IR 05000461/1988001

SALP Rept 50-461/88-01 for Sept 1987 - Aug 1988

ML20195D994
Person / Time
Site:	Clinton
Issue date:	08/31/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20195D991	List: IR 05000461/1988001 ML20195D987
References
50-461-88-01, 50-461-88-1, NUDOCS 8811070210
Download: ML20195D994 (31)

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SALP 8 SALP BOARD REPORT 0.S. NUCLEAR REGULATORY COMISSION

REGION III

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-461/88001 Inspectio') Report N Illinois Power Compag Name of Licensee Clinton Power Station Name of Facility September 1, 1987 through August 31, 1988 Assessment Period

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TABLE OF CON'ENTS ,

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• INTRODUCTION 1 I SUMMARY OF RESULTS 2 Overview 2 r Other Areas of Interest 2 III. CRITERIA 3 IV. PERFORMANCE ANALYSIS 5 Plant Operations 5 ,

' Radiological Controls 5 , Maintensnee/ Surveillance 11 , Emergency Preparedr.ess 14 i l Security 15 Engineering /Tei:hnical Support 17 , Safety Assessmint/ Quality Verification 19

i SUPPORTING DATA' AND SUMMARIES 24 t

- Licen;ee Activities 24 Inspection Activities 25 l Escalated Enforcament Actions 27

! Confirmatory Action Letters (CALs) 27 , Licensee Amendments Issued 27 i Review of Licensee Event Reports Submitted .

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I. INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information. SALP is supplemental to normal regulatory processes

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used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of their facility's performance in each functional are An NRC SALP Board, composed of staff members listed below, met on October 18, 1988, to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516. "Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section III of this report. The Board's findir s and recommendations were forwarded to the NRC Regional Adminisuator for approval issuanc This report is the NRC's assessment of the licensee's ' safety performance at Clinton for the period September 1, 1987 through August 31, 198 SALP Board for Clinton -

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Name Title

• E. 4crelius SALP Board Chairman, Director, Division of l

Radiation Safety and Safeguards (DRSS)

• E. G. Greenman Diractor,DivisionofReactorProjects(DRP)

• J. Miller Director, Division of Reactor Safety (DRS)

• R. Muller Project Directorate III-2, Office of Nuclear Reactor Regulation (NRR)

• L. Forney Deputy Director, DRP

• R. C. Knop Chief, Reactor Projects Branch 3. DRP R. W. Cooper Chief, Reactor Projects Section 3B, DRP

• P, L. Hiland Senior Resident Inspector S. P. Ray Resident Inspector

"J. A. Stevens Project Manager, NRR L. R. Greger Chief, Facilities Radiation Protectun Section, DRSS W. J. Slawinski Radiation Specialist, DRSS A. B. Davis Regicnal Administrator M. P. Phillips Chief, Operational Programs Section, DRS G. L. Pirtle Security Specialist, DRSS W. G. Snell Chief Emergency Preparedne:;s Section, DRSS R. L. Hague Chief, Technical Support Staff (TSS). DRP A. Dunlop, J Reacter Engineer, TSS, DRP

! R. B. Holtzman Cnemistry Specialist, DRSS H. A. Walker Reactor Inspectot, DRS

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II. SUMMARY OF RESULTS . Overview Management cor.tinued to demonstrate a high degree of involvement in all areas of plant operatio Root-cause and corrective action determinations for events, maintenance outage critiques and application of lessons learned, assessment of the safety impact of postponing field alterations, and reduction to zero of backlogged preventive maintenance items are areas where minagement attention

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generally aggressive in response to NRC safety concerns as well as in the resolution of technical issues; however, management attention is needed to correct control room deficiencies, ensure tracking of long-term corrective action to completion, and

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reemphasize the importance of completion of required surveillance

tests within the prescribed schedul The effectiveness of improven<ent initia ives has been demonstrated

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by the Ugnificant decrease in the numbt r sf reportable events compared to the previous assessment periou, as well as in the

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reduction of reportable u ents over the last. half of the assessment period. However, the number of reportable events associated with

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personnel errors remains high and indicates a neid for improved downward communication of expectations by management. Although i statfing and training are generally good, the training program should empha:ize the use of procedures, particularly by the

operators during and after events to vurify corrective action Resolution of security computer problems identified in the

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previous SALP and continued high level of management involvement, responsiveness to NRC concerns, and proactive planning ard actions by security managers contributed significantly to the rating change

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for the security area, from a SALP 2 to SALP 1 performanc Rating Last Rating This

Functional Area period period Trend

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Plant Operations 2 2 Improving l Radiological Controls 2 2 l Maintenance / Surveillance 2/2 2 Emergency Preparedness 2

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. Security 2 1 Engineering / Technical NR 2 Support 1 Safety Assessment / Quality NR 2 Verification l NR - Not Rated l Other Areas of Interest None

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III. CRITERIA ,

The licensee performance is assessed in selected functional area Each functional area normally represents areas significant to nuclear safety and the environment, and are nor.9al programmatic areas. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were usect to assess each functional are . Assurance of quality, including management involvement and contro . Approach to the identification and resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement history, Operational events (including response to, analysis of, and ,

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corrective actions for). Staffing (including management).

, Effectiveness of training and qualifications progra ,

However, the NRC is not limited to these criteria and others may be used where appropriat On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definition of these performance categories are as follows:

Category 1: Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirement Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriat Category 2: Licensee management attention to and involvement in the performance of nuclear safety or se.feguards activities are good. The

- licensee has attained a level of p'erformance above that needed to meet regulatory reauirements. Licensee resources are adequate and reasonably i allocated so that good plant and personnel performance is being r,chieve NRC attention may be maintained at normal level Categoiy 3: Licensee management attention to and involvement in the rerformance of nuclear safety or safeguards activities are not sufficient. The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirement Licensee resources appear to be strained or not effectively used. NRC attention should be increased above normal level ._- ___ _ ___ _ __ ,~ . .

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Trend: The SALP Board may determine to include an assessment of the performance trend of a functional area. Normally, this performance trend is coly used where both a definite trend of performance is

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discernible to the Board and the Board believes that continuation of the trend may result in a change of performance leve '

The trend, if used, is defined as:

improving i I.icensee performance was determined to be improving near the close of f the assessment perio '

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i Declining Licensee perforn.ance was determined to be declining near the close of

the assessment period, and the licensee had not taken meaningful steps ,

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IV. PERFORMANCE ANALYSIS Plant Operations Analysis Evaiuation of this functional area was bastd on the results of nine routine irspections conducted by resident inspector The licensee commenced commercial operation of Clinton Power Station on November 24, 1987. The equivalent availability from the start of commercial operation to the end of the assessment period was 76%. Reduction in the maximum equivalent availability (100%) resulted from the licensee's planned maintenance outage Mtween March 18 and May 5,198 In addition, unit deratings were necessary to maintain operating limits after 'he failure of one circulating water pump; to repair tube leaks in feedwater heaters and the main condenser; to perfccm rod sequence exchange; and to perform scheduled surveillance Enforcement history in this area showed improvement. During this assessment period, three Severity Level IV and one Severity Level V violations were identified compared with ten Severity Level IV and one Severity Level V during the previous assessment period. The violations were not of major safety significanc One Severity Level IV violation occurred when the licensee failed to meet the required action statement when a pressure transmitter was isolated from service for greater than the allowable two hours. The second Severity Level IV violation resulted from the failure of plant operators to recognize an inoperable cooling fan and its affect on emergency core cooling system (ECCS) operability. The third Severity Level IV violation resulted from inadequate implementation of corrective action by plant staff to control valve and electrical lineup change The Severity Level V violation concerned the licensee's failure to make a required report to the NRC in a timely manner. The four violations were considered to be isolated instances and not evidence of programmatic w,aknesses in the overall concuct of plant operations. The violation for failure to properly implement corrective actions for control of valve and electrical lineups, however, is an example discussed in the area of Safety k,sessment/ Quality Verification where a reed for followup on long-term corrective actions appears to be warranted. In addition, several violations and Licensee Event Reports (LERs)

discussed in the functional area of Maintenance / Surveillance resulted from personnel errors on the part of plant operator During this assessment period, the licensee issued four LERs pertaining to plant operations. This represented a significant improvement over the 48 plant operations LERs in the previous period. Two of the four involved violations of

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Technical Specifications because of personnel errors that were the subject of the above described Severity Level IV violation One LER reruited from a Technical Specification violation when thermal overloads were bypassed longer than allowed by Technical 3pecification The remaining LER was a reactor scram from 90% power caused by personnel error. Only one of the LERs occurred in the last half of the assessment period; this indicates an improving trend. Senior maragement attention, through the corporate level, was evident in reducing the number of LER As noted above, only one operational event was attributed to plant operations. That event was a reactor scram from 90% power caused by a noniteensed operator improperly performir.g an electrical bus transfer evolution. The event was partially attributed to inadequate labeling of component Equipment malfunctions caused two other automatic anel one manual scram during power operations (>15% power), as well as one scram while siutdown (no rod movement). Problems in the feedwater system and in the reactor recirculation system necetsitated rapid power reductions on several occasions that operators $re able to control in a safe and efficient manne The operators responded conservatively and in accordance with procedures to these events, and root causes were properly determined. The operators also responded to 11 engineered safety feature (ESF) actuations. None were attributed to plant

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operation Management involvement in the corrective actions for all  ;

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violations and LERs in this functional area was excellen Management was required to be notified of events within one hour and held formal critiques of events with all appropriate personnel. The critiques were directed toward fact finding, root-cause identification, and corrective action recommendations rather than attempting to lay the blame on particular individual As an additional management overview, the licensee instituted a corrective action board, chaired by the Manager - Clinton Power <

Station, with several other department managers involved. The board's putpose was to provide a detailed management review of critiques, root-cause determinations, and the appropriateness of corrective actions. The corrective action board looked for i adverse trends, interdepartmental coordination problems, and .

generic weaknesses, with the goal of improving the overall quality of site-wide operation Plant operations staffing was good. The licensee has trained and maintained enough senior reactor operators (SR0s) so that experienced SR0s can be rote.ted to other support functions, such as outage scheduling, maintenance planning, and procedure writing. During contingency planning for a threatened strike by bargaining unit personnel, including licensed reactor operators (R0s) and nonlicensed auxiliary operators (A0s), the licensee

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was able to identify enough SR0s to man three shifts of SRO, _

RO, and most A0 positions. The line organization above the shift supervisor's level was relatively stable, with the transfer of the Assistant Manager - Clinton Power Station, early in the assessment period being the only change in the structur Plant operators were responsive to NRC initiatives during the assessment period. The resident staff held weekly meetings with the Manager - Clinton Power Station, to express any concerns and those concerns generally roceived adequate attention. Management's response to the resident staff concerns about foreign material control and mismic restraints for temporary equipment in the containment building were inadequate, however. Repeated discrepancies in those areat resulted in two Severity Level IV violations that, although assigned to the Safety Assessment / Quality Verification functional area, could have been prevented by closer operating management attention. Weaknesses in the corrective actions in response to those violations were still evident late in the assessment perio One area that requires continued management attention involves the deficiencies in the main control room. Although some improvements were made during the assessment period in reducing the number of lighted and out-of-service annunciators, recorders, and instruments, continued management attention is needed to improve the overall conduct of plant operation Ten SRO and six RO replacement examinations were administered by the NRC during the assessment period. One SRO candidate failed these examinations. This represents a success rate of 94% for NRC administered examinations which is above the national average. No replacement or requalification enas were administered during the previous rating period so no statistics are available for compariso The only generic area of weakness identified involved the use of emergency operating procedures (EOP). Although the performance of the SRO candidates during the simulator portion of the operating examinations generally iadicated a good familiarity with both the procedural steps and the basis, the majority of the candidates did not open the E0Ps and use them to work through the casualties or to verify actions take The examiners belitved ti.:+ more training emphasis should be placed on using pre:edures duriny ...d after events to verify corrective action. The licensee provided a timely written response addressing this generic finding, stating the corrective actions that have been or are being take _ - _ _ - . _ - _ _ _ _ _ _ . _ _ _ _ _ . - ______._____ _-___

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During the rssessment period, observations by the resident inspectors indicated that the licensee was adhering to their  !

fire protection program. Identified deficiencies and equipment failures were eromptly compensated for in accordance with the licensee's progra Plant staff overtime averaged approximately 18% during the assessment period. This was considered high but the assessment period included portions of the startup testing program and two scheduled outages. Plant staff overtime in non-outage l periods was less than 10%. Licensee management attention was directed to reducin0 plant staff overtime and there generally was a decreasing trend in staff overtime. Average plant staff overtime was reduced by about 3% in the second half of the assessment perio I Housekeeping and cleanliness were observed to be good throughout the evaluation per a . Performance Rating The licensee's performance is rated Category 2 in this area with an improving trend. The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations None Radiological Controls

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, Analysis Evaluation of this functional area was based on the results of three routine inspections performed by regional inspectors and ,

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The enforcement history during this assessment period was good and showed improvement from the previous period. No violations ,

were identified this period compared with three violations (two Severity Level IV and nne Severity Level V) during the  ;

previous period; however, a violation assigned to the area of i Plant Operations concerning response to a drywell particulate i radioactivity monitor failure identified weaknesses in the ,

administrative practices of the Radiation Protection Departmen l The corrective actions teken or planned for those weaknesses i were appropriat l While technician staffing levels and qualifications were adequate to implement the routine radiation protection and radiochemistry programs, average olant specific and commercial i l

operational experience remained hw. Radiation protection staff [

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turnover continued to be relatively high early in the assessment period, but it stabilized somewhat in the middle and late stages of the period. A significant reduction in reliance on contractor health physics (HP) support should protido long-term benefits as plant experience levels increase. A new radiation protection manager (RPM) was appointed late in the assessment period when the former RPM transferred to another program area. The new RPM has had limited onsite experience, with much of his previous nuclear experience being in design and corporate positions, i Most of the technical / professional support staff vacancies that .

existed during the previous assessment period have been filled with well qualified personnel. An exception nas been the difficulty in refilling the position of assistant supervisor chemistry - support. Overtime of HP personnel during outages was extensive, but remained within NRC guidelines and did not appear to affect the performance of the radiation protection progra The training and qualification program was adequat Discrepancies noted early in the assessment period regarding implementation of the radiological operations technician qualification program have been partially resolved. Institute of Nuclear Power Operations (INPO) accreditation for the radiological operations technician training program was progressing satisfactorily; some additional efforts are required concerning expansion of the continuing training program. The licensee was proceeding adequately with the qualification program for workers responsible for ancillary ,

radwaste activities. The lack of an adequate safety tagout procedure, personnel errors, and worker inexperience all t contributed to a significant personal contamination / burn )

incident. An inadequate valve / component tagout was also the significant contributing factor in the contaminated water spill that occurred earlier in the assessment period. Worker nrrors ,

also caused a radwaste evaporator excursion that led to resin intrusion into downsi. ream radwaste system ,

Management involvement in ensuring quality was evident and I

generally good, as demonstrated by management oversight of the radiochemistry quality control (QC) program. However, l some early weaknesses were noted in the dry active waste l

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(DAW) processing program and in oversight of the radiological operations technician qualification program. Management attention and effort devoted to correcting recognized problems

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continued to be good, as evidenced by development of a radiation orotection improvenent plan in response to licensee identified program weaknesses, aggressive resolution of DAW packaging problems, continued management involvement in radiological events (radwaste evaporator incident, contaminated water spill, sewage treatment radiotodine cantamination), and support for plant decontamination. Labor / management relations continued to be strained early in the assessment period, with

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continuing staff morale problems, but relations appeared to -

improve later in the period as staffing levels increased and stabilized and contractor reliance was reduce Responsiveness to NRC initiatives was generally goo Allegations submitted for licensee followup were reviewed and dispositioned in a timely and appropriate manner. Previous NRC concerns that were addressed include improvements to mechanical maintenance shop contamination controls and high radiation area key controls, and completion of revisions to streamline and improve implementation of radiological improvement reports. The licensee was somewhat slow, however, to resolve a dosimetry /andor's thermoluminescent dosimeter (TLD) (beta spectrum) adjustment proble The licensee's approach to the resolution of radiological technical issues has been sound, as exhibited by radiological assessments performed for a radwaste evaporator incident, modifications to the survey program for release of materials

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into uncontrolled areas, and actions taken in response to the identification of radioiodine in the sewage treatment plan Also, the corrective action and investigation action plan developed as a result of resin intrusion into the liquid radwaste System was generally good, as was the radiological response to two significant contamination events (personnel /

area) that occurred during the assessment period. The licensee continued to implement the radiological housekeeping and contamination control program, including emphasis on system  !

1erk reduction, as part of the station's as low as reasonably achievable (ALARA) efforts. While there were no unplanned effluent releases or excessive individual personnel exposures during the assessment period, there has been insufficient plant operating experience to adequately evaluate control of personnel exposures and affluent releases. Station dose for 1987 was 56 person-rem, In 1988 through August, station dose was about r 100 person-rem. These doses are not excessive for the plant i operating history. The station achieved 94 agreements in 108 comparisons during its first radiological confirmatory measurements inspectio The problem was determined to be sample positioning on one of three detectors, and corrections have been u d . performance Rating The licensee's performance is rated Category 2 in this are The licensee's performence was rated Category 2 in the previous

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assessment perio . Recommendations None

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C. Maintenance / Surveillance Analysis Evaluation of this functional area was based on the results of nine routine inspections conducted by the resident inspectors and two inspections conducted by regional inspector Enforcement history in this functional area showed slight improvement in licensee perfomaance since the previous assessment period. During this assecsment period, 8 viclations ,

(6 Severity Level IV and 2 Severity Level V) were identified compared with 12 violatior.s (11 Severity Level IV and 1 Severity Level V) in the previous assessment period. The six Severity Level IV violations involved the licansee's failure to perform or properly restore from surveillance *.esting. These six violations were not considered to have major safety significance and did not indicate a breakdown in the licensee's programmatic controls. .t they were considered to b3 isolated cases of plant staffs' failures to follow procedures during the performance of surveillance or corrective maintenance. The two Severity Level V violaticas involved failures of maintenance personnel to follow procedures and were also considered to be isolated cases. The licensee's corrective actions for these violations were appropriat The licensee issued 21 LERs related to maintenance and surveillance program implementation. Of these, 19 LERs were attributed to personnel errors that caused 13 Technical Specification violations, 5 ESF actuations, and 1 reactor protection system (RPS) actuation that occurred wher: the plant was shutdown. The other 12 LERs related to equipment malfur.ctions that led to 3 reports of degraded equipment, 6 ESF actuations, and 3 RPS actuations at power. Of the three RPS actuations caused by 3quipment malfunctions, two were automatic scrams from greater than 60% power and the other was a manual scram from 100% power that was properly initiated in ,

response to a loss of circulating wate For the most part, the personnel errors were isolated cases for which the licensee took appropriate corrective actio None of the events were of i major safety significance; however, tney were indicative of le's than desirable performance in this area. The licensee's carrective actions following events appeared to be effective in that for the 31 LERs issued in this functional area, 14 had occurred in the first four months of the assessment period and the remaining half in the latter eight months. This reduction in the rate of event occurrence reflects well on the licensee's corrective action process. During the previous assessment period, 28 LERs were issued in this functional area of which 21 were caused by personnel erro I

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For the 31 LERs discussed above,10 LERs resulted from the

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licensee's failure to perform required surve111ances. Three ,

of those ten LERs were routine, periodic surveillances and the remaining seven LERs were missed surveillances required by entry into a Technical Specification action statement. All of the missed surveillances were attributed to personnel error. The licensee had implemented generic corrective action early in the assessment period following the first five instances of missed surveillance testing. That generic corrective action appeared to be effective; however, the recurrence of 'ive more misced turveillances in the latter part of the assessment period indicates that reemphasis of the corrective actions taken early in the assessment period is warrante Management it.volvement to assure quality in this functional area was generally evident throughout the assessment perio Formal critiques of operational events involving maintenance or survelliance activities were conduc+.ed to determine the root-cs:se. Managament support and involvement provided for in-depth review of each event, as veil as sound root-cause determination and clear corrective actions, where appropriat In addition, the licensee conducted critiques of the two maintenance outages that were performed during the assessment period to evaluate performance and areas where improvements could be made in the overall conduct of a major outag Lessons learned from the outage critiques wore incorporated into the planning for the first *efueling outage. Management also ensured quality through well-defined procedures (ECCS check valve testing) and well-documented test results ( esidual heat removal and reactor core isolatica cooling systems testing records). However, weaknesses were prevalent in two areas:

spara parts notifications to maintenance personnel and the apparent lack of strict procedural adherence which resulted in a high number of personnel crrors. Additionally, two isolated signif kant contamination evants noted in the Radiological Controls functional area reflected inadequacies in the system / component tagcut procedure for which the licensee has taken corrective action. As mentioned earlier in this evaluation, six vielations were attributable to failure to follow procedure Over the assessment period, the t:acklog of corrective maintenance items was reduced from about 1500 items to about 1000. The remaining corrective maintenance items had been evaluated for their impact on component or system operation. The Itcersee established priorities for corrective maintenance items in th3 12-week rolling maintenance schedule unless immediate action was required or the appropriate corrective maintenance item was scheduled to be cone during a scheduled plant outage. Of the 1000 corrective maintenance items existing at the end of the assessment period, abeut 400 had been identified as requiring a plant ::utage to perform, and the licensee had plans to perform

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about 300 of those during the first refueling outage in January 1989. The remaining 600 items were tracked as nonoutage and included about 100 safety-related maintenance items. During the assessment period, the licensee reduced the backlog of nonoutage safety-related maintenance at a rate of about five items per wee o One noteworthy effort on the part of the licensee was the reduction in the backlog of prevutive maintenance item During the previous assessment pertod, the large number of past-due preventive maintenance iteas was considered a weaknes The licensee significantly reduced ttat backlog ntar the close of the previous assessment period. Du-ing this assessment

, period, the licensee continued to reducs the number of overdue safety and non-safety-related preventive aaintenance items and was successful in achieving the stated goal of zero past-due itta The licensee has committed to continue the review of

er,uipment and components by system to determine whether the preventive maintenance program is comprehensive and tally

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The licensee's approach to the resolution of technical issues from a safety standpoint appeared to be technically soun Major maintenance was performed on the main steam isolation valves, high pressure core spray diesel, and containment 1:olation valves during the assessment period. For each of these activities, the licensee established good work controls and brought in technical experts to provide assistance. During the assessment period, a number of problems occurred in the feedwater heater system that resulted in operators responding to rapid changes in feedwater temperature. The licensee's approach to the problems involved a combined effort on the part of the engineering, mainten6nce, and operational staffs that was successful in reducing the feedwater temperature transients and stabilizing the feedeater heater Some examples identified during maintenance and audit activities, a

however, indicated a need for improvement in the resolution of

, technical nssues. In one sxample, an issue pertaining to the

correct value for torquing of studs on a MSIV was identified, but work continued witFout obtaining a technical evaluation.

1 Another example involved an audit finding that identified a probleta with the installation of incorrect resistors in process radiation monitors but did not address the generic aspects of the various problems identified during the investigation of the audit finding, Staffing in this functional area was adequate. Although some overtime was required during the two major outages, it e.ppeared to be well-controlled and at a level that would not impact the performance of maintenance or surveillance activities. Inspector

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observations of maintenance and surveillance activities determined i

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that personnel were knowledgeable in procedure For the most part, work was performed in a professional, skilled manner in accordance with technically adequate procedures and clearly specified quality requirements; the functions, responsibilities, and authorities at the management, supervisory, and nonsupervisory levels were clearly delineated in administrative procedure . Performance Ratina The licensee's performance is rated Category 2 in this are The licensee's performance in Maintenance was rated Category 2 and was rated Category 2 in Surveillance in the previous

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assessment perio , Recommendations None Emergency Preparedness Analysis Evaluation of this functional area was based on three inspections

, conducted by regional insputors, and resident inspector observations of drills during this assessment period. Regional L, inspections included observation of the 1988 annual emergency I preparedness exercise, a special Inspection to evaluate facilities available for an NRC site team, and an Emergency

, Response Facility Appraisal. The resident inspectors also performed followup inspection.. of events involving emergency preparednes Enforcement history improved during this assessment period,

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with no violations identified. Two violations (Severity I

Level IV) were identified during the previous assessment period. No additional concerns were identified during the routine inspection The 1988 emergency exercise was considered adequate and all

, aspects of the emergency plan were adequately exercised. No weaknesses or open items were identified during this exercise, i which was an improvement over the 1987 ext,rcise, and overall performance was adequate.

! The Emergency Response Facility Appraisal resulted in two open items relative to the heating, ventilating, and air-conditioning system and the capability for computer trending of parameter These items were not considered to be significant, and other

areas reviewed were acceptable.

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Management involvement in assuring quality was evident throughout

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the asses ment period, as evidenced by management's following each inspection and the adequacy with whit.h NRC-identified :

concerns were addressed.. The resident inspector's observations of scheduled emergency drills indicated professional attitudes by drill particioants. Late in the assessment period the licensee demonstrated foresight in devising a plan to assure adequate emergency response personnel during a threatenef strik '

The licensee's approach to the resolution of technical iss;.es appeared to be adequate; however, recurring problems with the proper activation of the offsite alert and notification system

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(strens) required several repair efforts. The recent corrective actions appear to be adequate, and the licensee is continuing to evaluate long-term improvements to the siren activation syste The licensee has been responsive to NRC concerns, and when resolving weaknesses from a safety' standpoint, has demonstrated good undurstanding of the issues involved. Once problems were clearly identified, the licensee adequataly resolved the issuo Staffing of emergency response positinns has been good, with

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the authorities and responsibilities of personr.a1 well-define Knowledge and capability of personnel to carry out their emergency response' duties and responsibilities were derronstrated i

during the annual emergetcy orsparedness exercise, as well as in Walkthrovghs durt.ig a routine inspection. This indicated that the licentee's training program had aduquotely prepared personnel for their assignment . Derformance Rating

' The licensee's performance is ratec Category 2 in this are The licensee's performance was rated Category 2 in the previous l

assessment perio . Recommendaticq None . Security Analysis Evaltation of this functional area was based on the results of one special and two *outine security inspections condveted by l regional security inspectort, and on the routine observations of

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daily security activities by the resident inspectors.

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Enforcement history indicated a slight decline from the previous assessment period. One Severity Level III violation that involved the inattentiveness of a security officer performing compensatory security measures was identified this period compared with two Severity level IV violations in the previous period. The Severity Level III violation was an isolated personnel error that had no direct safety significance. A civil penalty was not imposed because of the licensee's prompt identification and reporting and unusually prompt and extensive corrective actions prior to and subsequent to the even Management irrolvement i assuring quality was excellen Management support was instrumental in reducing security door alarms through the reduction of associated personnel error Prior pla.1ning by manage.nant resulted in smooth and efficient compensatory security measures to support construction and maintenance outage Management allocated key resources to the security computer enhancement project. Quality assurance audits of the security program were comprehensive and contributed to a high quality security program. The safeguards information (SI) physical protection program is a streng+.h and provides good control of S Licensee responses to security matters were technically sound, timely, and conservs.tive; a clear understanding of the issues was indicated. The licensee's progress in addressing spurious intrusion detection system alarms was deemed unsatisfactory in the previous assessment. During the current period, however, the licensee has demonstrated a comprehensive and long-term approach to resolving the alarm problem. The actions have pNduced a signifitant reduction in spurious alarm The licensee continued to be responsive to NRC concerns, particularly in matters referred to them for investigatio Their investigations were thorough and timel Licensee response to and reporting of security events were conservative. The licensee reported eight security events (four * vere later retracted) compared with 12 events in the previous period. A change in the security event reporting rule in October 1987 prevented meaningful comparisons between assessment periods. However, in the previous assessment period, there were six f ailure events related to the security computer, while there were none this period. All events were reported in a timely manner. Event analysis was comprehensive, and corrective actions were effective. The D eensee security efforts in response to a potential plant emp hyee strike and an equipment tampering event were effective and timel Security manning requirements were continually reviewed to support plant operations. Good planning, well-defined positions and responsibilities, and competent personnel in key security

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positions resulted in a dynamic security organization. The .

licensee's security supervisor changed at the beginning of the period, and several security contractor supervisors departed during this assessment period with no impact on the effectiveness of security operation The security officers were well-trained and knowledgeable of their individual and collective tasks. Effective training was a significant factor in the continued good performance of the security force, in spite of the previously discussed supervisor turnover. The one violation this period was not the result of any training deficiency. The licensee is presently satisfying all security contingency training requirements; however, more management emphasis is required in the area of tactical response training. The licensee is currently revising existing training and ceveloping new training to address NRC concern . Performance Rating The licensee's performance is rated Category 1 in this are The licensee's performance was rated Category 2 in the previous assessment period. Resolution of security computer problems identified in the previous SALP and continued high level of management involvement, responsiveness to NRC concerns, and proactive planning and actions by security managers contributed significantly to the SALP 1 rating for the security are . Recommendat' y None F. Engineering / Technical Support Analysis This is a new functional trea and consequently was not rated in previous SALPs. Evaluati?n of this functional area was based on the results of seven li.:r e.tions conducted by regional inspectors and nine inspections by the resident inspector Enforcement history during the assessment perir consisted of one Severity Level III violation, with assoclasad Civil Penalty of $75,000, and one Severity Level IV violation. The Severity i

Level III violation was issued during this assessment period, but was identified and discussed during the previous assessment period. It related to the failure of the licensee to I demonstrate environmental qualification of Amp Kynar splices, T8.8 nylon wire caps, and junction boxes without weep holes that were installed in a harsh environment. In addition, several violations discussed in the functional area of Safety Assessment /

Quality Verification could have been prevented by improvement in the technical support area. The Severity Level IV violation

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related to a loss of secondary containment when a penetration seal was removed for maintenance. The safety significance of the violation was mitigated by prompt identification a corrective action by plant operators. Since this area was not rated during the previous assessment period, no enforcement history is available for compariso Four LERs issued during the assessment period relate to this functional area. All four LERs were the result of personnel errors. One of the LERs discussed the lack of required "weep" holes in electrical junction boxes and was considered as part of the above escalated enforcement action. That event was one of two significant events as defined by AEOD criteria which occurred during the evaluation period. The other significant event is discussed in the Safety Assessment / Quality Verification functional area. One LER pertained to the Severity Level IV violation resulting from the loss of secondary containmen The remaining two LERs were not considered to be safety significant; they discussed a self-identified design deficiency in the diesel ventilation system and a missed preventive  ;

maintenance activity on a ventilation dampe Management's level of involvement to ensure quality in this area was good. Management's involvement and attention to the modification process was evidenced by the decrease of open modifications for several months and the utilization of a modification review committee to assess the postponement of field alterations (minor modifications) for impact on safet The licensee's review of modifications for post-modification '

tests, design review process, and configuration control was adequat.. These reviews were well-organized to facilitate in-depth examination of the modification pre:ess. In addition, the involvement of engineering and technical specialists in .

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licensee critiques of operational events provided for prompt corrective action based on sound judgement. Long-term corrective actions were given the appropriate priority, with a clear goal of permanent resolutio Specific examples of the involvement of engineering and technical specialists included: engineering review of diesel air start motor failures; the technical review of the plant-wide application of Agastat Type GpI series relays whose failure caused *. r::* tor scram during the assessment period; and the ir%ntification, root-cause investigation, and repair of deficiencies in the high pressure core spray emergency diesel generator. Another example was the licensee's followup on the discovery of water in a limit switch compartment of a motor operato Following discovery, ths licensee implemented a thorough inspection effort of electrical equipment subject to the same environment. That cffort identified deficiencies in the as-installed condition of Weed thermocouples and resistance temperature detectors that were nromptly corrected. In addition, the licensee performed a thorough review of the environmental qualification (EQ) program to identify any additional deficiencie __ ---. . _ - - - -

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The approach to resolution of technical issues from a safety standpoint was good. This was evident by the resolution of problems noted during the installation of modifications and ,

the resolution of the EQ issues discussed above.- Examples of ;

well-for s'.vted correctivo actions included efforts taken to mitigate carrosion, over/under torque of actuator-to-valve bolting on safety-related valves, proper thrust value calculations during performance of valve testing, and correction of design deficiencies in the diesel ventilation syste The licensee's responsiveness to previous NRC-identified concerns or weaknesses was mixed. A concern with a modification's safety evaluation, which did not adoress a welded tee connection when assessing whether an unreviewed safety question existed, was identified by NRC and promptly corrected by the licensee; however, one of the EQ deficiencies was the failure of the licensee to resolve a previously identified concern regarding the lack of weep holes in the EQ junction boxe Staffing in this functional area was good. The licensee's engineering and technical support staff being located at the site appears to facilitate responsiveness to the needs of thi operating staff. The licer;ee has effectively used the engineering and technical support of outside organizations, such as the architect engineer and nuclear steam system supplier, when specific expertise was not available within the organization. The licensee was transitioning to the system engineer concept during this assessment perio . Pg,*formance Rating i The licensee's performance is rated Category 2 in this are Because this is a new area, no rating is available for the previous assessment perio . Recommendations None Safety Assessment / Quality Verification Analysis Evaluation of this functional area was based on the results of four inspections performed by regional specialist inspectors, one special tcom inspection performed by regional specialists, and ten routine inspections conducted by the resident inspector In addition, NRC staff reviews of licensee submittals and request for amendments to the Clinton Operating License were considered.

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Enforcement history in this area was less than desirabl Six Severity Level IV violations were identified. During the previous assessment period, one Severity Level III violation, four Severity Level IV violations, and one Severity Level V violation were identified in the functional area of Quality Programs and Administrative Controls Affecting Qualit Although the two functional areas do not have a one-for-one correlation, they are similar. While none of the six violations were considered safety significant, two violations were of concern because they occurred after precursor events had been discussed at length with licensee management and corrective action to prwent the violations was ineffective. Of the two violations of concern, one related to the licensee's inability to recognize the effect that the removal of a support system from service had on the operability of safety-related equipmen The other violation concerned the licensee's failure to control material place ' in the containment during plant operation. The licensee's corrective actions for the remaining four violations were appropriat One LER was issued pertaining to this functioaal area. That was the second significant event, as defined by AE00, which resulted from an inadequate safety evaluation during the installation of a temporary modification. That safety evaluation did not einsider the environment to which temporary tygon tubing would be exposed within the containment. On the positive side, the licensee's independent safety engineering group (ISEG)

identified the inadequate safety evaluation and immediately informed the Manager-Clinton Power Station, who took prompt corrective action by removing the temporary modificatio Management involvement to assure quality was evident throughout the assessment period. The root-cause analysis of plant events was excellent and there was total management supper',. The root-cause analysis of two reactor scrams that occi.rred late in the assessment period not only identified the immrdiate cause of e

the events but led to a thorough review of the arplication of Agastat relays in low-voltage systems following the first scra The root-cause analysis of the second reactor scram (loss of circulating water) identified not only the cause for 1csi of circulating water but analyzed the total performance of plant operators in response to the event and identified a number of minor weaknesse The types of root-caust analysis discussed above were typical of the management involvement for all events that occurred during the assessment period. The well-conceived long-term corrective actions for some events were not, however, adequately monitored for proper implementation. An example of this failure to assure proper implementation of long-term corrective action was the violation discussed in the area of Plant Operations, which occurred because changes to valve lineups were not controlled in accordance with corrective action to an operational even *

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C Management involvement and control in the quality verification process was acceptable. This was eviden,ted by the licensee's progress in conducting performance-based audits and the processing of audit findings that focused not just on implementation of corrective action, but also the effectivenes Management involvement was also evidenced by the effective utilization of independent reviews and the licensee's ISEG that identified potential problems. A weakness that requires increased management attention is in the area of trendin The licensee's Quality Assurance (QA) Department utilized a three month data base for trending condition reports (CRs)

that would identify gross trends but not subtle trend Licensee management demonstrated active participation in all licensee activities related to license amendment applications and requests for relief from the regulations, as well as in the submittals related to generic letters, bulletins, and other technical reviews required by the regulations. The submittals have generally been of high quality and have not required significant rework to satisfy NRC requirements. Management involvement and control in assuring quality was evident in the submittal of the first ten-year interval inservice inspection program for the Clinton Plant, which included certain relief requests. The program submittals were technically sound, and there was evidence of a conscientious effort to comply with the regulation The approach to resolution of technical issues from a safety standpoint was generally acceptable. Results from the review of LERs and CRs indicated that the licensee was effective in identifying deficiencies, resolving tM issues, and preventing recurrence, particularly in the areas of calibration and instrumentation and operations. Additional effort and management involvement in taking corrective action was notad and was specifically evident in the LER reduction plan instituted in late 1987. Tracking of corrective action documents and resolution of the issues, such as CRs, LERs, audit findings, and NRC violations, were adequately accomplished by the licensee by using a trending program under the direction of the QA department. Trend analysis of corrective action documents were based, however, on the problem rather than the root-cause, and therefore there was the potential for missing adverse trend Further, the root-cause was verified to be correct only upon closure of the corrective action documen Licensee efforts were continuing to improve methods of trending and root-cause analysis and to increase the effectiveness of these program The identification of potential problems by independent reviews was effective; however, increased management attention is needed in the resolution of problems. Two of the technical issues identified that were not adequately addressed pertained

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to the testing of check valves in the standby liquid control system and the testing of two active valves in the residual-heat removal syste The licensee has demonstrated extensive technical expertise in all licensing areas and has been responsive to NRC requirements and requests by generally providing complete information in a timely manner. The high quality of the technical resolutions and the overall responsiveness of the licensee demonstrates good management support, and licensee commitmen The inspectors review of the licensee actions taken in response to NRC information notices, bulletins, generic letters, and 10 CFR Part 21 reports showed appropriate distribution and level of review. The licensee matitained adequate records of actions.taken, and if no actions were required, a sufficient justification was provided. A regional inspection of licensee actions based on a 10 CFR Part 21 report that resulted from

valve stem failures of two motor-operated valves during

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preoperational testing indicated that the licensee's corrective actions, including testing and requesting General Electric to perform an evaluation, demonstrated a clear understanding of the 'tsue. Viable, generally sound and thorough t.pproaches

were applied to this effort.

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During this assessment period, the licensee was responsive to allegations made through their own quality report or hotline program In addition, several allegations received by

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NRC were transmitted to the licensee for investigation.

1 Those investigations w n e conducted in a thorough manner and

corrective actions, if appropriate, were promptly implemented, i

1 NRC evaluated lice ,ubnittals and issued eight license

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amendments and nice safety avaluations on subjects other than license amendments, during the assessment period. Licensee F submittals were technies11y sourd and complete, with one t exception. The exception was the initial application for an exemption from 10 CFR Part 50, Appendix J, which was doficient because the need for a scheduler exemption was not iovntified. All related, subsequent submittals were technically sound ard complete. The licensee's performance was more apptopriately exemplified by the analysis cont.sined in the submittals regarding the addition of test connections upstream of certain excess-flow check valves and the Nuclear Systems Protection System Self-Test System Failure Detsetion and Indication for Clinton. These examples demonstrated the licensee's good understanding of the technical issues and ability to provide sound justification for positions. An appropriate level of management and technical expertise was provided in response to all NRC requests for additional information needed to evaluate licensee submittal _ _

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The licensee was responsive to NRC licensing requirements and requests by generally providing complete information in a timely manner. The licensee has clso been equally responsive to both their own amendment / relief requests as well as NRC technical reviews required by the regulations. The licensee appropriately assigns higher priority to those issues with more safety significanc Staffing in the QA department was adequate and the technical expertise was sufficient for performing thorough audit and surveillance activities in the area examined during NRC inspection. An SRO qualified individual was assigned as a permanent member of the QA organization; in addition, technical experts from other departments were available and participated in ongoing audits. Effective QA management was eviden . Performance Rating The licensee's performance is rated Category 2 in this are Because this is a new area, no rating is available for the previous assessment perio . Recommendations None

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. pipp0RTING DATA AND SUMMARIES Licensee Activities The Clinton Nuclear Power Station began the assessment period in startup testing (Condition 6) and operated at normal power levels up to 100%, until September 21, and October 2, 1987, when the plant experierded two forced octages; the first caused by equipment malfunct. ion and the second caused by operator errors. During Octobe 1987, the licensee completed the power ascension test program and began a 35-day mainterance/ surveillance outage. The Itcensee completed the outage activities during November 1987, and the plant began commercial operation. The plant operated routinely until March 19, 1988, when a scheduled maintenance / surveillance outage started and continued through the end of June 1988. The plant operated at eFoected power levels throughout the remainder of the assessment period.

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l The licensee reported 11 ESF actuations (five ESFs were the result of personnel errors). Five reactor trips were reported. There were four automatic trips and one manual. Two trips were caused by personnel errors and three trips were related to equipment / design problems. Four trips occurred when operating above 15% power i and one below 15% power. Significant outages / major events are discussed below:

Significant Outages / Major Events

' On September 22, 1987, the plant experienced a forced outage after the reactor tripped on high reactor vessel water leve The plant remained shutdown to recalibrate one of three NPSH sensing circuit . On October 9, 1987, the 100-hours warranty run was complete . On October 14, 1987, the startup program was completed with a load rejection tes . During October 14-November 24, 1987, the plant was shutdown for a scheduled 35-day maintenance outag . During March 18-May 5, 1988, the plant was shutdown for a scheduled maintenance outage. The primary purpose of the outage was to co.1 duct all outage surveillances that would become due before the January 1989 outag Other major activities included repairs to the 'O' MSIV, cleaning and plugging of main condenser tubes, installation of condenser tubes, repairs on the RHR system full-flew test return valves, and inspection of all three emergency diesel generator _ _ _ _ _ . . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ __ _ _-. _ . _ _ _ _ _ _ _ _ - _ _ _

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l r During June 24-26, 1988, the plant shutdown after an automatic reactor trip, because of low reactor vessel water level. It- *

remained shutdown to investigate the causes of the trip, and

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repairs were made to a relay in the startup level controller for the 'B' turbine-driven reactor feedwater. pum . During July 12-13, 1988, tne plant was shutdown after a manual .

reactor trip caused by a loss of circulating water. It remained i shutdown until repairs were completed on level switches in the condenser pi l

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B. Inspection Activities [

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Thirty inspection reports are discussed in this SALP report l (September 1, 1987 through August 31,1988) and are listed in  !

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Paragraph 1 of this section, Inspection Data. Table 1 lists the violations per functional area and severity level. Significant  ;

inspection activities are listed in Paragraph 2 of this section, I Special Inspection Summar ,

. Inspection Data

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Facility : Clinton

, Docket No.: 50-461 t Inspection Report Nos.: 87010, 87027, 87032 through  !

87040, 88002 through 88019, and 88021 l

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Table 1 i Number of Violations in Each Severity Level _

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Functional Areas  !!! IV V  ;

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Plant Operations 3 1 Radiological Controls

Maintenance / Surveillance 6 2 Emergency Preparedness Security 1 , Engineering / Technical Support 1** 1 -

Safety Assessment / Quality 6

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Verification ,

TOTALS III IV V j

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! " This violation was identified during SALP 7, but was not issued until SALP 8 (Inspection Report 461/88010). It is included in the totals for this SALP perio ; Special Inspection Summary f

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Significant inspections conducted during this SALP 8 i :ssessment period are listed below: ,

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4 A special team inspection was conducted during  !

March 21-April 15, 1988, to assess the effectiveness l

! of the licensee's quality verification organization i

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l (Inspection Report No. 461/88007).

i A special inspection was conducted during February 25 1 -March 31, 1988, related to EQ. The findings during I i this inspaction resulted in escalated enforcement l l actions, and a Civil Penalty of $75,000 was issued [

i (Inspection Report No. 461/88010 Enforcement Notice l

! No. EA-88-090).  !

, A special security inspection was conducted during  ;

i Aprt) 5-8, 1988, regarding the April 4,1988, failure [

l to adequately control access to a vital area. An '

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enforcement conference was held on April 21, 1988, j and no Civil Penalty was issued (Inspection Report i No. 461/88011, Enforcement Notice No. EA-88-111). l An emergency preparedness exercise was conducted during j l

April 25-27, 1988 (Inspection Report No. 461/88012).  ;

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C. Escalated Enforcement Actions A Severity Level III violation, and proposed imposition of a Civil Penalty in the amount of $75,000 was issued to the licensee on May 26, 1988. This action was based on violations relating to the licensee's failure to assure that electrical equipment important to safety, involving electrical connectors and junction boxes, was environmentally qualified. This resulted in a significant deficiency which could have led to equipment failures during postulated accident conditiens in multiple safety system Escalation and mitigation factors of the enforcement policy were considered. While the licensee took prompt corrective action, prior notices had been issutd by NRC and multiple safety systems were affected by the violations. NRC received a response dated June 1, 1988, in which the licensee challenged the Civil Penalty. This case is presently under NRC evaluation. (Inspection Report No. 461/88010 Enforcement Case No. EA-88-090, Enforcement Notice No. EN-88-041).

A Severity Level III violation was issued tc 'he licensee on May 3, 1988 for inattentiveness of a security officer posted at an open vital area door. A Civil Penalty was not imposed because of the licensee's prompt identification and reporting and unusually prompt and extensive corrective action D. Confirmatory Action Letters i None Licensee Amendments Issue _d Amendments N Description Date 1 Technical Specification March 18, 1988 (TS) change to extend specified valve local leak test until the first refueling outag TS change to add test March 21, 1988 connections upstream of certain excess-flow check valve i 3 Amendment to Paragraph 2.2E July 26, 1988 of the license requiring compliance with the amended physical security pla '

l 4 TS change to correct August 3, 1988 action statement associated I with reactor water level

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low-low level 2 channels for reactor water cleanup '

isolatio TS change to safety August 3, 1988 relief valve low-low function setpoint tolerance and the MSIV leakage control syste TS change to the August 8, 1988 radioactivity rate of noble gases of off gas recombiner effluen '

7 TS change to add test August 9, 1988 connections upstream of certain excess flow check valve ,

8 TS request to change August 15, 1988 DC battery load F. Review of Licensee Event Reports Submitted by the Licensee Forty LERs were issued in accordance with NUREG-1022 guidelines during this assessment period. Table 2 shows a cause code ccmrarison of the SALP 7 and 8 cycle LER Nos. 87052 through 87070 88001 through 88021 ,

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- Table 2

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(12 M0) (12 MO)

Cause Areas SALP 7 SALP 8 No. (Percent) No. (Percent)

Personnel Errors 36 (47.4%) ~23 (57.5%)

Design Problems 0 ( 0.0%) 3 ( 7.5%)

External Causes 0 ( 0.0%) 0 ( 0.0%)

Procedure Inadequacies 15 (19.7%) 2 ( 5.0%)

Component / Equipment 25(32.9%) 12 (30.0%)

Other/ Unknown 0 ( 0.0%) 0 ( 0.0%)

TOTALS 76 40 FREQUENCY (LERs/MO) .3 NOTE: The soove LER information was derived from review of LER's performed by NRC staff and may not completely coincide with the licensee's cause assignment _