reports and Network entries; and Vendor and A/E Documents including Service Information Letters (SILs), Turbine Information Letters (TILs),' Rapid Information Communications.ServiceInformationLetters;(RICSILs),andother documents. 'In addition to the above, CPS established an LER exchange program with Perry, River Bend, and Grand Gulf Nuclear Power Station The inspectors reviewed a sample of the licensee's review and processing of the above incoming documents. Since the LER exchange program began only three months .ago, CPS obtained and reviewed all of the Perry LERs since.the issuance of.the' Perry operating license. The inspectors reviewed the licensee's formal reviews of the Perry LERs. This review by the Independent Safety Engineering Group (ISEG) included determining if the event was applicable to CPS'and recommending actions ~ (if any) that either operations or engineering should take relative to the even ISEG's reviews of the incoming LERs were documented on memos to the applicable organizations with requests that the action organization respond back to ISEG with an estimated.dve date for closure of the commitment tracking items that were assigned to each LER that required actions. The inspectors concluded from their review of the actions CPS had taken from Perry LERs, that CPS has an adequate response threshold and that plant actions in response to Perry events appeared to be adequat The non-LER documents listed'above are initially reviewed and tracked by the CPS Licensing and Safety department with action items assigned to operations and engineering and tracked by a. separate licensing tracking system. The inspectors' review of a sample of these documents indicated that the licensee's actions were appropriate and well documented with easily retrievable records, In addition to the above, the licensee participated in the BWR Startup and Operating Experience Conference in Chicago on December.8-9, 1986 and May 19-20, 1987. From the key points of the presentations, the licensee prepared a list of tasks and evaluation requests. These items were assigned to applicable CPS managers in order for them to make use of the operational feedback and lessons learned from other new BWRs. Items listed included startup experience, jumper control, ESF actuations, BWR water chemistry, RWCU system problems, alarm reduction, refueling experience, and spare parts inventory. The licensee's responses indicated that the lessons learned have been considered, and, if applicable, have been incorporated into the plant or made part of long term planning i activitie _ _ _ - _ - _ _ _ _ _ _ _ - _ -

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. Review of Licensee's' Performance' Trending Programs (92720):

To. determine _the' adequacy of the licensee's programs for trending plant performance and providing recommendations for improvement, the inspectors reviewed the.following programs:

Licensee Event Reports (LER) - Monthly Reports The licensee performs a monthly review of LERs issued during the; month. 1his review includes an analysis of each LER that categorize

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the cause of each event, describes the events, and trends the events-using the complete LER data base. The reviews are issued as monthl reports to upper mr.nagement and include a conclusions / recommendations sectio The inspectors _ reviewed the past four LER monthly reports and found that they generally lacked both an indepth analysis and/o recommendations. However, the last issued monthly report showed some improvement over the previous three reports in that several c recommendations.were made with applicable department manager responses requested. The inspectors discussed this concern with the licensee and were told that more recommendations and request for department responses would be made in the future as adverse trends are identifie Condition-Report Trending Program The licensee's quality assurance organization issues a monthly site trend analysis covering the three preceding months. This report is based on the review of all documented deficiencies, including condition reports, generated.during the previous three month period (approximately 1000 documented deficiencies). Adverse trends are identified and, if appropriate, Management Action Items (MAls) are generated which require applicable department managers to provide the QA organization with written plans for correcting the adverse trends. The QA organization continues to monitor the adverse trends after closing the MAls to assure corrective actions are effectiv The inspectors reviewed selected monthly site trend analysis and management responses to MAls and found the MAls to be valuable feed-back mechanisms and responses to contain indepth actions plans that should result.in plant improvement Material Condition Management Program The licensee is in the process of implementing a Material Condition Management Program (MCMP) (June 9, 1987 memo from D. Hall to Managers). The purpose of this program is to identify, at an early stage, conditions that would detract from proper equipment performance. Many aspects of this program are currently in place including utilization of reliability engineering to evaluate plant operation. A Reliability Engineering Group (REG) is responsible

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for administrating the MCMP program. The REG will evaluate plant reliability on a systematic basis and expand the current program to include additional areas such as plant performance monitoring, condition reports evaluations, reliability controlled maintenance analyses, and failure modes and effects analysis on selected systems. .The REG will utilize corrective and preventive main-tenance data, trending analysis, and information from external sources such as the Nuclear Power Reliability Data System (INP0),

Nuclear Operation Maintenance Information System and Operating Performance Evaluation System in the evaluation of system perform-ance. The team views the current program and the expansion of this program as positive steps towards reduction of system and component failures and improved plant performanc Non-LER Event Critique Program The Condition Report (CR) system identifies a wide range of issues which are evaluated for, among other things, deportability under 10 CFR 50.72 and 10 CFR 50.73. As discussed later, the mandatory nature of the LER reporting system focuses management and staff attention on high level problems. To address significant issues and events that may not meet deportability requirements, the licensee has implemented a self-generated " critique" review program for these ev nts. This program assembles a cross-section of technical and mah3gement expertise to perform detailed analyses of these issues and events. Analysis and corrective actions were found to be on a par with those_ generated by LERs. A review of several of the most recent critiques indicated that the licensee is taking positive aad timely measures to prevent recurrence or escalation of problem Corrective actions effectively addressed root causes and were specific in nature. The following critiques were reviewed:

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Auto transfer of HPCS suction valve Rod 36-09 withdrawal error

Isolation of H,/0 monitor Skin contamination even This critique program appears to be a progressive and comprehensive approach to analysis and prevention of "near miss" event From the team's review of the above four programs for trending and/or analyzing performance, the team has concluded that the licensee has implemented comprehensive systems with sufficient overlap to assure that significant negative trends are identified and appropriately acted o Continued improvement in the quality of the LER - monthly reports, particularly in the area of identification of specific action items and request for applicable department manager responses, will enhance this are _ _ _ ,_ _ _ _ -_ - _

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. . Review of the Licensee's Events Reporting / Notifications Administrative

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Program (92720)

'0 The inspectors performed a detailed review of the licensee's Event Reporting / Notifications program to assure that the program met regulatory requirements and that the events are being properly;. classified and/or reporte The inspectors reviewed Clinton Administrative Procedure CPS No. 1016.04

" CPS Licensee Event Reports (LER)", Revision 2, dated November 17,-1986, and CPS No. 1016.01 " CPS Condition Reports", Revision 17 dated May 8, 1987. The inspectors fo:md that the procedures closely followed 10 CFR 50.72/10 CFR 50.73 reporting requirements. The procedures specifically listed criteria for genereN Condition Report (CRs),10 CFR 50.72 notifications, and LERs. During the inspection, the inspectors were

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informed that CPS No. 1016.04 was undergoing an extensive revision along 1 with other related lower tiered procedures in order to streamline the I condition report system. The revised condition report program was i expected to be fully implemented within a few months.

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Prior to the performance of this inspection, the team performed a review of all LER's issued by the licensee from license issuance on September 29, 1986, through May 15, 1987, (LERs 86-01 through 86-25 and 87-01 through 87-23). In addition, the inspectors performed indepth reviews of selected LERs and CRs which are discussed in later portions of this repor From the review of these documents, and the administrative program for reportable events, the inspectors determined that 10 CFR 50.72 notifications were timely; CRs sufficiently related the scope of the events; 10 CFR 59.72 notifications were adequately evaluated to determine if LERs were also required; assessment of the events followed provisions of 10 CFR 50.73; and the licensee's program had resulted in comprehensive and well dowmented problem identifications, analyses, and resolution '

Generally, LER files reviewed represented a complete history of events from identifi;:ation to mignment of corrective actions. This was a noteworthy approar.h to probiem cesolution. Event Critiques and {

investigations evidenced a probing and comprehensive approach to event analysis. Critiques were chaired by management or senior supervisory J personnel and were well attended at all levels by representatives of l concerned disciplines. Corrective actions addressed rcot causes and )

often generated independent investigourns of related matters to ensure i prevention of similar eve ts. These actions were documented and entered {

into various tracking /c'osure schemes depending upon their significance l and relation to the e'ent. Inspection of tlic corrective action tracking 1 program showed it to ae well structured and effective. Review of a '

number of actions sF awed documentation of complete closure or entry into other formal track-ng programs. Ancillary issues raised at critiques

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often became the basis for department enhancement activities. These ,

issues would then become action items and would be individually tracked i by the responsible department. Overall, the prcgram appeared to be I well-managed and effective, l

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l 6. Assessment of Specific LERs and CRs (62700) (92700) (41701)

As stated earlier, prior to the start of the onsite inspection, the licensee's LERs (LERs 86-01 through 86-25 and 87-01 through 87-23) were sorted into the five broad categories of: Controls and Instrumentation (C&I), Mechanical, Electrical, Technical Specification /LC0 Control, and I ERs primarily attributed to procedural, administrative, or operator errors. The inspection team was in turn divided into five groups and performed a detailed review cf the LERs in their respective categor This review included the identification of adverse trends in licensee performance, major and minor event classification, and completeness of the LERs. In addition, the inspectors reviewed the licensee's quarterly trend reports to determine if the licensee's analyses were adequately identifying adverse trend During the onsite inspection, the inspectors performed indepth reviews of selected LERs,10 CFR 50.72 notifications, and CRs in their respective l categories to determine if the events were properly documented and the s root cause and corrective actions were appropriate and comprehensiv The inspection included interviewing key individuals, reviewing procedures and hardware if applicable, and reviewing supportive documentation i including.the licensee's corrective actions taken to reduce the possibility of recurrence. In addition to the general observations identified in section 5, the following cre specific observations made by the inspectors during their onsite review of plant events: The inspectors noted that LERs 87-01, 87-19 and 87-23 lacked required component failure data in block 13 of the formal LER reports. The licensee apparently intentionally left this information out due to their threshold for providing component failure data. The inspectors informed the licensee that a slightly lower threshold would provide an increase of useful data into the LER system. The licensee intends to review this matter and make any appropriate change During a detailed onsite review of LER 87-23, the inspectors noted that the radiation monitor detector whose failure caused the event was noted to have had a high tube failure rate in the critique package. However, the observation never became a formal corrective action requiring followu Further investigation showed that the licensee Radiation Protection division had developed an effective approach to detennining and minimizing detector tube failures. The approach should ensure that a high quality supply of tubes is available as spares and kept under controlled conditions. This division initiative should have been formally tracked as an ancillary item to the LER. The licensee has committed to formal tracking of this action under the Centralized Commitment Tracking (CCT) progra Clinton experienced two reactor scrams in May 1987, due to the same feedwater regulating valve malfunctioning. On May 6 (LER 87-25),

the reactor was manually scrammed because the feedwater control

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V valve failed'open, causing reactor water -level to rise. 'Cause of the

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r control valvet failure was a ruptured pressure switch. Corrective action included replacing the pressure switch, cleaning of:

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components exposed tol hydraulic fluid, and requesting the vendor to' perform an on-site inspection.to confirm proper operation of_the

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0n May 24, before the vendor arrived, a second scram.due to a feedwater- valve failure occurred (LER 87-29). The valve failed

in .the open position, increasing the flow of feedwater, resultin in the. Average Power Range Monitor (APRM) automatically scramming the reactor when the flux' level teached the. indicated setpoin Corrective action: included replacing'a' faulty-(leaking) solenoid valve, replacing the control. circuit board (which was suspected to be' subject to intermittent . failure), and tuning the hydraulic uni The valve operated satisfactorily during tests following these repair activities. The ' failed control circuit. board was returned to the vendor for testing; a report from the vendor on this testing is due in' the latter part of June:1987. .

There was some question whether the corrective actions were~ complete and timely after the first scram, considering the history of sluggish behavior of the feedwater regulating' valve. However,'the licensee-had attributed the sluggish behavior to the low flow conditions that existed during this-time frame and the need for J additional tuning of the hydraulic unit for which they had requested

vendor representative assistance. - Corrective actions after the second scram appeared to be adequate. 'The feedwater regulating valve' is not safety related, but can cause reactor transients leading to reactor trip LERs 86-01, 07, 12, 18,.21,'87-13, 20, 24, 27,:and 30 address (16)

Reactor Water Cleanup System (RWCU) isolation events at Clinton.

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.Most of these events-involved a high differential flow signal occuring during low power operation, and over one third 'of the

. events involved personnel errors. This number of RWCU isolation events is typical of most new BWRs during startu Clinton was well aware of the differential flow problem at both its own plant and other BWRs. The licensee is aware of potential and actual hardware fixes being used by other BWRs which are applicable to its plant, such as resizing orifices, increasing time delays,

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adding density correction, and filtering of signals. The licensee is in contact with other new BWRs regarding.these changes, and are developing a plan to eliminate these isolations, but no schedules

.or deadlines have been prepared. The licensee's program which is a systemic' step by step approach for correcting high differential flow RWCU isolations at low flow / low power conditions appear to be adequate in light of the safety significance of these events, i

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l The personnel errors that caused RWCU isolations appear to be l

.mostly isolated incidents, with the exception of LER 86-018. In this event, the problem was related to lifted leads which is being addressed by a lifted leads task force as discussed in part e of

. this sectio Clinton has requested concurrence with an interpretation of the LER rule 10 CFR 50.73 and NUREG 1022 guidance that RWCU isolation at low reactor power and low feedwater flow rates be considered preplanned and therefore not reportable. The inspection team can not support this interpretation. Even though these events may be probable to occur at these conditions, they are not preplanned events. The licensee should continue to report these events. While continuing to report, Clinton may also request an exemption to the reporting requirements. Granting of exemptions to reporting requirements are the responsibility of the NRC Executive Director for Operation During the first two months (October and November 1986) following issuance of the low power license six LERs related to lifted leads occurred. The licensee's initial corrective action was contained in a November 19, 1986, memorandum from J. Wilson, the Plant Manager, to the plant staff and startup employees. This memorandum included Plant Manager Standing Order 30 (PMSO 30) which required a surveillance impact matrix to be completed prior to lift'ng leads, or installing jumpers or test equipment that could affect the circui Since the implementation of PMS0 30, only three lifted lead related events have occurred (LER 87-05, 87-16 and 87-21). LER 87-21 occurred because the surveillance impact matrix was not completed and j included with the procedure before the surveillance was performe '

In addition to the issuance of PM50 30 the licensee fonned a lifted leads task force which issued a report dated December 19, 1986, from J. S. Perry, Task Force Manager, to D. P. Hall, Vice President of Illinois Power. This report contained findings and recommendations ,

to eliminate this problem. During this inspection, the team l reviewed the status of the key recommendations contained in the task force report and found that the following additional actic's !

have been take The Licensing and Safety Department has developed a procedure (Licensing and Safety Procedure I.6) to review and correlate industry and NRC lessons learned. The licensee through its Independent Safety Engineering Group is also reviewing LERs from !

other utilities which would include those related to lifted leads (See Section 3 of this report).

A lifted lead point paper dated April 8, 1987, describes a plan to review plant panels and cabinets involved in surveillance and periodic maintenance to determine which, if any, require modification *

A reference matrix for instruments and signal transmitters which involve Technical Specification systems has been

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E developed to aid the operator in' determining what safety-

.actuations~ functions are affected by a: specific' instrumen *

Lesson plans have been developed and plant staff.. involved in checking circuit continuity, writing procedures, work documents, and plant modifications.. In addition, the plant staff have received-increased training in print readinef utilizing these lesson plan The April 8,'1987, point paper. discussed above, also contains the licensee's short term and long term corrective actions to establish an improved program to assure leads are lifted without inadvertent actuation .This program contains the following key elements:

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A computerized Technical Specification (TS) program which ties TS to the equipment. identification number and to the plant drawings and plant procedure *

Identification'of selected hardware modifications that would significantly. reduce the potential for accidental safety system actuation *

An independent review of maintenance and surveillance ' lifted leads procedure *

An examination of the effects of lifted leads and' jumpers in the balance of plant on reactor and plant operations'.

The. licensee has stated that except for modifications this program which is currently in progress should be completed by the end of the summe The inspectors believe that since the implementation of PMSO 30

'the licensee has gained control of the lifted lead problems which initially occurred and reduced the problem to an acceptable leve .

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The followup corrective action program by the licensee represents a !

significant effort and adequately addresses the recommendations of the licensee's lifted' leads task force. This program when fully

. implemented, should reduce this problem to a level where it should no longer be a staff concer f.- Specific LERs reviewed in the electrical area during the team l inspection included LERs 86-24, 86-21, and 87-16. In addition, the following seven CRs were reviewed: '1-87-02-048; 1-87-02-071; 1-87-02-121; 1-87-02-122; 1-87-03-018; 1-87-03-085; and 1-87-05-03 From'these reviews, the inspectors observed that CPS has suffered

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from most of the same problems that other new BWRs'have encountered '

and it did not appear that the licensee was initially aggressive in avoiding these problems. However, current programs such as the  ;

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lifted leads and jumpers effort indicates that the licensee is taking steps to address problems common to new 8WRs during initial operation Although the completeness of most LERs/CRs were commendable with very thorough investigation, root cause determinations, and followup including training, one exception was noted as follows:

It was discovered in the review of LER 87-16 that the instrument calibration which caused the wrong lead to be lifted, resulting in a RWCU isolation, was prompted by a confusing identification between the RWCU cells (pump room)

and the RWCU cell instrumentation. During the inspector's review of this LER, it was discovered that the confusing identification had not been corrected. The licensee committed to resolve this concern, and issued an interoffice memo on June 18, 1987, from the CPS Manager of Licensing and Safety

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to the CPS Manager of Nuclear Station Engineering, subject:

"RT Pump Room Labeling in the Control Room." Based on the licensee actions to resolve this issue, the inspectors have

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no further concerns in this are g. In review of CPS Technical Specifications (TS) and Limiting Condition for Operation (LCO) control LERs and CRs, an indepth review was conducted by the inspectors of several LERs and CRs. The following is a brief description of the events and the results of the reviews; (1) LER 87-03 concerned the detection of the unexpected isolation of the turbine first stage pressure transmitters from the Reactor Protection System (RPS) and from the Rod Pattern Control and Information System (RCIS) while the plant was at 13% powe The unexpected isolation was due to an incorrect valve lineup procedure resulting in the first stage pressure transmitter being valved closed. The valve lineup procedure had been corrected prior to the event but not implemented in the fiel CPS-TS 3.1.4.2, " Rod Pattern Control System", requires the transmitters to be operable in Operational Conditions 1 and CPS-TS Table 3.3.1.1, item 11, " Turbine Control Valve Fast Closure" also requires the transmitters to be operable in Operational Condition 1 with a note that the trip function shall be bypassed automatically at less than 40% powe The licensee's corrective actions included the preparation of Temporary Procedure CPS No. 1005.11 " Revisions / Changes to Valve Lineups or Electrical Lineups". This procedure facilitates informing the Shift Supervisor or Assistant Shift Supervisor of valve / electrical lineup changes and should ensure such lineups are performed with each valve lineup revisio This procedure was drafted for concurrence review within 8 days of the event. In addition, the licensee performed a review of all safety system valve lineups to assure that other similar valve lineup problems do not exist. With over 60% of the safety systems evaluated at the time of the inspection, about

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300 minor' discrepancies had been identified. None of the L discrepancies were reported to have any safety significance.

l .The. inspectors believe the licensee took appropriate' action-l 'to correct this proble .(2) LER 86-09 ' identified an operator' error during the performance of Automatic Depressurization System (ADS) surveillance

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procedure. CPS 9056.01- that resulted in a technical specifi-cation violation and identified a procedural. inadequacy that y> resulted in.an automatic ESF actuation. CPS TS 3.3.2 requires the operation of the standby gas treatment system.and the stopping of core alterations if more than the allowed number of ADS system channels is inoperable. The LER accurately-identified the root cause of the TS violation to be personnel error, it-inferred that the error was the result of an inadequate understanding of TS surveillance procedura ,

requirements. In this LER, performing the channel functional-test surveillance made multiple channels of two ADS trip system divisions-inoperable, causing an isolation. Containment isolation' valves actuated during this surveillance because procedures did not specify the correct electrical leads to be-lifte The licensee made appropriate TS revisions to clear up the requirements regarding action statements while in the core alteration mode. The licensee also revised the surveillance procedures to correct the electrical lead -identification error Although the licensee has procedures to require red line i entries into the shift supervisors log book to list TS inoperable systems or components, it does not have a formal system for tracking short term action statements such as when a channel is placed in the tripped condition for up to two hours for the purpose of surveillance testing. The licensee relies on administrative procedures to ensure short term action statements restrictions are me (3) The inspectors reviewed CR 1-87-02-031 which stated that TS LCOs 3.8.1.2 and 3.5.2 were entered to perform procedure CPS 9080.01 on the Division 1 Diesel Generator with Division 2 inoperable. The licensee restored the number of required subsystems to operable status within 3 3/4 hours. The TS limit is four hours. The CR was in accordance with procedure CPS 1405.02 which requires a CR to be written for each LC0 entry and' review for LER deportabilit I This condition report clearly stated that the reactor was in a stable condition at 0% power in Operational Condition 4. There appears to have been adequate controls for adhering to station procedures and the assessment of the deportability requirements were correc _

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7. Surveillance Testing and Calibration Control Program (61725) ,

The inspectors selected a representative Technical Specification (TS) required surveillance schedule to determine the adequacy of the licensee's program. The Emergency Core. Cooling System (ECCS) actuation instrumentation channel operability requirements of TS 4.3.3.1 were i selected. In particular, the Table 4.3.3.1-1 requirements for Suppression Pool Water Level input to the High Pressure Core Spray (HPCS) system were reviewed. Procedures reviewed included CPS 9030.01,

"ATM Channel Functional and Calibration Check Instructions", CPS 9433.17

"HPCS Suppression Pool Water Level E22-N055C(G) Channel Calibration" and CPS 9000.01, " Control Room Surveillance Log". These combined procedures fulfilled the TS required surveillance frequency for Channel Check, Channel Functional Test, and Channel Calibration. The procedures were well written and comprehensive. All aspects of functional and calibration testing were adequately covered by these procedure In addition to reviewing the surveillance testing and calibration control program, the inspectors' performed a plant walkdown and noted the tortuous vent path necessary to acequately purge many safety related differential

, cells. Numerous swedgelock fittings, bends and elbows appeared to  :

increase the probability of air bindin Couple these design flaws with differential cells that were found to be installed with the vent plugs inverted and the probability of air binding the cells following the 4

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performance of maintenance / surveillance procedures becomes high. When questioned on this issue, plant personnel confirmed the inspector's suspicion that technicians often must resort to " mechanical agitation" of the cell piping to ensure adequate venting is achieved. This is an undesirable compensation for a poor design / installation scheme. The licensee has recently instituted a forced fill procedure to alleviate this problem. This should prove to be an effective remed Additionally, installation of differential cells at elevations above normal working height (5 to 6 feet) can affect the process of obtaining accurate calibration data. Several cells were observed to be at heights requiring use of extensive ladders (15 to 18 feet) during performance of calibration procedures. This is a less than optimal situation for performing safety related surveillanc . Review of Field Problem Reports (92720)

The inspectors examined the use of Field Problem Reports (FPR's) during the inspection. The intended use of FPRs was for the plant staff to ask questions related to the design of Clinton. However, an Illinois Power Company Quality Assurance Audit of FPRs dated October 20, 1986 (Report 38-86-59) resulted in the following three findings:

The QA manual endorses FPRs as a nonconformance document, but no program has been developed to comply with Procedure CNP 3.02 on Corrective Actions; Nonconforming conditions are being documented on FPR; and

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Design changes are being made'outside the requirements of Procedure j CNP 4.05 concerning the Plant Modification Syste j-As a result of these findings, the following corrective actions taken'by ]

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the licensee were verified by the'. inspectors:

A memo from the plant manager (JWW-1895-86) was' issued to all CPS-department heads that emphasizes that FPRs.should not be utilized to-report nonconformances;-

A memo from the plant manager.'(JWW-2094).was issued to all-CPS c personnel. which emphasized that the use of FPRs to identify plant nonconformances was not in accordance with Plant Manager-Standing Order (PMS0-016). PM50-016 states that the use of FPRs does not relieve the originator of the responsibility to. identify nonconformance using Nonconforming _ Material Reports.(NCMR) or condition reports;:

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NSED is screening all FPRs for nonconformances. A' change.has also been made to NSED Procedure D.9 related to FPRs which requires'a-CR to be initiated if a problem is determined to be a nonconformance; and

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A revision to the QA manual has been initiated which will eliminate the endorsement of FPRs as a nonconformance documen =The inspectors believe that the corrective actions taken by the licensee were responsive to the QA audit findings and should eliminate the proble .- Summary of Observations ~and Conclusions (71707)- 1 The licensee was found to have a comprehensive and well-documented problem identification, analysis, and resolution program for plant event This program was found to meet regulatory requirements and have the necessary ingredients-to reduce the frequency of events and assure safe operation of the plant. Several important trending programs nist that identify material, administrative, and personnel weaknesses and request written corrective action responses by applicable department heads. Documentation of events and corrective actions, trend findings,

,

responses, and other related information was easily obtained. Action '

items were adequately tracked to assure timely response Interviews with plant staff, including management, technical, and operations personnel, and observations of a shift turnover and plant scheduling /statusing meeting revealed that upper management was actively involved in resolving plant events, and plant staff was knowledgeable of plant procedures and equipment and conducted themselves in a professional manne !

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10. ExitInterview(30703)

The inspectors met with the licensee representatives denoted in Paragraph I throughout the inspection period and during the exit held on June 19, 1987. The inspectors summarized the scope and results of the inspection and discussed the likely content of the inspection report. The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur