IR 05000461/1987030

Insp Rept 50-461/87-30 on 870804-0831.Violations Noted. Major Areas Inspected:Licensee Action on Previous Insp Items,Followup on IE Info Notices,Allegation Review,Ler Review & Followup & Monthly Maint Observation

ML20238E630
Person / Time
Site:	Clinton
Issue date:	09/10/1987
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20238E110	List: IR 05000461/1987030 ML20238E109 ML20238E112
References
50-461-87-30, IEIN-87-004, IEIN-87-010, IEIN-87-012, IEIN-87-10, IEIN-87-12, IEIN-87-4, NUDOCS 8709150111
Download: ML20238E630 (29)

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U.~ S.. NUCLEAR REGULATORY COMMISSION'

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h Report No. 50-461/87030(DRP) k Docket No. 50-461- License No. NPF-62 f(

Licensee: . Illinois Power Company 500' South 27th Street

.Decatur, IL' 62525

Facility.Name

Clinton Power Station Inspection At: 'Clinton Site, Clinton, IL Inspection Con' ducted: August 4 through 31, 1987

. . 1 Inspectors: P.~ Hiland ,

S. Ray M. McCormick-Barger B. Hasse Approved By:

f0 g R. C. Knop, Chief

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7~/O-'5/ ni Projects Section 1B Date

Inspection Suninary Inspection on August 4 through 31, 1987-(Report No. 50-461/87030(DRP))

Areas Inspected: Routine.. unannounced safety inspection by the resident .

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inspectors.and region-based inspectors of licensee action on previous 4 inspection findings; followup on IE information notices; allegation review;

'censee event report review and followup; monthly. maintenance observation; nanthly surveillance observation; operational safety verification; engineered safety feature system walkdown; training effectiveness; onsite! followup of events at operating reactors; and management meeting.-

Results: Of the 11 areas inspected, no violations or deviations were identified N 'mv areas. One violation was identified in the area of onsit'e followup vi - f paragraph 11.b.(4), failure to implemeNc maintenance -

. procedure), h .. e <esolved Items were identified; one in,the area of engineered safety system walkdown (paragraph 9.b.) and one in the area of onsite followup of events (paragraph 11.b.(11)). All of these items.cre-receiving licensee mancgement attention. Additionally 3 four Technical-Specification violations were identified in the onsite followup,sf events area for which a Notice of Violation was not issued in accordet.ce with

'10 CFR 2. Appendix C, Paragraph V (inadequate surveillance on' land use census - Paragraph 11.b.(1); IST stroking of three air operated valves -

Paragraph 11.b.(5); grab sam  ;

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> - Paragraph 11.b.(6)ples late in meeting

and missed required daily channel checks action required timeby of - 1 Technical Specification - Paragraph 11.b.(7).).

8709150111 870910 PDR ADOCK 05000461 G LPDR

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1; . sPersonnel Contacte'd

< % Tilino4 Power' Company (IP)

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~' 4 M . Baker, Supervisors'I&E. Interface, Licensing and Safety (L&S)

e W@ %y #T, Camilleri,' Manager e Scheduling 0utage, and Maintenance i6 J, *#R. Campbell, Man 6ger;--QA q '

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' *#W. Connell, Manager - Nuclear. Station. Engineering Department (NSED)

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1. J. Cook, Assistant Manager - Clinton Power Station-(CPS) i

• J.:Dodson,' Supervisor, Nuclear Commission-  !

.. *#R. Freeman, Ass.istant Plant Manager', Maintenance-

• *#W. Gerstner, Executive Vice President ,i

• 1. D. Hall, Vice President,. Nuclear -l

.D. Holesinger, Assistant Manager. .Startup

1. W. Kelley, Chairman,and President, Illinois Fower-

• J. Miller, Manager," Scheduling & Outage Management

• J. Palchak, Supervisor -' Plant Support Services W'

• J. Perry, Manager - Nuclear Program Coordination

• fF -Spangenberg, Manager - L&S o . *#J. Weaver,: Director - Licensing M *#J.-Wilson, Mana'ger - CPS

,j "#R. Wyatt, Director-Nuclear Program Assessment w, s Soyland/WIM2 y U #J.- Greenwood, Nnager Power Supply

Nuclear Regulatory Commission

• 1. P. Hiland, Senior Resident Inspector, Clinton

1. S. Ray, Resident Inspector, Clinton frM. McCormick-Barger, Project Inspector, Region III n

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1. R. Knop, Chief, Section 18, Region III

" #W. Forney, Chief,, Projects Branch 1, Region III

1. Denotes those attending the management meeting on August 27, 198 *DenotesthoseattqrdingthemonthlyexitmeetingonAugust 31, 198 The inspector also contacted and interviewed other licensee and

. contractor personne . 'Previously Identified Items (92701)(92702) (Closed) Open Item (461/86065-02): Actions Taken By Licensee To Improve Their Industry Experience Program.

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During a review of licensee action on I&E Information Notices, the inspector was advised that a management consultant had been retained

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by the licensee to review and make recommendations on potential

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y areas of improvement. - The _ inspector reviewed IP memoranda Y-203387, dated October 8, 1986, and Y-203409, dated 0ctober.10, 1986, which documented the recommendations made for program improvement and the actions taken by the licensee to incorporate those recommendation Specifically, the-following programmatic improvements were

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implemented:

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The Licensing Department was to coordinate the review and

, disposition of less complex documents via teleconference with working level engineers.-

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The Licensing Department was to review all outstanding documents to determine which could be closed by a single departmen The Licensing Department was to prioritize industry feedback material'in accordance with the licensee's Corporate Nuclear-Procedure For complex documents the Licensing Department was to prepare a summary or annotate the significant portions of the document to aid the review proces Based on the above review, the inspector concluded that the licensee had acted upon the recommendations to improve their industry

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feedback progra The impact these improvements have on the licensee's industry feedback program will be reviewed on a routine basis by the inspector (e.g., paragraph 3. below). This item is close b. (Closed) Open Item (461/86072-01): Control of Measuring and Test Equipment (M&TE).

This item was previously reviewed as documented in Inspection Report'

50-461/87015, paragraph 2.b. At the time of that review, this. item remained open because of late responses to the Use History Analysis (UHA) log.- The UHA log was the administrative mechanism defined by CPS No.' 1512.01, " Calibration and Control of M&TE" to describe actions that were to be taken when an M&TE was found to be out of calibratio The inspector noted that the licensee received responses from the responsible departments for the late UHAs identified during the i previous review. In-addition, the licensee performed an audit of Plant Staff's compliance to CPS No. 1512.01. The inspector reviewed audit report Q-38-87-28, dated June 19, 1987. The results of that audit report indicated that the licensee had taken appropriate action in accordance with CPS No. 1512.01. Based on the review performed, the inspector concluded that the control of M&TE was in accordance with the applicable procedures. This item is close Q ,c

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Y ., 9 (Closed)OpenItem(461/87007-01): Shift of High Pressure Core Spray (HPCS) Suction Due To Failed Analog TriF Module (ATM). J The licensee huf identified the root cause for an automatic shif t of the HPCS se/ction on January 9,1997_, .to have been a failed ATt '

Previjus to that event, the licensee h6d repurted via LER N t 86'20-00 3 EPCS suction valve shift op November 11, 1986, that was

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suspected to be due to rust particulate in the storaga tank level transmy %er '

E E4 The licensee reviewed tip maintenance troubleshooting that wrs performed following the HPCS suction valve shift reported via LER No. L6-20 oco That review noted that the ATM failure that occurred t'

on Janue.y 9,1987, was not identified as a problem following the November 11, 1986, event. The lfcensee was not able to' determine if the ' ATM failure on January 9,1987,. contributed to the first event j

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Based on the reviews. performed by the licenseeland clnce no similar

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events have occurred since January 9, 1987, the. inspector concurred with the licensee's conclusion that the problem had been resolve This item is close .

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l d .- ddlosed) Violation (461/F7006-01A(DRS)): Failure To Take Corrective  !

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Action For A Deficiency :'dantified In Condition Report fj -

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'(CR)1-86-$16 ,' , ,

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) .The-CR had identified seven surveillance procedures that had been i impacteG'by two modifications; however, the irnpact had not been

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identified on the " Detailed Impact A s sment Form" which provides t

,the vehicle for identifying such impact. The licensee invalidated

the CR on the basis that the modifications were still open and the fi@act had subsequently been identified. The root cause for the i failure to identify the impact daring the impact assessment and reouired corrective actions was not addressed. The inspector reviewed the actions taken in response to the violation. The CR had been r.eopened and the root cause (inadequate training) determine l The process of impact assessments was stocoed until the personnel performing the assessments had been trafned. Previously closed -

modifications were reassessed for impact., Further, QA and compliance persor.nel were trainei on their responsibilities for l assuring that invalidation of d CR was adecuately justifie Previously invalidated CRs were then reviewad to determine if they i were adequately justified. No problems were found. The inspector reviewed the documentation of these actions and determined that the actious taken were adequate to close this itera. This item is close ' (Oren) Violation (461/87006-02(DRS)): . Failure To Frepare E0Ps In Accordance With The P-STG And Control Change The licensee had previously corrected safety significant deficien-cies in the E0Ps identified by the NRC as rned in Inspection a

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• .' Report 50-461/87015(DRP). The' inspector reviewed the current

! revision (Revision 2) of the P-STG to determine if the' require Trevisions resulting from the NRC inspection and the licensee's

."Tabletop": review had been incorporated. The NRC identified changes

.i; had been; incorporated; however, the inspector identified two changes required by the stabletop review that had not been incorporate '

l The inspector's review 'of the " Tabletop"; items included only three ;

of the five E0Ps. The remaining two contained changes not i e

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-incorporated into the.P-STG. >The items identified by the inspector had minor safety significance. The items.were: '(1) E0P 4403.01, Step 4.1'.9, requ? rod RPV iidection water, temperature to be main-

tained above 70 degrees Fahrenheit while the P-STG required maintaining the-RPV water temperature above 70 degrees. Fahrenheit

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(the E0P is the most conservative); (2).the caution preceding Step 3.1.1.of E0P 4406.01 is not the same as that in the P-STG (no intent change involved). . Th'e inspector identified one additional discrepancy.between,the E0Ps and Revision 2 of the P-STG: The

'E0Ps' required a minimum suppression pool, level of six feet before

.using the SRVs or ADVs for RPV depressurization while the P-STG required a minimum of eight feet. The limitation was based on

'the level of the'velve discharge spargers in the suppression poo The licensee stated that the level given in the E0Ps was. technically-correct (the spargers'would be covered at this level); however, the verification / validation effort determined that the minimum level readable on.the control room. instrumentation was eight fee .'

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The P.-STG.was changed in Revision 2 to.' reflect this fact. The

.EOPs were to'be changed via revisions currently in progres ;

.This item wi.11 remain open pending the licensee's completion of the P-STG and E0P changes and the NRC review of these action i (Closed) Open' Item (461/87006-05(DRS)): E0P Training Program Not Constrained By. Commitments Made In The Procedures Generation l Package.

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The inspector reviewed lesson plans 95503, " Principles with j Emergency Operating Procedures", Revision 2, and 95002, "SPDS",

, Revision 2. The reference section of the lesson plans included the

.PGP with a notation that it was not to be removed since it contained commitments relating to the training nrogram. The inspector was I satisfied that this would preclude inadvertently deleting PGP ,

requirements from the training program. This item is considered close )

No violations or deviations were identifie >

1 Followup on IE Information Notices (92701) J

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For each of the IE Information Notices discussed below, the inspector verified that the licensee had received the Information Notice, had distributed the Notice to appropriate personnel, had reviewed the-Notice for applicability, and, if applicable, had scheduled or completed 1 appropriate corrective action j 5 I i

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,. - a. '(Closed). Information Notice No. 87-04 (461/87004-NN): Diesel

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Generator Fails Test Because Of Degraded Fue This Information Notice was received by the licensee on January 23, 1987. Following' receipt, the licensee, assigned review responsibility in accordance with Licensing and Safety Procedure L.1, " Feedback Program". IP Review Sheet Y-204058, dated January. 27, 1987, assigned responsibility for review to the l Clinton Plant Staff with a review due date of March 13, 198 l i

IP memorandum K. Stokes to B. Green dated June 1/, d87, documented

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the review performed by plant staff. The review concluded that based on existing programs detailed in Chemical Procedure CPS N .{

6001.01, " Sampling and Analysis Requirements" and Surveillance y Procedure CPS No. 9281.05, " Emergency Diesel Fuel Oil Storage Tank 1 Cleaning" no further action was required to address the subject Information Notice. That review also concluded that no additional h maintenance was required on screen elements in the Y-strainer .

The inspector noted that the response by' plant staff was provided three months beyond the requested review due date. Prior to this report period, the inspector:also noted that increased management attention was being. focused on improving response times.to this type of review. The licensee was tracking all I&E issues against a planned schedule at their weekly management meetin Based on the inspector's review of licensee action in response to this 1 Information Notice and the increased management attention focused on all I&E issues, this item is close I . (Closed) Information Notice No. 87-10 (461/87010-NN): Potential For Water Hammer During Restart Of Residual Heat Removal Pump This Information Notice was received by the licensee on February 19, 1987. Following receipt, the licensee assigned review respons-ibility in accordance with Licensing and Safety Procedure L.1,

" Feedback Program".- IP Review Sheet Y-204281, dated February 23, 1987, assigned responsibility for review to Clinton Plant Staff, Nuclear Station Engine 3rirq Department, and Nuclear Training {

Department with a review te date of April 10, 198 IP memorandum Y-83831, dated March 24, 1987, documented the review performed by the Nuclear Station Engineering Department. That

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9 review discussed the actions that had been taken by the licensee in response to NRC Engineering Evaluation No. AE0D/E309 referenced in the Information Notice. The licensee's evaluation of AE0D/E309 was performed in 1983 and documented in Condition Report 1-83-09-01 The licensee. concluded that Clinton Power Station was susceptible to the water hammer event and implemented administrative controls in Operating Procedure CPS No. 3312.01, " Residual Heat Removal".

The inspector verified that CPS No. 3312.01 contained the controls established by the licensee's previous review (ref: CPS N i 3312.01, paragraph 11.28).

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IP memorandum CHM-87-019, dated April 24, 1987, documented the l review performed by Clinton Plant Staff. That review concluded )

that no further action on this Information Notice was required j based on the actions taken, as discussed above, in response to AE0D/E30 Nuclear Training Department (NTD) Tracking Number 131, dated

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. July 20, 1987, documented the NTD review performed and action to be taken in response to this Information Notice. The review ;

assigned a Training Deoartme,et evaluator te perform impact evaluation on Lesson Plan No. 95066 with an expected completion date of March 31, 198 Based on the licensee review of this Information Notice and the inspector's verification that procedural controls had been implemented, this item is close (Closed) Information Notice No. 87-12 (461/87012-NN): Potential Problems With Metal Clad Circuit Breakers, General Electric Type AKF-2-2 This Information Notice was received by the licensee on February 23, 1987. Following receipt, the licensee assigned review respons-ivility in accordance with Licensing and Safety Procedure L.1,

" Feedback Program". IP Review Sheet Y-204319, dated February 27, 1987, assigned responsibility for review to the Clinton Plant Staff and the Nuclear Station Engineering Department with a review due date of April 10, 198 IP memorandum K. Stokes to B. Greene, dated July 10, 1987, documented the Clinton Plant Staff review of this Information Notice. That review identified one application of the AKF-2-25 breaker at the Clinton Power Station. The one AKF-2-25 breaker was classified as non-safety rMated and was located in the SCR monitoring panel for the altarrix excitation system. Plant Staff was directed to initiate two Preventative Maintenance (PM) items !

for the AKF-2-25 breake The PMs developed follow the guidelines provided by General Electric in Service Information Letter (SIL)'

44 Commitment Tracking item (CCT) 044396 was initiated to track development of the P CCT 044396 was completed July 22, 198 ,

IP memorandum Y-84053, dated April 10, 1987, documented the Nuclear Station Engineering Department (NSED) review of this Information Notice. The NSED review also concluded that one non-safety related application of the AKF-2-25 breaker was present at Clinton Power Station. NSED revised Turbine Generator Instruction Manual K2804-007B to include the maintenance and lubrication procedures provided by GE SIL-44 Based on the licensee reviews of this Information Notice and development of PMs for the AKF-2-25 breaker in use at Clinton Power Station, this item is closed.

l-l No violations or deviations were identifie i

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4. _ Review-of Allegations (99014)'

a._ 1(Closed) Allegation (RIII-86-A-0200/#210): On April 8, 1987, Region m: III submitted the following employee concern to Illinois Power Companyi(IP) for their investigation and disposition. On May 17, 1987,'IP' notified Region III by-letter U-600930 that their review and followup was complete. The inspector' reviewed IP's response-to~the concern as. documented belo Concern Work instructions and procedures do not always agree. An example'

was given of a maintenance work request calling for the installation of a " pancake" flange. The procedure:specified a " blank" flang Review IP's review concluded that the use of " blank" or " pancake" flanges is not considered a conflict since " blank, pancake, lollipop and Dutchman" are al1~ slang terms for a blind flange. To avoid confusion maintenance planners were instructed to use standard terminology in'

maintenance work requests (work instructions).

Illinois Power Company's review concluded that existing maintenanc procedures provided adequate reviews of Maintenance Work Requests-(MWRs) to assure agreement with established procedures. The_IP review described MWR processing as follows:

Upon receipt of a maintenance request, an MWR is job-stepped by Maintenance Planning.. In preparation, Maintenance Planning uses approved vendor manuals and/or procedures relative to the job. The MWR is then reviewed by NSED to ensure all maintenance requirements are adequate. If the work is

" quality related", the MWR is reviewed by Quality Operations

and Maintenance 10 ensure all controls and QA requirements are met. If required, QC inspections are conducted in the field and a post work review is conducted which includes Q The inspector verified that the above statement was consistant '

with Clinton Power Station Procedure CPS 1029.01, " Preparation and Routing of Maintenance Work' Requests," Revision 17, dated April 17, 198 Should a situation arise where a maintenance work request conflicted with an existing maintenance procedure and both documents were of the same hierarchy,- technicians were instructed to contact their supervisors to obtain resolutio Conclusion Given the general nature of the allegation, the portion stating that instructions and procedures do not always agree, could not be substantiated. The portion of the allegation implying that pancake

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. flanges- differ from blank' flanges was not substantiated.in that j these' were merely different. terms for the same. thing. IP's review ,

and followup actions satisfactorily addressed this allegatio ..This allegation.is close b. L(Closed) Allegation.(P.III-87-A-0061/#215): On ilune.1,1987, Region

'III submitted the following concern to. Illinois Power (IP) for their

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investigation and disposition.,On July 28, 1987, IP notified Region ,

III by letter'U-600994.that their review and followup was complet I

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The;inspec. tor reviewed"IP's response to the concern as documenteo

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Concern An ' individual, who was involved in falsification of Quality Control-(QC)recordsattheTrojanNuclearPlant'in1986,previouslyworked at the Clinton Power Station during 1985. A review was conducted to l determine whether or not the duties performed by the individual at the Clinton Power Station adversely affected plant qualit Review The inspector reviewed the licensee's letter, seven Conduit &

Raceway Electrical Travelers that the individual had worked on, documentation of the licensee's reinspection of the accessible attributes of the work associated with the aforementioned seven travelers, and performed an inspection of several of the accessible attributes of one of the seven traveler The inspector determined the following:

(1) The individual named in the allegation had worked at the Clinton Power Station (CPS) for about nine months during 1985 as an Electrical QC Inspector. Since the work performed by the individual prior to September 1985 was subject to an overinspection effort, IP reviewed 600 of the approximately 6000 Conduit ar.d Raceway Electrical Travelers implemented between September 1985 and the date when.the individual's term of employment at CPS ended. This review identified seven travelers that the individual worked o (2) The licensee's reinspection found all accessible attributes of the seven travelers to be acceptabl (3) The accessible attributes of Traveler E29-1001-01A-WCA-F-8E, which the inspector verified by direct inspection, were

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acceptable, h Conclusion

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This allegation was substantiated only to the extent that the individual worked at CPS in 1985. Based on the sample reinspection

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-of.'the individual's work, it was concluded that the. inspections performed by the individual at CPS-had no adverse impact on qualit This! allegation is close ' (Closed)-Allegation (RIII-87-A-0109;1218):-OnJuly 17, 1987, the inspector received an anonymous allegation that a "non-certified welder-fitter" was welding in the' Teamster's Fab Shop outside the protected area. The anonymous alleger further stated that the

"non-certified welder-fitter" was an employee of an onsite

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contractor, Collup Construction Compan .

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NRC Review and Results i The above allegation was discusrad between the inspector and Region III. management on July 17. The licensee was asked to conduct an inspection of activities being performed by Collup Construction

' Company. Monitor Report No. 87-07-131, dated July 22, 1987, documented the results of the licensee's- inspection which concluded that. work being performed by.Collup Construction was restricted.to

'"non-plant" related activities-(e.g. lawn mower repair, off-road equipment repair, etc.). The licensee identified that weld rod

'being used by Collup Construction Co. was not being stored in a-

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' tightly controlled manner and.took action to require weld rod.to be placed in locked: storag On July 23., 1987, the inspector received a telephone call from the

.same. individual that had initially called on July 17. During that conversation, the individual stated that the inspection performed by the licensee was deficient since they did not interview any of the Collup Construction craf The inspector conducted an unannounced inspection of the Teamster's !

Garage on July 23, 1987, to verify the accuracy of the licensee's ;

inspection report and to personally interview Collup Construction craftsmen. The inspector verified by interviews and direct 1 observations that the activities being performed by Collup Construction were as described by the licensee's reports. During y interviews of Collup Construction craftsmen, the inspector noted that welding activities being performed were limited to repairs of lawn mowers, off-road equipment, and some storage rack None of the activities described through those interviews or observed by the inspector appeared to be on plant equipment. The. inspector toured the Teamster's Garage, which was the primary work location for Collup Construction, to confirm that weld rod being used was under control'as described in the licensee's monitor report. The inspector did not find any loose weld ro During the inspector's interview with the Collup Construction h craftsmen, one individual disclosed that he had been welding on j a pipe about two weeks prior in a site Fabrication Shop. The '

individual stated that he was "just practicing" how to wel However, ne went on to state that when asked by another individual

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what he was doing, he' replied to that individual that he was making a " Flush Pipe". The inspector requested the individual to accompany him to that Fabrication Shop and point out s' specifically where the

. pipe came from, where he " practiced" welding, and where he.placed ,

, the. pipe. The' inspector-conducted a tour of the Fabrication Shop )

Eand noted that what used to be the'Pipefitter's Fab Shop during 1

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construction was being' used as a Fab Shop for "non-safety" activities on site (e.g., making handrails for walkways). The

. inspector noted that there was a large amount of waste pipe material (non-sc.fety) readily available for the type of activity described b the individual. The inspector also noted that a scrap dumpster was-located in the immediate area. The individual' stated that when he completed his welding practice, he disposed of the pipe in the scrap dumpster. The inspector conducted an inspection of the Fab Shop and did not identify any loose weld rod in the area. The activities being conducted at that Fab Shop did not appear to be safety relate Following the formal exit for the report period, the inspector was advised by the licensee that additional information concerning this allegation was available. Specifically, the individual discussed above had made the statement that he was "just practicing" how-to weld was incorrect. In fact, the individual had welded pipe for use at.a sedimentation pond pump house located outside the protected'

area but within the' owner controlled area. On September 3, 1987, the inspector, accompanied by the licensee's QA manager, performed an inspection of the sedimentation fhcility. The inspector noted that the pipe welded by the "non-certified" welder was used in a non-safety application. The welds observed appeared to be of poor quality; however, no impact on permanent plant equipment was possibl Conclusion This allegation was substantiated in that a non-certified welder was welding pipe. However, based on the interviews and observations discussed above, the inspector concluded that there was no safety significance to this allegation. Specifically, Collup Construction does not perform any safety related work or work on permanent plant equipment; inspections conducted at the Teamster's Garage (Collup Construction Work Area), at the Pipe Fab Shop (area where the individual welded pipe), and at the sedimentation pond pump house did not identify any safety related work or work on permanent plant equipment. This allegation is close : No violations or deviations were identifie . Onsite Followup Of Written Reports Of Nonroutine Events At Power Reactor Facilities (92700)

For the LERs listed below, the inspector performed an onsite followup inspection of the LERs to determine whether response to the events were adequate and met regulatory requirements, license conditions, and

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- commitments and to determine whether the licensee had taken corrective actions as stated in the LER a. . IClosed).LERNo. 86-007-00 (461/86007-LL): Reactor Water Cleanup System Isolat 4n Due to High Differential Flo This LER was previously reviewed as documented in Inspection Report 50-461/86072, paragraph 6.b.(2) At the time of that review, this LER remained open pending the inspector's review of an approved corrective accion plan for Condition Report (CR) 1-86-09-039 which'

.was directly. related to this LER. In addition, verification that corrective action was completed for this LER was require During the report period, the inspector reviewed CR 1-86-09-039 and

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noted that an approved corrective action plan had been initiated to revise. twelve system operating procedure Those' revisions were to incorporate instructions for Filling, Venting, and Draining of system piping as required by ANSI N18.7. -The inspector's review identified that six of the twelve system operating procedures had not been revised to incorporate filling and venting instruction However, the licensee had revised Administrative Procedure CPS N ,

1401.01 " Conduct of Operations", to include generic instructions for filling, venting or draining fluid systems. The licensee was reviewing the need to revise the six remaining system operating )

procedures based on the revision that had been incorporated in CPS i No.-1401.01. The inspector concluded that the approved corrective action plan identified in CR 1-86-09-039 was being-implemented and

.that the licensee's ongoing review to determine if the six remaining .,

procedural revisions'were still required was in accordance with the licensee's corrective action progra ]

The inspector confirmed that the corrective actions as. stated in LER No. 86-007-00 had been completed by review of the following:

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Surveillance Procedure CPS No. 9015.01, " Standby Liquid Control System Operability", revision 25, dated February 27, 1987, provided instructions to ensure the Reactor Water Cleanup isolation valves did not isolate during the conduct of the surveillanc Operating Procedure CPS No. 3303.01, " Reactor Water Cleanup (RT)", revision 9, dated July 31, 1987, provided a " CAUTION" to ensure system was filled and vented after a system isolatio Nuclear Training Department lesson plans for Standby Liquid Control (SLC) (#74038) and Reactor Water Cleanup (RT) (#74039)

were revised to incorporate training on the interlock between l the SLC and RT system An engineering review, documented in IP memorandum Y-84732, dated June 11, 1987, concluded that administrative controls that had been established were sufficient, and a plant modification was not warranted.

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Based on the inspector's review si the approved corrective action plan in CR 1-86-09-039 and the verification that corrective actions stated in LER 86-007-00 had been completed, this LER is closed, (Closed) LER No. 86-004-00 (461/86004-LL): Unplanned Automatic Initiation Of Standby Gas Treatment System Due To Inadequate Procedure This LCR was previously reviewed as documented in Inspection Reports 50-461/87002, paragraph 5.b.(1); 50-461/86072, paragraph 6.b.(1);

and 50-461/86065, paragraph 6.b.(1). At the conclusion of those reviews there was an Open Item (461/87007-02) that concerned the use of unannunciated trip seal-in logic. That Open Item was reviewed and closed by the inspector as documented in Inspection Report 50-461/87031, paragraph IP memorandum Y-83793, dated March 23, 1987, documented the licensee's engineering evaluation of the unannunciated trip seal-in logic. That evaluation concluded that procedural changes were adequate to_ prevent inadvertent actuation of the Standby Gas Treatment system. The inspector confirmed that Surveillance Procedure CPS No. 9920.72, " Channel Functional Testing Of Safety Related Process Radiation Monitors", revision 20, dated April 30, 1987, provided explicit instructions to prevent an inadvertent actuation during the surveillance performanc Based on the previous closure of Open Item 461/87007-02 and the inspector's verification that corrective action was completed, this LER is close No violations or deviations were identifie . Operational Safety Verification (71707)

Inspections were routinely performed to ensure that the licensee conducts activities at the facility safely and in conformance with regulatory requirements. The inspections focused on the implementation and overall effectiveness of licensee's control of operating activities, and the performance of licensed and nonlicensed operators and shift technical advisors. The following items were considered during these inspections:

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Adequacy of plant staffing and supervisio l

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Control room professionalism including procedure adherence, operator attentiveness and response to alarms, events, and off normal i condition Operability of selected safety-related systems including attendant alarms, instrumentation, and control Maintenance of quality records and report !

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. The inspections included direct observation of activities, tours 'of the-facility interviews and discussions'with licensee personnel, independent verification'of safety system status and limiting conditions for operation.(LCO), and review of facility procedures, records, and report On' August 4,1987, the licensee entered a Limiting Condition for Operation (LC0-87-8-10) when preventative maintenance was performed on Residual' Heat Removal system train B (RHR-B). About 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after initial entry into the'LCO, the licensee identified that the RHR-B minimum flow valve IE21-F064B was not closed in accordanc with the action statement requirement of Technical Specification 3.6.4. The licensee's'immediate action was to close manual isolation valve IE21-F018B which satisfied Technical Specification 3.6.4, Action The RHR-B minimum flow valve (1E21-F0648) was a duel function valve intended to provide a minimum flow' path for the RHR-B pump and to provide containment isolation via remote-manual operation.- In addition to the remote-manual motor operated valve (1E12-F0648),'a second containment isolation barrier consisted of the piping outside of the containment which was a closed loop (CLOC).-

The licensee reviewed the events discussed above and concluded that the Technical Specification 3.6.4 Action a.3. required for valve

.IE21-F064B being inoperable (i.e. the power source had been tagged out upon initial entry into the LCO) was-being met.by the Closed Loop Outside. Containment barrier-provided. The_ licensee discussed this interpretation with the NRR Project Manager,' Mr. A. Wang and others of the staff on August 20, 1987. The' staff agreed that the licensee had not operated in a condition prohibited by plant Technical Specification. However, the inspector noted that the interpretation on satisfying Technical Specification 3.6.4. Action a.3. by use of a Closed Loop Outside Containment was'not contained in the Technical Specification. This will remain an Open Item pending more explicit guidance.from NRR to Region III on this interpretation (461/87030-01).

7. Monthly Maintenance Observation (62703)

Selected portions of the plant maintenance activities on safety-related systems and components were observed or reviewed to ascertain that the activities were performed in accordance with approved procedures, regulatory guides, industry codes and standards, and that the performance i of the activities conformed to the Technical Specifications. The ,

inspection included activities associated with preventive or corrective maintenance.of electrical, instrumentation and control, mechanical equipment, and systems. The following items were considered during these i inspections: .the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibration was performed prior to returning the components or systems to i

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. service; parts and materials. that were used were properly certified; and maintenance of appropriate fire prevention, radiological, and housekeeping condition The inspector observed / reviewed the following work activities:

Maintenance Work Request'N ' '

Activity C-37334 Post Modification Test PR-20 C-36545 Panel Verification Discrepancies C-36563 Panel Verification Discrepancies C-51002 Inspect / Rework Linkage on Recirc Flow Control Valve 1833-F060B C-40957 Troubleshoot Response Problems with 1 Recirc Flow Control Valve 1833-F060A No violations or deviations were identified, i Surveillance (61726)

An inspection of inservice and testing activities was performed to ascertain that the activities were accomplished in accordance with applicable regulatory guides, industry codes and standards, and in i conformance with regulatory requirement Items which were considered during the' inspection included whether adequate procedures Mere used to perform the testing, test instrumentation was calibrated, test results conformed with technical i specifications and precedural requirements, and that tests were performed .

within the required tire limits. The inspector determined that the test j results were reviewed by someone other than the personnel involved with l the performance of the test, and that any deficiencies identified during the testing were reviewed and resolved by appropriate management j personne J J

The inspector observed / reviewed the following activitie ,

. Surveillance / Test i Procedure N Activity f

CPS No. 9432.10, Rev. 32 CRVICS AND MAIN STEAM TUNNEL DIFFERENTIAL TEMPERATURE E-31-N605B and F CHANNEL {

FUNCTIONAL No violations or deviations were identifie . Engineered Safety Feature System Walkdown (71710)

f The inspector performed a walkdown of the accessible portions of the Low !

Pressure Core Spray (LPCS) system during the report period to verify the system status. At the time the walkdown was performed, the licensee had l

identified the LPCS system as an operable Emergency Core Cooling system meeting all the requirements of the plant's technical specifications.

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s' , :For the purpose of this walkdown, the; inspector utilized the~followin L isystem drawings and. the checklists. contained 1n the system operating and 1 g* surveillance procedures.;

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-: CPS No. 3313.01V001, revision.6, LPCS Valve Lineup )

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. CPS No. 3313.01V002, revision 3, LPCS. Instrument Valve Lineup ]

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CPS No. 3313.01E001', revision 6, LPCS Electrical Lineup j!

' CPS No.L 9061.05D001, revision 23. Containment and Drywell Test

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l Connection, Vent and Drain Valves - Monthly -j

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CPS No. 9061.05D002,-revision 23, Containment and Drywell Test Connection, Vent and Drain Valves - Quarterly  :

- P&ID M05-1073,, sheet 1, revision Y For?the inspection performed, the following attributes were observed: l

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Hangers:and-supports were made up properly and aligned correctl l

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Housekeeping land cleanliness were' adequat ,

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Valves in'the system were installed correctly and did not exhibit !

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leakage or mechanical' problem (One valve and oae.pipecap were not !

installed and'are' discussed below).

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No prohibited ignition sources or flammable materials were in the !

vicinit Major system components were properly labeled, lubricated and cooled, and no. leakage existe Interiors of electrical and instrumentation cabinets were free of i debris, loose material, unco'ntrolled jumpers, with no evidence of l rodent '

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Instrumentation was installed and functioning and exhibited normal expected value Instrument calibration dates were curren Support systems essential to system actuation or performance were operationa ;

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Valves were in their proper positions and . locked where required and system lineups matched plant' drawings. (Exceptions are discussed

.- below.) 1 During the walkdown, the following discrepancies were noted with the valve lineup procedures:

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i (1) Valves 1E21-F013, IE21-F014, 1E21-F331, 1E21-F346, 1E21-F347, 1E21-F356A, iE21-F3568, and IE21-F358 were all listed as

" closed" on valve lineup CPS No. 3313.01VD01. These valves i were listed as containment. isolation valves on Table 6.2-47 of l the CPS Final Safety Analysis Report (FSAk) and Table 3.6.4-1 j of CPS Technical Specification. CPS FSAR Section 6.2.4.3.1-required that non-powered containment isolation valves be locked'in position. The accessible valves appeared to be ,

locked closed on field verification and were checked " locked closed" in surveillance CPS No. 9061.050001 or 9061.05000 The normal system valve lineup checklist did not reflect the desired locked closed position of these valve i I

(2) Valves 1E21-F351 and 1E21-F352 (LPCS Water Leg Pump Suction j'

Pressure Gauge Root Velves) were shown to be normally closed on P&lD M05-1073, sheet 1 and on valve lineup CPS No. 3313.01V00 .

They were also required to be left closed after the performance 4 of surveillance CPS No. 9052.01 and appeared to be closed during the walkdown. These same valves were shown to be t nomally open on instrument valve lineup CPS No. 3313.01V00 '

The normal instrument valve lineup checklist did not reflect

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the desired closed position of these valve ;

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(3) Valves 1E21-F349A,' 1E21-F3498, 1E21-F350A, and 1E21-F350B were shown to be open on valve lineup CPS No. 3313.V001 but were showr to be closed on P&ID M05-1073, sheet 1. These valves j were required to be left closed after the performance of j surveillance CPS No. 9052.01. The valves all appeared to be a'

open during the walkdown. The valve lineup procedure did not appear to show the correct position of the valve (4) Valve IE21-F353 was shown to be open on valve lineup CPS N l 3313.V001, but closed on P&ID M05-1073, sheet 1. The valve j appeared to be closed during the walkdown. The valve lineup ;

procedure did not match the P&I (5) Valve IE21-F368 appeared on P&ID M05-1073, sheet 1, but was not i listed on valve lineup CPS No. 3313.V001. The valve did not !

appear to be installed during the walkdown. The valve should ,

be installed and added to the lineup or removed from the P&I (6) P&ID M05-1073, sheet I shows a pipe cup installed downstream of High Point Vent Valve 1E21-F361. During the walkd wn the inspector noted that the pipe cap was missin For items a(1) through a(6) discussed above, the inspector noted l that these items did not impact the operability of the Low Pressure l Core Spray system. The discrepancies noted dealt with a local suction pressure gauge placed in service only during the conduct of a surveillance or dealt with interrelated proce h es/ drawing details considered minor. However, the inspector ducussed with

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' discrepancies.. Items a(1) through a(6) above are considered'an in Open' Item'(461/87030-02).

b .- -Infaddition to the discrepancies discussed above, the following 1 ~was identified:

m, -(1)' Revision'6 to CPS No. 3313.01V001 was incorporated on July 31, 1987. Documentation could not be found that an evaluation of-the change was conducted by the Shift Supervisor as was-4 required by Temporary Procedure CPS No. 1005.11, revision 0, dated June 23, 1987. -CPS No. 1005.11 was developed as a corrective action to Licensee Event Report No. 87-033-00 in which valves were added to a lineup during a revision but the revised valve lineup was not evaluated to determine if it<

should be performed. ' CPS.No. 1005.11 required that whenever a valve lineup procedure was' revised, form CPS No. 1005.11F001 should be filled out and signed by the' Shift Supervisor to Ldocument that the' revision was evaluated for impact of.the changes and determination of valves that would need to be' lined up. Form CPS No. 1005.11F001'should have been filed in the vault along.with the valve lineup ~ revision documentation, but was not ther >

'the inspector also noted that temporary procedure CPS No. 1005.11 expired on August-1,1987, but a permanent procedure had not been developed to incorporate.its provision Failure of the licensee to perform the evaluation required by CPS No. 1005.11 did not appear to impact the operability of the Low Pressure Core system since the changes incorporated in revision 6 to CPS No. 3313.01V001 were minor and dealt with a local suction pressure gauge placed in service only during the conduct of a surveillance. Discussions with the' licensee n indicated they were aware of problems with implementing CPS N .11 and had been taking additional corrective' action. The licensee's failure to implement CPS No. 1005.11 as discussed above in item b(1) is considered an Unresolved Item pending

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further review by the inspector of the licensee's corrective  !

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action (461/87030-03).

In conjunction with the above, the inspector reviewed the results of I current surveillance performed on the LPCS system to verify technical specification requirements were met. The following surveillance test results were reviewed:

Surveillance N Title Frequency Test Date-l -'. CPS No. 9052.01 LPCS OPERABILITY Quarterly July 7, 1987 p CHECKS f CPS No. 9052.02 LPCS VALVE Quarterly July 7, 1987

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OPERABILITY CHECKS l

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The inspector concluded that the LPCS system was operable based on direct field observations of the above lineups and inspection attributes. In addition, the inspector's-review of current surveillance tests for the LPCS system indicated the plant's Technical Specifications were being me 'One unresolved item and one open item were identifie ,

10. Training and Qualification Effectiveness (41400 & 41701)

The. effectiveness of training programs for licensed and nonlicensed personnel were reviewed by the inspector during the witnessing of the licensee's performance of routine surveillance, maintenance, and operational activities and during the review of the licensee's response to events which occurred during the month of August 1987. Personnel appeared to be knowledgeable of the tasks being performe No violations or deviations were identifie . Onsite Followup of Events at Operating Reactors (93702) General The inspector performed onsite followup activities for events which occurred during the inspection period. Followup inspection included one or more of the following: reviews of operating logs, procedures, condition reports; direct observation of licensee actions; and interviews of licensee personnel. For each event, the inspector reviewed one or more of the following: the sequence of actions; the functioning of safety systems required by plant conditions; licensee actions to verify consistency with plant procedures and license conditions; and attempted to varify the nature of the event. Additionally, in some cases, the inspector verified that licensee investigation had identified root causes of equipment malfunctions and/or personnel errors and weie taking or had taken

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appropriate corrective actions. Details of tSe events and licensee corrective actions noted during the inspector'r followup are i provided in paragraph b. belo Details (1) Technical Specification Violation - Land Use Census Surveillance Inadequate LENS N/A]

On July 22, 1987, while preparing to perform the annual environmental Land Use Census required by Technical Specifica-tion Surveillance 4.12.2, the licensee discovered that the previous Land Use Census performed in July 1986, did not meet the requirements of Technical Specification 3.1 The Land Use Census that was completed in July 1986, did not include a garden census within the required three (3) mile radius of the Clinton Power Station. Technical Specification

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3.12.2 required that all gardens within a three mile radius be identified during the annual Land Use Census for plants with mixed release mode effluent The licensee identified the cause of this event was due to a deficient surveillance procedure. CPS Surveillance Procedure No. 9911.75 had not identified all the requirements of Technical Specification 3.12.2. The 1987 Land Use Census was l satisfactorily performed between July 22 and August 3, 1987, l incorporating all applicable Technical Specification require-l ments. 82 gardens were identified within a three mile radius of the Clinton Power Station. As a result of the census, a perimeter garden presently designated for sampling by the Radiological Environmental Monitoring Program will be relocated to the north sector in accordance with the requirement of Technical Specification Action Statement 3.12.2.b. This is a licensee identified violation (461/87030-04) which meets the criteria of 10 CFR 2, Appendix C, Paragraph V; consequently, no Notice of Violation will be issued, and this matter is considered close (2) Technical Specification Violation - Surveillance Not Done Satisfactorily [ ENS No. N/A]

On July 29, 1987, the licensee determined that the Liquid Radwaste Discharge Process Rad Monitor Channel Functional Test surveillance had been revised to delete isolation valve trip testing for several monitor modes. It was determined that two liquid radwaste discharges had occurred during the period when the monitor had exceeded the allowed surveillance periodicity without the appropriate Action statement being entere During a critique of this event on July 30, 1987, the licensee discovered that additional Technical Specification violations had occurred with this and several other liquid effluent monitors in that they had not been initially calibrated over their intended range of energy and measurement range as required by Technical Specification Table 4.3.7.11-1, note (3).

Further investigation revealed that this condition had been recognized by licensee personnel as early as April 21, 1987, but had not received the proper level of management attentio A supplemental critique was held on August 7, 1987, with the inspector in attendance to further investigate the additional violation This event was referred to Region III specialist inspectors for further review. Results of that review have been documented in Inspection Report 50-461/8702 _ _ - _ _ _ _ - - _ _ _ _ _ _ _ - .

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(3) Unusual Event [ENSNo.09544]

On August 4, 1987 at 4:42 p.m., the licensee declared an Unusual Event when the plant entered a condition which required a shutdown in accordance with Technical Specifications. The plant was operating at approximately 60% power with the B train of Division II of ECCS out of service for maintenanc While conducting a shiftly channel check on reactor vessel pressure-low (LPCI and LPCS injection valve permissive), on instrument number IB21-N679A, the analog trip module indicated zero engineering units. Because of the failed channel check, the associated ECCS Division (Div. I) was declared inoperable which required that the plant be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The licensee immediately conducted a channel functional check on the affected instrument. The functional check indicated that the instrument was functioning normally, and the unusual event was terminated at 5:04 p.m. on August 4, 198 j The licensee's investigation determined that the pressure instrument and logic portion of the channel had been working normally, but the software for conversion of the signal from percent full scale to engineering units in the indicating portion of the analog trip module would not support values of reactor vessel pressure greater than 999.9 psig. Pressure was approximately 1010 psig at the time of the event. The percent full scale reading on the channel was indicating normall The licensee revised the channel check procedure to allow use of percent full scale readings when engineering units are not indicating properly and provided operator aids to allow manual

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conversion of indications from percent full scale to engineering unit (4) Reactor Scram [ ENS No. 09634]

At about 12:20 a.m. on August 12, 1987, the licensee experienced a reactor scram when the APRM trip setpoint of 95%

was reached. The licensee was in Test Condition 3 (TC-3) of their startup test program which included testing up to 75%

powe The APRM trip was set 20% above the expected power levels for TC- During the conduct of a startup test procedure for recirc flow control system tune up and demonstration at TC-3, plant technicians removed a " Function Generator Card" from the "B" l recirc flow control valve circuit in order to obtain test dat I Since the hydraulic power unit for the "B" recirc flow control l valve was not " locked out", removal of the function generator card caused the "B" recirc flow control valve to ramp closed resulting in a corresponding power reduction. Plant ,

technicians then reinserted the " Function Generator Card" {

causing the "B" recirc flow control valve to rapidly open j ( resulting in a power increase to the APRM trip setpoint of 95%. I i

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Plant 1 systems responded asfexpected to the reactor. scram. At

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.the time of event occurrence, the reactor plant was operating at about 70% power.. The, licensee notified the NRC Operations

. Center of: this event via the ENS at about 1:15 a.m. on August-12, 198 Subsequent investigation by the licensee identified the fact

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.that plant technicians had failed to follow Maintenance Work

Request.(MWR) C-37643 instructions prior to removal of the function generator card that initiated this even Specifically, MWR C-37643, step 4 instructed " Prior to performing work / calibration, ensure OPS has the HPU.(of the trainbeingworked)lockedout. Work one train at a time."~

Failure of the plant technicians'to properly implement MWR C-37643 is a Violation of Technical Specification 6.8.1.'a (461/87030-05).

The. licensee. performed preplanned maintenance activities and returned the plant to operation on August 17, 198 (5) Technical Specification Violation - Inservice Testing Requirements Not Met- LENS No. N/A]

On August 13, 1987, the licensee discovered that the required Inservice Inspection valve exercising of three cooling water valves for the Residual Heat Removal (RHR) Pump Room area g coolers had not been accomplished. On August-3, 1987,'a list of valves needing to be exercised was presented to Operations Department personnel. .Theyl reviewed'the. list'and determined ,

that valves ISX027A, B, and.C were not required to be exercised o since they were locked open. On August.13, 1987, it was determined that the locking devices only locked the hand wheels of the valves but did not prevent normal air operation of the valves. By August 13, the allowed surveillance periodicity for stroking the valves had expire The subject valves were properly exercised on August 14, 1987, in accordance with the. applicable surveillance procedure. This 1 is a licensee identified violation (461/87030-06) which meets the criteria of 10 CFR 2, Appendix C, Paragraph V; consequently, no Notice of Violation will be issued, and this matter is considered close (6) Technical Specification Violation - Grab Samples Taken Late

[ ENS No. N/A]

On August 17, and August 18, 1987, three grab samples on the Hydrogen Analyzer portion of the Main Condenser Off Gas Treatment System, which were required to be taken every four hours'in accordance with Technical Specification Table 3.3.7.12.1-1, Action Item 24, were teken lat The three

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samples were 19 minutes, 2 minutes and 10 minutes late respectively. All late samples were identified by the license The first late sample on August 17, 1987, was due to failure to enter the LC0 action statement when operations of the monitor became necessary due to air ejectors being started. The second and third occurrences of late samples on August 18, 1987, were due to a combination of not allowing enough time for the technicians to accomplish the unfamiliar procedure, poor coordination between the Chemistry Department and Radiation Protection Department, and a valve that was difficult to tur A critique on the events was held on August 19, 1987. During the critique, a discussion was held on the interpretation of the requirement to sample each four hours. The question asked was whether that means only that a sample need be taken once during each four hour " window" after the equipment becomes inoperable or that each sample must be taken within four hours of the previous sample. After discussions between the licensee, the' inspector, and others of the staff, the licensee agreed that the latter interpretation was correc This is a licensee identified violation (461/87030-07) which meets the criteria of 10CFR2, Appendix C, Paragraph V; consequently, no Notice of Violation will be issued, and this matter is considered close (7) Technical S) edification Violation - Daily Channel Checks Not

, Performed . ENS No. N/AJ On August 19, 1987, the licensee discovered that two daily channel check surveillance had not been performed on August 18, 1987. A critique was held August 20, 1987, to investigate the circumstances and determine the causes and corrective actions 1 for the event. The missed surveillance were caused by a ]

revision to CPS No. 9000.010001, " Control Room Operator J Surveillance Log - Mode 1, 2, 3 Data Sheet". There apparently j was confusion over whether initials in the appropriate blocks for these particular surveillance requirements meant that the ]

j person who initialed had only verified that the surveillance had been donc in the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or had actually J performed the surveillance on that shift. Thus, a shift superdsor :,eeing initials in the blocks for August 18, 1987, assumed that the surveillance had already been done that day when in fact the initials meant that the previous shift supervisor had verified the surveillance had been done the previous da The licensee successfully performed the missed daily channel checks on August 19, 1987. A procedural revision was implemented on August 20, 1987, which required shiftly

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verification of all daily surveillsnces' noting the.due date/ time' of the next surveillance. ' This is a licensee identifiedviolation(461/87030-08) which meets the criteri >

of 10 CFR 2, Appendix C, Paragraph V; consequently, no Notice of Violation will be issued, and this matter is considered close '(8) Unusual Event - Bomb Threat

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At:about 5:00 p.m. on August 19, 1987, the licensee declared an Unusual Event and implemented. appropriate security measures in response to an anonymous bomb threa Representatives of the Federal Bureau of Investigation, Bureau of Alcohol, Tobacco, and Firearms Illinois State Police, DeWitt County Sheriff's Department, Clinton Police Department and other law enforcement agencies responded to the site to provide investigative support, threat assessment, and plant protectio The licensee's search.found no explosives, and no explosion occurred. The licensee, with the NRC agreement, terminated the Unusual Event at 10:30 p.m. Some augmented security measures were kept in place through the night.. The plant routinely

' operated at approximately 50 percent power throughout the even (9) ESF Actuation - Reactor Scram On August 25, 1987, the licensee experienced a turbine trip /

reactor trip on low vacuum in the condenser. The licensee had switched from the "B" to the "A" steam jet air ejector (SJAE). Shortly thereafter they noticed that condenser vacuum I was slowly dropping and an investigation was started to determine the cause. When the cause of loss of vacuum could not be' determined, the licensee attempted to switch back to the "B" SJAE but the turbine tripped before the switch could be completed. The reactor was at about 50% power at the tim The inspector was in the control room during event and noted that plant operators responded in accordance with plant procedures to the reactor. tri A critique was held later the same day to detennine the cause of the loss of vacuum. It was determined that the procedure to 4

witch SJAEs was incorrect in that it instructed the operators j to close the inner condenser drains on both sets of SJAEs, not just the one being secured. This caused the on line SJAE condenser to flood which caused a loss of main condenser vacuu The licensee performed preplanned maintenance activities and returned the plant to operation on August 28, 198 _. _ _ _ -

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(10)'011 Spill [ENSNo.09804]

On August 28, 1987, at about 2:30 p.m., the licensee discovered an oil slick in the cooling lake adjacent to their circulating water screen hous The slick was in a narrow stream of ateut one foot by 100 feet. The licensee estimated that the spill contained about one gallon of oil. The oil was thought to be from a' leak on one of the traveling screen motors. The licensee stopped the traveling screen motor, placed floating booms around the spill, and placed adsorption material in the traveling screen cleanout pit. The licensee notified the National Response Center, Illinois Emergency Services Disaster Agency,t,nd t'ie DeWitt County Sheriff. The licensee notified the NRC~Uperations. Center of this event at 4:50 p.m. on August 28, 19G (11) Technical Specification Violation - Mode Change Without Performing lequired Surveillance [ ENS No. N/A]

On August 28, 1987, the licensee entered Operational Condition (OC) I without the Rod Pattern Control System Rod Withdrawal Limiter High Power Setpoint channel functional test being done within one hour prior to control rod movement as required by Technical Specification Table 4.3.6-1, Item 1.b, Note (C).

The licensee discovered the missed surveillance approximately 40 minutes after entry into OC 1 and immediately halted all rod movement and successfully performed the surveillanc A critique was held later the same day with the inspector in attendance. The preliminary investigation determined that the surveillance was missed because it was not called out by either the Mode 1 Checklist or as a procedural step in the Operating Procedure in effect (CPS No. 3002.01). However, CPS No.3002.01 contained the surveillance requirement in the Limitations sectio The licensee was reviewing all previous startups to determine l if this or other similarly worded surveillance requirements I were missed. This item is considered an Unresolved Item pending the results of that investigatio (461/87030-09)

(12) Unusual Event - Bomb Threat At about 11:55 p.m. on August 28, 1987, the licensee declared an Unusual Event and implemented appropriate security measures in response to an anonymous bomb threa The threat was initially received by a GTE telephone operator at about 11:30 p.m. on August 28. The telephone operator notified local law enforcement agencies who in turn notified Clinton Power Station Security at about 11:45 p.m. Upon notification of the threat from Security, the Shift Supervisor I

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A declared the Unusual Event and notified IP management personnel. At about 3:15 a.m. on August 29, 1987, the security search was completed. The licensee terminated the Unusual Event at about 3:30 a.m. on August 29, 1987. The licensee notified the NRC Operations Center of this Unusual Event at about 12:45 a.m. on August 29, 198 As discussed in 10 CFR 2, the NRC wants to encourage and support

, licensee initiative. for self-identification and correction of l problems; therefore, a Notice of Violation for the events discussed

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above in Paragraphs (1), (5), (6), and (7) will not be issue One Violation and one Unresolved Item were identified. Four violations were identified for which a Notice of Violation was not issued in accordance with 10CFR2, Appendix C, Paragraph . Management Meeting (30702)

On August 27, 1987, NRC management met with IP management at the Clinton Power Station to discuss the status of the facility, the licensee's Monthly Performance Monitoring Management Report and actions being taken to enhance the licensee's performance in several area Key personnel attending the meeting are identified by (#) in paragraph 1. of this repor The licensee discussed the results of their latest quarterly evaluation of the Clinton Quality Assurance Program. The licensee had identified a need for increased management attention in four areas; Quality Programs and Administrative Controls Affecting Quality, Operations, Radiological Controls, and Security. The licensee discussed what actions were being taken to improve their performance in these area The licensee then provided the status of of their power ascension test progra In addition, the licensee discussed the cause for three reactor trips that had occurred since the last NRC/IP management meeting held on July 13, 1987. The licensee also discussed actions being taken in response to recent Licensee Event Reports. The licensee discussed the status of plant maintenance and near term goals for improving their maintenance progra NRC (Region III) management acknowledged the licensee's status and plan The meeting concluded with a tentative agreement to meet again on October 6,1987, at the Clinton Power Station with a similar agend As discussed in Paragraph 13 of Inspection Report 50-461/87031, the licensee met with RIII on July 13, 1987, to discuss the results of the licensee's monitored evolutions that were conducted at the conclusion of test Condition Illinois Power Company detailed in IP letter U-600995, the results of the monitored evolutions that were discussed during that meetin _ _ _ _ _ _ _ _ _

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O The letter provides results of 75 monitored evolutions for Plant Operators, 18 monitored maintenance tasks and 8 monitored Radiation Protection Task l Areas needing improvement in operations included procedural problems, '

operator control and additional training.

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Areas requiring improvement in maintenance were documentation and j notifications of tasks, and preventative maintenance of equipmen Areas requiring improvement in Radiation Protection included procedural problems and procedural complianc The overall evaluation indicated satisfactory performance in all three j areas. The contents of the IP letter was consistent with the licensee's presentation on July 13, 1987, and the results of the NRC inspection of those activities during the previous report perio . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which will involve some action on the part of the NRC or licensee or both. Two open items disclosed during the inspection were discussed in paragraph 6.a. and

' paragraph . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Two unresolved items disclosed during this inspection were discussed in paragraph 9.b. and paragraph 11.b (11), i 15. Violations For Which A " Notice of Violation" Will Not Be Issued The NRC uses the Notice of Violation as a standard method for formalizing !

the existence of a violation of a legally binding requirement. However, because the NRC wants to encourage and support licensee's initiatives for self-identification and correction of problems, the NRC will not generally issue a Notice of Violation for a violation that meets the tests of 10 CFR 2, Appendix C, Section V. A. These tests are: (1) the violation was identified by the licensee; (2) the violation would be categorized as Severity Level IV or V; (3) the violation was reported to the NRC, if required; (4) the violation will be corrected, including measures to prevent recurrence, within a reasonable time period; and (5)

it is not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violatio Violations of regulatory requirements identified during the inspection for which a Notice of Violation will not be issued are discussed in Paragraphs 11.b(1), 11.b(5), 11.b(6), and 11.b.(7).

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1 ExitMeetings(30703)

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

throughout the inspection and at the conclusion of the inspection on August 31, 1987. The inspector summarized the scope and findings of the inspection activities. The licensee acknowledged the inspection finding The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any documents / processes as proprietar The resident inspector attended exit meetings held between Region III based inspectors and the licensee as follows:

Inspector Date A. Gautam 8/21/87 R. Paul 8/07/87 W. Slawinski 8/07/87 *

R. Love 8/14/87

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