IR 05000461/1990006

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Insp Rept 50-461/90-06 on 900317-0511.Noncited Violations Noted.Major Areas Inspected:Previous Insp Findings, Operational Safety,Event Followup,New Fuel Receipt,Maint/ Surveillance & Mods & Changes to Facility
ML20043E938
Person / Time
Site: Clinton Constellation icon.png
Issue date: 06/01/1990
From: Lanksbury R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20043E935 List:
References
50-461-90-06, 50-461-90-6, NUDOCS 9006140017
Download: ML20043E938 (29)


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U. S. NUCLEAR REGULATORY COMMISSION i

REGION III

t Report No.- 50-461/90006(DRP)

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Docket No. 50-461 License No. NPF-62 f

Licensee:

Illinois Power Company

500 South 27th Street i

Decat,ur, IL 62525

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facility Name:

Clinton Power Station

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Inspection At:

Clinton Site, Clinton, Illinois Inspection Conducted:

March 17 - May 11, 1990

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Inspectors:

-P. G. Brochman S. P. Ra

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t Approved By:

. Lanihs f

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Re r Projects Section 3B Dats

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Inspection Summary

t-3n Inspection +from f. arch 37*May'11t 1990 *(Report'Nor-50-461/90006(DRP))3 "" '

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Areas Inspected:

Routine, unannounced safety inspection by the resident inspe.: tors of licensee action on previous inspection. findings; operational safety; event follow-up; new fuel. receipt; maintenance / surveillance; regional-i requests; modifications and' changes to the facility; and meetings.

Results:

Ouring this irrection period a non-cited violation was identified

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and reviewed in the area of maintenance.

The violation involving a personnel error by a maintenance planner who specified a step in a post maintenance test-which removed the particulate filter from a radiation monitor without-specifying the related step to reinstall the filter.

Other weaknesses were

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noted in the areas of plant operations involving communications and procedural

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compliance.

Examples were the condenser waterbox overpressurization and

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cracking, the nuclear system protection system bus de-energization, and the

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improper rod withdrawal event.

Performance in the area of safety assessment remained the same.

Problems were noted in the area of engineering and

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~ technical support, which were principally a function of design errors during

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9006140017 900601

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PDR ADOCK 05000461

PDC

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DETAILS 1.

Persons Contacted Illinois Power Company (IP)

  1. W. Kelley, Chairman and Chief Executive Officer
    1. J. Perry, Vice President
    1. J. Cook, Manager - Clinton Power Station
    1. J. Miller, Manager - Nuclear Station Engineering-
    1. R. Morgerptern, Manager - Scheduling and Outage Management
    1. J. Palmer, Manager - Nuclear Training
    1. J. Palchak, Manager - Nuclear Planning and Support
    1. F. Spangenberg, III, Manager - Licensing and Safety
    1. R. Wyatt, Manager - Quality Assurance
    1. S. Hall, Director - Nuclear Program Assessment
  1. D. Morris, Director - Plant Operations
    1. R. Phares, Director - Licensing
  1. S. Pasor, Director - Plant Maintenance
    1. K. Baker, Supervisor, I&E Interface

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Soyland Power

    1. J. Greenwood, Manager - Power Supply l

The inspector also contacted and interviewed other licensee and contractor personnel during the course of this inspection.

v.# Denotes-thos,e present during the management meeting on April 12, 1990.

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  • Denotes those present during the exit interview on May 11, 1990.

l 2.

Action on Previous Inspection Findinas (92702)

(Closed) Open Item 461/88004-05:

Failure of Division III Diesel Generator Air Start Motors.

This item was previously discussed in Inspection Report 461/88004, paragraph 9.b.(9) and closed in Inspection Report 461/89038, paragraph l

3.c.

The item was closed based partially on the licensee's decision to completely disassemble, lubricate and reassemble new air start motors t

before they were placed in storage.

Since the open item was closed, the licensee's investigation has determined that the root cause of the air start motor failures was not a mixed lubrication problem as first believed, but'rather was due to incorrect bendixes being put in the

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motors when they were converted from lef t-hand drive to right-hand drive during construction.

The licensee-determined that they could safely delete the commitment to rebuild Ingersoll-Rand air start motors used in the division III diesel

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generator upon receipt.

They still intended to rebuild POW-R-QUIK air start motors used in the division I and II diesel generators.

The

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licensee also decided to revise the maintenance procedure for installing l

the motors so that correct rotation of the bendix will be verified and will review the November 10, 1988, special report of the diesel generator failure for revision of the root cause.

This item is considered closed.

No violations or deviations were identified.

3.

Plant Operations a.

Summary of Operations The inspection period began with the unit in a forced outage due to a failure of a local leak rate test on containment isolation valves.

The unit remained shutdown through planned outage (PO-3) which began on March 21, 1990.

PO-3 was extended longer than the original plan a

due to emergent work required to balance the shutdown service water system.

Inspection Report 461/90005(DRS) discussed the results of an NRC special team inspection of that issue.

The unit was taken critical at 5:59 p.m. on April 8, and was

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synchronized to the grid at 9:00 p.m. on April 10.

During the subsequent power increase on April 11, control rods were withdrawn,

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while above the low power setpoint of the rod pattern control system, with the turbine bypass valves open; which was contrary to the Technical Specifications.

Illinois Power senior management decided to shut the plant down to emphasize the significance of the event and to conduct extra training for licensed operators.

The-generator

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was taken off line at 9:42 p.m. on April 13, the reactor was

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shutdown at 6:40 a.m. on April 14, and the plant reached cold

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  • shutdown"at' 5:45:' lm. 'on April'15; Inspection' Report 461790009'(DRP)" * 'f7 T d a

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discussed the results of an NRC special team inspection of the event,

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The unit was again taken critical at 9:01 p.m. on April 22, and t

synchronized to the grid at 1:M p.m. on April 24.

During the subsequent power increase or, ail 26, the unit experienced a turbine runback of about 55 NWe due to a failure of the generator

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stator cooling water flow comparator circuit.

The circuit was bypassed and the power ascension continued to 100% power.

L On May 8, the division I and II diesel generators were both declared l

inoperable when they were determined to be in an unanalyzed l

condition after it was discovered that tie rods designed to limit

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the relative motion of service water (SX) expansion bellows on the-SX supply to both diesels were not installed.

A Notification of

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Unusual Event was declared and a controlled shutdown was started in accordance with Technical Specifications.

The unit was manually scrammed from about 25% power at 7:26 a.m. on May 9 to place the unit in Hot Shutdown.

The unit was taken to Cold Shutdown at 5:15 a.m. on May 10, and remained shut down for the rest of the report period.

Inspection Report 461/90012 discussed the results of a special team inspection of that event.

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Operational Safety (71707)

The inspectors observed control room operation, reviewed applicable logs and conducted discussions with control room on.rators during the inspection period.

During these discussions and observations, i

the inspectors ascertained that the operators were alert, cognizant of plant conditions, and attentive to changes in.those conditions.

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and that they took prompt action when appropriate. The inspectors verified the operability of selected emergency systems, reviewed tagout. records, and verified the proper return to service of affected components.

Tours of the containment, auxiliary, fuel-hjndling, diesel and control, radwaste, and turbine buildings

were conducted to obs arve plant ' equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations, and to verify that maintenance requests had been initiated for equipment

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in need of maintenance.

The inspectors verified by observation and direct interviews that

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the physical security plan is being implemented in accordance with the station security plan.

The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls.

The inspectors also witnessed portions of the radioactive waste system controls associated with rad-waste shipments and processing.

The observed facility operations were verified to be in accordance with the requirements established under Technical Specifications,

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10 CFR, and administrative procedures.

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Additional observations of control room activities, during this inspection period, were discussed in Inspection Report No. 461/90009(DRP).

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Onsite Event Follow-up (93702)

i The inspectors performed onsite follow-up activities for events

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which occurred during the inspection period.

These follow-ups included reviews of operating logs, proceduras, Condition Reports, Licensee Event Reports (where available), and interviews with licensee personnel.

For each event, the inspectors developed a chronology, reviewed the functioning of safety systems required by plant conditions, and reviewed licerisee actions to verify consistency with procedures, license conditions, and the nature of the event.

Additionally, the inspectors verified that the licensee's investigation had identified the root causes of

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equipment malfunctions a.nd/or personnel errors and that the licensee had taken appropriate corrective actions prior to restarting the unit.

Details of the events and the licensee's corrective actions developed through inspectors' follow-up are provided in paragraphs (1) through (4) below:

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(1) Cracking of Condenser Waterboxes On March 18, 1990, the unit was in cold shutdown and the operators were preparing to return the circulating water (CW)

system to operation.

At 6:09 a.m., a control room operator

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started a CW pump without moving the condenser waterbox outlet r

valves to their proper position.

Consequently, when the pump.

was started, a hydraulic shock was delivered to the waterboxes which cracked the A and B waterbox inlets and outlets.

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largest crack was six feet-long and 1/2 inch wide.

There were many other cracks, some of which did not penetrate through the wAterbox wall.

Approximately 27,000 gallons of water was

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spilled into the condenser pit before the CW pump could be j

secured.. The licensee performed an ultrasonic examination of

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the waterboxes to identify any additional cracks and completed

weld repair, with post heat treatment, on all identified

cracks.

The licensee improved the position indicators for the j

outlet valves and revised the procedure for starting the CW

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pumps.

The licensee performed an Human Performance Evaluation System (HPES) evaluation of this event and identified the following j

causes:

Communications:

No briefing was conducted before the evolution.

The position of the outlet valves was not adequately communicated from one reactor operator to, another.

Assumptions were made about valve position, t

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without regard to available indications.

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communication path'between the control room and the

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condenser was inadequate.

The position of the valves

was not verified just prior to the pump start.

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Supervision:

Supervisory involvement was not adequate.

L The control room supervisor had not reviewed the l

procedure.

Plant management considered this event a

" critical" evolution, because of previous events where o

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the waterbox had been cracked; however, this fact was not-understood by the control room supervisor and the reactor

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operators.

Preparation:

The reactor operators performed a minimal a

review of the procedure; consequently, they were unaware that significant changes to the procedure had occurred.

Additionally, this is an infrequently performed evolution.

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Operators were under pressure to perform this evolution

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quickly, due tc problems with keeping the waterbox full of water.

(2) Engineered Safety Feature Actuation due to De-eneraizing the Division 11 Nuclear System Protection System Bus I-

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On March 31, 1990, the licensee reported that an engineered

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safety feature (ESF) actuation had occurred.

The event was caused when a non-licensed operator was re-energizing the l

nuclear system protection system (NSPS) inverter for the i

division II NSPS bus.

Both the non-licensed operator and the

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licensed reactor operator who directed him to perform the evolution were unsure whether the NSPS bus was de-energized or being powered from the alternate AC supply.

The non-licensed operator at the local panel incorrectly determined that the

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NSPS bus was not powered and proceeded to re-energize the

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inverter using a part of the procedure that first called for

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opening all the bus load breakers.

When the breakers were opened, several actuations occurred i

including a containment isolation of several groups, reactor

trip signal, reactor water cleanup system isolation and trip, reactor core isolation cooling (RCIC) system actuation signal,

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and low pressure coolant injection (LPCI) system actuation

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signal for the "B" and "C" LPCI pumps.

No water was actually

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injected into the vessel because the RCIC system was interlocked from starting due to low reactor pressure and the

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LPCI pumps were tagged out.

No actual rod motion occurred

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because the reactor was shutdown and a scram signal was already present.

All equipment appeared to function as expected.

  • The four NSPS buses were normally energized by AC power from inverters fed from the safety-related batteries.

The buses

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could also be powered from alternate AC sources by changing the state of a static transfer switch or by rotating a manual

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transfer switch.

The static switch changed states ^

automatically if the inverter output was lost and could also be r

changed by the use of pushbuttons on the local panel.

A mimic of the system with various lights and indications was on the local panel.

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The inspectors-attended the event critique in which several

errors were discussed.

The NSPS bus had been placed on the

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alternate AC supply and the inverter secured during the

previous shift.

The information about the status of the bus had not been clearly communicated to the reactor operator on the next shift, although other individuals on the shift were

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aware of the status.

The bus had been transferred to the alternate supply by using the static switch pushbutton instead of the more usual manual bypass switch. Although the procedure i

contained instructions for transferring power using either method, the use of the manual switch was specified in the part.

of the procedure for securing the inverter.

The use of the pushbutton instead of the manual switch made it harder for the non-licensed operator to determine the status of.the bus by

looking at the panel.

An indicating light which would indicate that the alternate AC source is being fed through the static

switch was powered from the DC input so that it was not lit

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when the inverter was secured.

This led the non-licensed operator to believe that the bus was not powered.from the alternate source.

The local p aol contained output voltage, frequency, and current meters which were showing normal AC power to the NSPS bus, but the non-licensed operator stated that he believed that the meters would have failed "as-is" when

the bus was de-energized.

i The licensee submitted Licensee Event Report (LER)90-007 to report their evaluation of the root cause and corrective actions for this event.

The inspectors will review the licensee's

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c,ptrective actions when the LER is closed.

The LER did not discuss a corrective action to evaluate the design of the

indicating lights on the. inverter's mimic panel although, i

in this case, that design contributed to the cause of the

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event.

During the exit meeting for this report, the inspectors

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recommended that the licensee perform a design review.

L (3) Turbine Runback

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On April 26, 1990, while increasing power from about 50% to

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70%, a turbine runback occurred.

Generator load decreased from

480 to 425 MWe and two turbine bypass valves opened.

The runback was apparently caused by-a failure of the generator stator cooling water flow comparator instrument.

During the time that turbine bypass valves were opened, the operators

entered a Limiting Condition for Operation in accordance with Technical Specification 3.1.4.1 and stationed a second licensed

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operator to prevent the withdrawal of control rods.

Control

,, M rods.werei nser.ted to.'cause the1 bypass 9alves to'closerabout'40

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minutes after the runback.

The licensee installed a temporary modification to disable the runback feature. Additional inspectors' observations concerning

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the temporary modification are discussed in paragraph 6.b. of this report.

As part of the corrective action for the rod withdrawal event

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reported by the licensee in LER 90-008, the licensee changed the Sentinel Log of the General Electric Transit Analysis Recording System (GETARS) so that the opening of the first

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turbine bypass valve to five percent would cause a trip of the GETARS Sentinel trip annunciator in the main control room.

During the inspectors' review of the runback event, the reactor operator who had been in the main control room told the inspectors that the annunciator had not activated.

Later, the Shift Technical Advisor who had been on duty told the

' inspectors that he had turned off the GETARS shortly before the runback in order tro prevent a spurious activation of the system during an anticipated feedwater pump evolution.

During the exit meeting for this inspection, the inspectors informed the licensee of the finding and suggested that their policy for control of the GETARS be reviewed.

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(4) Shutdown Required by Technical Specifications Due to Unanalyzed Dondition in Diesel Generator Service Water Piping On May 8, 1990, the licensee informed the NRC via the Emergency Notification System (ENS) of a Notification of Unusual Event (NOUE).

They had declared both the division I and II emergency diesel generators inoperable and were commencing a plant shutdown in accordance with Technical Specification 3.8.1.1.

The diesels had been declared inoperable when the licenseo discovered that tie rods were not installed on the thermal ej:pansion bellows on the inlet and outlet service water piping-for the diesel generator's heat exchangers.

The tie rods were designed to limit the amount of expansion of the bellows to prevent damage to the associated piping and supports.

While-investigating the missing tie rods, damage was noted to one of the rigid supports on the division I diesel service water piping and displacement was noted on division II piping.

Because of the possibility that the piping may have been overstressed, the licensee determined that this was an unanalyzed condition and declared the diesels inoperable while

they investigated.

~ A controlled shutdown was started on the evening of May 8 and i

the reactor was scrammed from about 25% power on the morning of May 9 at which time the NOUE was terminated.

The licensee made a second ENS notification on May 9 concerning potential media interest in the event.

The plant reached Cold Shutdown on.

May 10, 1990.

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l This issue was being reviewed'in Inspection Report

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No. 461/90012(DRP).

d.

New Fuel Receipt (60705)

During this inspection period the licensee began receiving and inspecting new fuel for use in the next refueling.

The inspectors made selected observation of the new fuel receipt activities.

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I general, the evolutions were performed carefully and correctly with

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adequate supervision.

The inspectors observed one incident in which a worker on the top of the unloading stand hit his head on the crane hook after the hook was' lowered, apparently without his knowledge.

This incident was discussed with plant management including the Director - Industrial Safety.

Early one morning, the inspectors noted that one of the radiation

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protection instruments in use on the fuel floor had not been response l

checked that day. When it was pointed out to the radiation i

protection technician at the site, he indicated that he was confused about the date and thought it was actually the date indicated on the

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source response sticker.

He immediately took the instrument to be source checked and checked all his other instruments.

Since it was relatively early in the day, and the instrument had been source I

checked about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> earlier, the inspectors did not consider the finding as a violation of the instrument surveillance procedure.

The stickers used by radiation protection on instruments to record daily source checks all start with the first day of the month in the upper left hand corner.

This can create confusion because the stickers look like calendar pages but do not match the format of a l

calendar except when the first day of the month happens to fall on a l

Sunday.

The inspectors discussed the observation with the Director

- Radiation Protection.

No violations or deviations were identified.

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4.

Maintenance / Surveillance (61726 & 62703)

Station maintenance and surveillance activities of the safety-related i

systems and components listed below were observed or reviewed to

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ascertain that they were conducted in accordance with approved

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procedures regulatory guides, and industry codes or standards, and i

in conformance with Technical Specifications.

The following items were considered during this review:

the limiting

conditions for operation were met while affected components or systems were removed from and restored to service; approvals were obtained prior to initiating work or testing; quality control records were maintained; parts and materials used were properly certified; radiological and fire

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  • prevention 'controis-were: accomplished *in' accordaricehith. approved" !".!' T '

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procedures; maintenance and testing were accomplished by qualified

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personnel; test instrumentation was within its calibration interval; functional testing and/or calibrations were performed prior to returning components or systems to. service; test results conformed with Technical Specifications and procedural requirements and were reviewed by personnel other than the individual directing the test; any deficiencies identified

during the testing were properly documented, reviewed, and resolved by appropriate management personnel; work requests were reviewed to determine the status of outstanding jobs and to assure that priority was assigned to safety-related equipment maintenance which may affect system performance.

The following maintenance and surveillance activities were observed:

Activity Title CPS No. 2800.10 Service Water System Flow Balancing CPS No. 9000.09 Control Rod Manipulation CPS No. 9031.14 IRM Channel Functional Test l

CPS No. 9080.06 Division I Diesel Generator Monthly Test CPS No. 9080.14 Division III Diesel Generator Monthly Test j

CPS No. 9431.61 APRM Setpoint Verification

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MWR D14754 Division II VX Chiller Inspection HWR 015459 Install Tie Rods on Division I Diesel i

Bellows Several other maintenance and surveillance activities were observed during the special team inspection reported by Inspection Report

No. 461/90005(0RS).

j a.

On March 22, 1990, the licensee identified that a particulate filter was not installed in heating, ventilating and air conditioning (HVAC) stack discharge process radiation monitor ORIX-PR002.

The missing particulate filter rendered the iodine and particulate channels of the monitor inoperable.

The monitor had been required by Technical Specification 3.3.7.12 to be operable from 9:15 a.m. on

March 21, when the monitor was incorrectly declared operable after

maintenance, until 10:45 p.m. on March 22, when the filter was installed.

The licensee reported the event to the NRC as LER 90-006.

The event was not considered safety significant because the plant was shutdown during the time that the monitor was inoperable and other monitors capable of monitoring releases under design basis conditions were operable.

The cause of the event was attributed to personnel error.

A modification to install a mass flow meter in the monitor had just been completed.

The maintenance planner who specified the post

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maintenance test to be performed after the modification specified that certain steps in the monitor's calibration procedure be

performed.

The steps specified included a step which removed the

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particulate filter but did not include the step to reinstall the

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filter. -The licensee's corrective actions included a planned-

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revision to Administrative Procedure CPS 1502.01, " Conduct of Maintenance," to provide guidance for specifying the use of partial procedures for maintenance activities.

Training for maintenance planners on the use of partial procedures was also to be held.

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addition, monitor calibration procedures were to be reviewed and revised as necessary to insure that verification of filter r

reinsta11ation steps are in the appropriate places in the procedure.

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The LER indicated that LER 87-040 discussed a similar event in which

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l the particulate filter was missing from the HVAC common stack high I

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range gaseous effluent monitor.

That event was discussed in Inspection Report No. 461/87031, paragraph 10.c.(2), and was considered a licensee-identified, non-cited violation (461/87031-08).

Although not mentioned in LER 90-006, the event was also similar to an event reported in LER 87-068 in which the particulate filter was discovered missing from the standby gas treatment exhaust high range

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radiation monitor.

This event was discussed in Inspection Report No. 461/87039, paragtaph 9.b.(2) and was one part of Violation 461/87039-01.

The inspectors reviewed these two previous events to determine if corrective actions for those violations should have prevented the

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event on March 22, 1990.

Corrective actions for the previous events were adequate in that they included incorporating steps into the calibration procedures to verify that the particulate filters were

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installed.

In the March 22 event, the procedural steps were available but were not specified to be performed by the maintenance planner.

For this reason, the inspectors determined that the March 22 event was not one that should have been prevented by

corrective actions on previous violations and the event was considered a " licensee-identified" violation (NCV 461/90006-01).

l The violation was not cited because the criteria specified in Section V.G.1 of the Enforcement Policy were satisfied. This issue is considered closed.

The inspectors intend to review completion i

of'the long3 term corrective actions when the LER is closed.

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b.

On April 18, 1990, during a post maintenance test run of the

division 11.1 diesel generator, the test was aborted when it was noted that one of the air start motors did not disengage.

An investigation determined that the air start motor had been installed

incorrectly in that it was canted slightly in its mounting.

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caused excessive binding between the air start motor bendix gear and the bull gear on the diesel.

This was the first failure of this type experienced at Clinton.

The cause appeared to be an isolated maintenance error.

The licensee considered the diesel test to be an invalid test performed for troubleshooting in accordance with

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Regulatory Guide 1.108, Revision 1, and thus did not consider the event to be reportable as a diesel failure in accordance with

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-Technical Specification 4.8.1.1.3.

Air start motor installation procedures were being reviewed to determine if the installation instruction could be improved to prevent recurrence.

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c.

On' April 27, 1990,'the licensee identified thaf, the particulate

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filter paper in drywell fission product monitor IE31-P002 was not advancing on 4 take-up reel.

The licensee's investigation determined t M the paper had probably not been advancing since at least April 4 1990.

This period included about 12 days in which

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the plant was in Operational Conditions 1 or 2 and the monitor was t

required to be operable.

t The licensee was investigating the finding and intended to submit their analysis in LER 90-009.

The inspectors intend to-review the

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event in more detail when the LER is issued and determine if a Notice of Violation is appropriate, i

l No deficiencies were identified, however, one non-cited violation was

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identified.

l 5.

Engineering and Technical Support Several engineering issues were reviewed by the inspectors during this l

inspection period, but all were being followed up by regional inspectors and were documented in other reports.

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a.

The inspectors spent considerable time following the licensee's actions to resolve the issues of shutdown service water flow.

Inspection Report 461/90005 (DRS) reported the inspectors'

findings concerning this issue.

b.

As discussed in Inspection Report 461/90001, paragraph 7.b.(2), the licensee discovered that certain Automatic Switch Company (ASCO)

solenoid valves in safety-related applications could fail due to failure of nonsafety-related air regulators providing air to them.

The licensee reported the results of their investigation and corrective actions for this finding as LER 90-004.

Inspection Report 461/90007(DRS) documented the NRC review of this issue.

During the inspectors' followup of the issue, they reviewed Quality Assurance Surveillance Report Q-13833.

The surveillance was-performed to verify the adequacy of the proposed corrective actions for Condition Report 1-90-03-056 which tracked the ASCO issue.

The inspectors noted that the surveillance indicated that the ASCO solenoid valves internal to the hydrogen / oxygen monitors were considered not to have a post accident function.

The inspectors informed the QA supervisor that the monitors were required to be operable for post accident mitigation and the surveillance was revised to require Nuclear Station Engineering to address those valves in their corrective action.

No violations or deviations were identified.

6.

Safety Assessment / Quality Verification a.

Regional Request (92700)

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On April 18, 1990, the inspectors provided the licensee with information from another utility concerning problems with speed

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control of Model 8271-2301 Woodward governors used on emergency diesel generators.

Regional management requested that the inspectors determine whether Clinton had the same model governors and whethe: they had experienced any problems with speed control.

i The licensee provided the requested information to the inspectors on April 20, 1990.

The governors on Clinton's emergency diesel generators are Woodward Model 8271-2301A.

They had Model 8271-2301

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governors installed originally but problems were encountered with i

speed oscillations during startup testing due to circuit noise in j

the power supply. The governors were subsequently replaced with the

"A" model.

The "A" model had updated electronic circuits, a different power supply which did not use dropping resistors, and t

other improvements.

Since that time no problems of the same nature as those described in the regional request have been experienced.

The licensee's response to the NRC's safety concern was very prompt and demonstrated due regard to followup of industry events..The system engineer for the diesel generators was especially cognizant

of the issue and thoroughly researched the event.

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b.

Inadequate Safety Evaluation of Temporary Modification (37828)

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On April 26, 1990, while following up the licensee's actions in I

response to a turbine runback discussed in paragraph 3.c.(3), the

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inspectors identified a concern with the safety evaluation for a

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temporary modification.

Temporary Modification 90-21 had been i

approved and installed on April 26 to prevent an inadvertent runback i

of the turbine generator due to a faulty generator stator cooling low-low flow transmitter.

The Safety Evaluation Screening Form SE-1 for the temporary modification justified not performing a written

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full safety evaluation in accordance with 10 CFR 50.59 because the generator runback circuit af fected by the temporary modification was

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not described in the Clinton Updated Safety Analysis Report (USAR)

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and generator functional characteristics and its protection were not j

affected.

The inspectors reviewed Section 10.2.2.5, " Turbine Protection System," of the USAR and noted that although the runback feature was i

not described, a turbine trip was described on " prolonged loss of generator stator cooling at loads in excess of a preset value."

I This feature was intended to protect the generator if a. runback i

failed to clear a problem in stator cooling within a preset time.

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The runback and potential trip would occur on either low stator cooling water pressure, high stator cooling water temperature, or low stator cooling water flow for a given load.

Thus by disabling

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the low flow comparator runback, the licensee effectively changed the turbine trip described in the USAR.

The inspectors discussed their concern with the Staff Assistant

~'Shif t' Supervisor'who" issued Condition ' Report'h90-04-082 and'

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returned the safety evaluation screening to Engineering for further review.

Engineering personnel told the inspectors that they had realized that the temporary modification would remove one of the inputs to the turbine runback / trip system, but that the other two

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diverse inputs insured that the trip feature described in the USAR

was still operable and thus a written safety evaluations was not

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necessary.

The inspectors reviewed the USAR and references used in developing the design basis of the trip system in the USAR and could find no specific description of the logic.

Thus, technically a written i

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safety evaluation was not required but the inspectors pointed out

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that since the screening sheet did not even mention that generator stator cooling low flow could cause a turbine trip, it may have misled tra licensed Senior Reactor Operator who approved the installation of the temporary modification.

The licensae agreed to l

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perform a written safety evaluation for the temporary modification and~the Manager Clinton Power Station established a policy to s

perform written safety evaluation of all temporary modifications until the procedure for screening changes was reevaluated.

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No violations or deviations were identified.

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7.

Management Changes On April 2, 1990, Mr. R. Freeman, Manager - Nuclear Station Engineering Department lef t the 1111nois Power Company.

He was replactd by Mr. J. Miller, formerly Manager - Scheduling and Outage Mar agement.

Mr. Miller was replaced by R. Morgenstern, formerly Directar - Plant i

Technical Staff.

Mr. Morgenstern was replaced by K. Moort, formerly a supervisor in the Technical Staff.

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8.

Items For Which A " Notice Of Violation" Will Not Be Issued

l The NRC use; the Notice of Violation as a standard method for formalizing i

the existence of a violation of a legally binding requirernent.

However,.

j because the NRC wants to encourage and support licensee initiative in the i

self-identification and correction of problems, the NRC will not generally issue a Notice of Violation for an issue that meets the tests of 10 CFR 2, Appendix C, Section V.G.I.

These tests are: 1) the issue was identified

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by the licensee; 2) the issue would be categorized as Severity Level IV

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or V violation; 3) the issue was reported to the NRC, if required; 4) the

issue will be corrected, includin a reasonable time period; and 5) g measures to prevent recurrence, within t

it was not a issue that could reasonably be expected to have been prevented by the licensee's corrective action for l

a previous violation.

In addition, in accordance with Section V.A. of the enforcement policy, for isolated Severity Level V violations, a Notice of Violation normally will not be issued regardless of who identifies the violation provided that the licensee has initiated appropriate corrective action before the inspection ends.

An issue involving the failure to meet regulatory requirements, identified during the inspection, for which a Notice of Violation was not issued is discussed _in paragraph 4.a.

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9.

Meetings a.

Management Meetings (30702)

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On April 12, 1990, Messrs. A. Bert Davis, Regional Administrator, R. C. Knop, Chief, Reactor Projects Branch 3, F. L. Brush, and the NRC resident inspectors met with Messrs. W. J. Kelley, Chairman and i

CEO, J..S. Perry, Vice President, and licensee managers and supervisors denoted in paragraph 1 of this report.

This meeting was held for the licensee to provide information on the shutdown service water flow findings, air operated valve questions and other technical topics of interest.

The licensee also provided information of the the status of their initiatives for 1990.

The Regional Administrator acknowledged the information and expressed his concern about the performance of licensed operators during the recent improper rod withdrawal event and with the response to date of the licensee.

b.

Exit Interview (30703)

The inspectors met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on May 11, 1990.

The inspectors summarized the purpose and scope of the inspection

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.and the: findings.- The inspectors also discussed the'likely'

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informational content of the inspection report, with regard to l

documents or processes reviewed by the inspectors during the j

inspection.

The licensee did not identify any such documents or

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DETAILS

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1.

Persons Contacted Illinois Power Company (IP)

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  1. W. Kelley, Chairman and Chief Executive Officer
    1. J. Perry, Vice President

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    1. J. Cook, Manager - Clinton Power Station

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    1. J. Miller, Manager - Nuclear Station Engineering
    1. R. Morgenstern, Manager - Scheduling and Outage Management

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    1. J. Palmer, Manager - Nuclear Training
    1. J. Palchak, Manager - Nuclear Planning and Support
    1. F. Spangenberg, III, Manager - Licensing and Safety
    1. R. Wyatt, Manager - Quality Assurance
    1. 5. Hall, Director - Nuclear Program Assessment
  1. D. Morris, Director - Plant Operations

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' *#R. Phares, Director - Licensing

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  1. S. Rasor, Director.- Plant Maintenance
    1. K. Baker, Supervisor, I&E Interface Soyland Power
    1. J. Greenwood, Manager - Power Supply

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The inspector also contacted and interviewed other licensee and contractor personnel during the course of this inspection.

  1. Denotes those present during the management meeting on April 12, 1990.
  • Denotes those present during the exit interview on May 11, 1990.

2.

Action on Previous Inspection Findings (92702)

(Closed) Open Item 461/8800905:

Failure of Division III Diesel Generator

Air Start Motors.

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This item was previously discussed in Inspection Report 461/88004, paragraph 9.b.(9) and closed in Inspection Report 461/89038, paragraph 3.c.

The item was closed based partially on the licensee's decision to completely disassemble, lubricate and reassemble new air start moto.s s

before they were placed in storage.

Since the open item was closed, the L

L licensee's investigation has determined that the root cause of the air start motor failures was not a mixed lubrication problem as first believed, but rather was due to incorrect bendixes being put in the motors when they were converted from left-hand drive to right-hand drive during construction.

The licensee determined that they could safely delete the commitment to

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L rebuild Ingersoll-Rand air start motors used in the division III diesel

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generator upon receipt.

They still intended to rebuild POW-R-QUIK air I

start motors used in the division I and 11 diesel generators.

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licensee also decided to revise the maintenance procedure for installing the motors so that correct rotation of the bendix will be verified and will review the November 10, 1988, special report of the diesel generator failure for revision of the root cause.

This item is considered closed.

No violations or deviations were identified.

3.

Plant Operations a.

Summary of Operations The inspection period began with the unit in a forced outage due to a failure of a local leak rate test on containment isolation valves.

The unit remained shutdown through planned. outage (PO-3) which began

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on March 21, 1990.

PO-3 was extended longer than the original plan

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due to emergent work required to balance the shutdown service water

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system.

Inspection Report 461/90005(DRS) discussed the results of i

an NRC special team inspection of that issue.

The unit was taken critical at 5:59 p.m. on April 8, and was synchronized to the grid at 9:00 p.m. on April 10.

During the subsequent power increase on April 11, control rods were withdrawn, while above the low power setpoint of the rod pattern control system, with the turbine bypass valves open; which was contrary to the Technical Specifications.

Illinois Power senior management decided to shut the plant down to emphasize the significance of the event and to conduct extra training for licensed operators.

The generator was taken off line at 9:42 p.m. on April 13, the reactor was

shutdown at 6:40 a.m. on April 14, and the plant reached cold shutdown at 5:45 a.m. on April 15.

Inspection Report 461/90009(DRP)

discussed the results of an NRC special team inspection of the event.

The unit was again taken critical at 9:01 p.m. on April 22, and synchronized to the grid at 1:04 p.m. on April 24.

During the

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subsequent power increase on April 26, the unit experienced a turbine runback of about 55 MWe due to a failure of the generator

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stator cooling water flow comparator circuit.

The circuit was

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l bypassed and the power ascension continued to 100% power.

On May 8, the division I and II diesel generators were both declared inoperable when they were determined to be in an unanalyzed g

condition after it was discovered that tie rods designed to limit

the relative motion of service water (SX) expansion bellows on the SX supply to both diesels were not installed.

A Notification of

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Unusual Event was declared and a controlled shutdown was started in b.

accordance with Technical Specifications.

The unit was manually scrammed from about 25% power at 7:26 a.m. on May 9 to place the unit in Hot Shutdown.

The unit was taken to Cold Shutdown at 5:15 a.m. on May 10, and remained shut down for the rest of the report period.

Inspection Report 461/90012 discussed the results of a special team inspection of that event.

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b.

Operational Safety (71707)

The inspectors observed control room operation, reviewed applicable logs and conducted discussions with control room operators during the inspection period.

During.these discussions and observations, the inspectors ascertained that the operators were alert, cognizant of plant conditions, and attentive to changes in those conditions, and that they took prompt action when appropriate.

The inspectors verified the operability of selected emergency systems, reviewed tagout records, and verified the proper return to service of affected components.

Tours of the containment, auxiliary,

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fuel-handling, diesel and control, radwaste, and turbine buildings

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were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations, and

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to verify that maintenance requests had been initiated for equipment in need of maintenance.

The inspectors verified by observation and direct interviews that

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the physical security plan is being implemented in accordance with l

the station security plan.

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The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls.

The

. inspectors also witnessed portions of the radioactive waste system controls associated with rad-waste shipments and processing.

l The observed facility operations were verified to be in accordance with the requirements established under Technical Specifications, 10 CFR, and administrative procedures.

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Additional observations of control room activities, during this inspection period, were discussed in Inspection Report No. 461/90009(DRP).

c.

Onsite Event' Follow-up (93702)

The inspectors performed onsite follow-up activities for events which occurred during the inspection period. These follow-ups included reviews of operating logs, procedures, Condition Reports, Licensee Event Reports (where available), and interviews with licensee personnel.

For each event, the inspectors developed a

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chronology, reviewed the functioning of safety systems required by plant conditions, and reviewed licensee actions to verify

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consistency with procedures, license conditions, and the nature of the ever,t.

Mditionally, the inspectors verified that the

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licensee's investigation had identified the root causes of equipment malfunctions and/or personnel errors and that the licensee had taken appropriate corrective actions prior to restarting the unit.

Details of the events and the licensee's corrective actions developed through inspectors' follow-up are provided in paragraphs (1) through (4) below:

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(1) Cracking of Condenser _ Waterboxes On March 18, 1990, the unit was in cold shutdown and the operators were preparing to return the circulating water (CW)

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system to operation.

At 6:09 a.m., a control room operator i

started a CW pump without toving the condenser waterbox outlet j

valves to their proper position.

Consequently, when the punp was started, a hydraulic shock was delivered to the waterbo)es

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which cracked the A and B w3terbox inlets and outlets.

The largest crack was six feet long and 1/2 inch wide.

There were

many other cracks, some of which did not penetrate through !.he i

waterbox wall.

Approximately 27,000 gallons of water was.

i spilled into the condenser pit before the CW pump could be-secured.

The licensee performed an ultrasonic examination of

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the waterboxes to identify any additional cracks and completed weld repair, with post heat treatment, on all identified

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cracks.

The licensee improved the position indicators for the outlet valves and revised the procedure for starting the CW t

pumps.

The licensee performed an Human Performance Evaluation System (HPES) evaluation of this event and identified the following i-causes:

Communications:

No briefing was conducted before the evolution.

The position of the outlet valves was not adequately communicated from o m reactor operator to another.- Assumptions were made about valve position,

i without regard to available indications.

The

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condenser was inadequate.

The position of the valves

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was not verified just prior to the pump start.

Supervision:

Supervisory involvement was not adequate.

The control room supervisor had not reviewed the

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procedure.

Flant management considered this event a

" critical" evolution, because of previous events where

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I the waterbox had been cracked; however, this fact was not L

understood by the control room supervisor and the reactor

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operators.

Preparation:

The reactor operators performed a minimal review of the procedure; consequently, they were unaware

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that significant changes to the procedure had occurred.

Additionally, this is an infrequently performed evolution.

Operators were under pressure to perform this evolution quickly, due to problems with keeping the waterbox full

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of water.

(2) Engineered Safety Feature Actuation due to De-energizing the Division 11 Nuclear Systeni Protection System Bus

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safety feature (ESF) actuation had occurred.

The event was-

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caused when a non-licensed operator was re-energizing the

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nuclear system' protection system (NSPS) inverter for.the

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i division II NSPS bus.

Both the non-licensed operator and the'

l licensed reactor operator who-directed him'to perform the i

evolution were unsure whether the NSPS bus was de-energized or

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being powered from the alternate AC supply.

The non _ licensed l

operator at the local panel incorrectly determined that the

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NSPS bus was not powered and proceeded to re-energize the inverter using a part of the procedure that first called for g

L opening all the bus load breakers, i

When the breakers were opened, several actuations occurred including e. containment isolation of several groups, reactor

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trip signal, reactor water cleanup system isolation and trip-reactor core isolation cooling (RCIC) system actuatinn signal, and low pressure coolant injection (LPCI) system actuation signal for the "B" and "C" LPCI pumps.

No water was actually

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c-injected into the vessel because the RCIC system was interlocked from starting due to low reactor pressure and the LPCI pumps were tagged out.

No actual rod motion occurred because.the reactor was shutdown and a scram signal was already'

present.

All equipment appeared to function as expected.

The:four'NSPS. buses were m rmally energized by AC power from inverters fed from the safety-related batteries.

The buses-could'also be powered from alternate AC sources.by changing-

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the state of a static transfer switch ~or by rotating a manual-transfer-switch.

The static switch changed states l-automatically if the inverter output was lost and could also be

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changed by the use of pushbuttons on the local panel.

A mimic i

of the system with various lights and indications was on the local panel.

The inspectors attended the event critique in which'several errors were discussed.

The NSPS bus had been placed on the alternate AC supply and the inverter secured during the

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previous shift.

The information.about the status of the bus

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had not been clearly communicated to the reactor operator on the next shift, although other individuals on the shift were aware of the status.

The bus had been transferred to the.

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alternate supply by using the static switch pushbutton instead of the more usual ma.iual bypass switch.

Although the procedure

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contained instructions for transferring power using either method, the use of the manual switch was specified in the part i

of the procedure for securing the inverter.

The use of the

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pushbutton instead of the manual switch made it harder for the non-licensed operator to determine the status of the bus by looking at the panel.

An indicating light which would indicate that the alternate AC source is being fed through the static switch was powered from the DC input so that it was not lit

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when the inverter was secured.

This led the non-licensed operator to believe that the bus was not powered from the alternate source.

The local panel contained output voltage,

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frequency, and current meters which were showing normal AC

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power to the NSPS bus, but the non-licensed operator stated

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that he believed that the meters would have failed "as-is" when the bus was de energized.

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The licensee submitted Licensee Event Report (LER)90-007 to report their evaluation of the root cause and corrective actions for this event.

The inspectors will review the licensee's

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corrective action <, when the LER is closed.

The LER did not discuss a corrective action to evaluate the design of the

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indict. ting lights on the inverter's mimic panel although, in this case, that design contributed to the cause of the

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event.

During the exit meeting for this report, the inspectors L

recommer.ded that the licensee perform a design review, b

E (3) Turbine Runback On April 26, 1990, while increasing power from about 50% to 70%, a turbine runback occurred.

Generator load decreased from

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480 to 425 MWe and two turbine bypass valves opened.

The

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runback was apparently caused by a failure of the generator

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stator cooling water flow comparator instrument.

During the time that turbine bypass valves were opened, the operators entered a Limiting Condition for Operation in accordance with

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Technical Specification 3.1.4.1 and stationea a second licensed operator to prevent the withdrawal of control rods.

Control

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rods were inserted to cause the bypass valves to close about 40 minutes after the runback.

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The licensee installed a temporary modification to disable the runback feature.

Additional inspectors' observations concerning the temporary modification are discussed in paragraph 6.b. of

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this report.

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As part of the corrective action for the rod withdrawal event

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reported by the licensee in LER 90-008, the licensee changed

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the Sentinel Log of the General Electric Transit Analysis

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Recording System (GETARS) so that the opening of the first

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turbine bypass valve to five percent would cause a trip of the r

GETARS Sentinel trip annunciator ni the main control room.

During the inspectors' review of the runback event, the reactor

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operator who had been in the main control room told the

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inspectors that the annunciator had not activated.

Later, the Shift Technical Advisor who had been on duty told the o

inspectors that he had turned off the GETARS shortly before the I

runback in order to prevent a spurious activation of the system during an anticipated feedwater pump evolution.

During the

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exit meeting for this inspection, the inspectors informed the licensee of the findirg and suggested that their policy for control of the GETARS be reviewed.

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(4)E Shutdown Required by Technical Specifications Due'to Unanalyzed-a Condition in Diesel Generator Service Water Piping r.

f On May 8, 1990, the licensee informed the NRC'via the Emergency Notification' System (ENS)'of a Notification of Unusual Event

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'(NOVE).

They had declared both the division I_and II emergency

. diesel generators inoperable and were commencing a plent w

jg shutdown in accordance with Technical Specification 3.8.1.1.

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The diesels had been declared inoperable whenlthe-licensee-i discovered that tie rods were not installed on the thermal

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expansion bellows on the inlet and outlet service water piping for the diesel generator's heat exchangers. -The tie rods were designed to limit the amount of expansion of the bellows to-i prevent damage to the associated piping and. supports.

While investigating the missing tie rods, damage was noted to one of the rigid supports on the division I diesel service water piping and displacement was noted on division II piping.

Because of the possibility that the piping may have been overstressed, the licensee determined that this was an unanalyzed condition and declared the diesels inoperable while they investigated.

A controlled shutdown was started on the evening of May 8 and the reactor was scrammed from about 25% power on the morning of May 9 at which time the'NOUE was terminated.

The licensee made a second ENS notification on May 9:concerning potential' media interest in the_ event.

The plant reached Cold Shutdown on

=Nay 10, 1990.

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This issue was being reviewed in Inspection Report No. 461/90012(DRP).

d.

New Fuel Receipt (60705)

During this inspection period the licensee began receiving and e

inspecting new fuel'for use in the next refueling.

The inspectors

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made selected observation of the new fuel receipt activities. 'In general, the evolutions were performed carefully and correctly with-adequate supervision.

The inspectors observed one incident in which a worker on the top of the. unloading stand hit his head on the crane hook af ter the hook

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was lowered, apparently without his knowledge.

This incident was discussed with plant management including the Director - Industrial Safety.

Early one morning, the inspectors noted that one of the radiation protection instruments in use on the fuel floor had not been response checked that day. When it was pointed out to the radiation protection technici6n at the site, he indicated that he was confused about the date and thought it was actually the date indicated on the c'

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He immediately took the instrument to be

. source checked and checked all his other instruments.

Since-it was r

relatively early in the day, and the instrument had been source checked about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> earlier, the inspectors did not consider-the finding as a. violation of the instrument surveillance procedure.

The stickers used by radiation protection on instruments to record daily source checks all start with the first day of the month in the

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upper lef t hand corner.

This can create confusion because the.

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stickers look like calendar pages but do not match the format of a calendar except when the first day of the month happens to fall on a

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Sunday.

The inspectors discussed the observation with-the Director.

- Radiation Protection.

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No violations or deviations were identified.

4, Maintenance / Surveillance (61726 & 62703)

e Station maintenance and surveillance activities of the safety-related systems and components listed below were observed or reviewed to ascertain that they.were conducted in accordance with approved procedures, regulatory guides, and industry codes or standards, and in conformance with Technical Specifications.

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The following items were considered during this review:

the limiting conditions for operation were met while affected components or systems were removed from and restored to-service; approvals were obtained prior

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to initiating work or testing; quality control records were maintained; Lparts and materials used were properly certified; radiological and fire prevention controls were accomplished in accordance with approved procedures; maintenance and testing were accomplished by qualified personnel; test instrumentation was within its calibration interval; functional. testing and/or calibrations were performed prior to returning components or systems to service; test results conformed with Technical Specifications and procedural requirements and were. reviewed by personnel other than the individual directing the test; any deficiencies identified during the testing were properly. documented, reviewed, and resolved by appropriate management personnel;-work requests were reviewed to determine the status of outstanding jobs and to assure that princity was assigned to safety-related equipment maintenance which may affect system performance.

The following maintenance and surveillance activities were

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. observed:

Activity Title CPS Ho. 2800.10 Service Water System Flow Balancing CPS No. 9000.09 Contro'l Rod Manipulation CPS No. 9031.14 IRM Channel Functional Test CPS No. 9080.06 Division I Diesel Generator Monthly Test CPS No. 9080.14 Division III Diesel Generator Monthly Test CPS No. 9431-'61 APRM Setpoint Verification

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i MWR D14754 Division 11 VX Chiller Inspection

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MWR D15459 Install Tie Rods on Division I Diesel Bellows

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Several other maintenance and surveillance activities were observed

'during the spec.ial team inspection reported by Inspection Report No. 461/90005(DRS).

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a.

On March 22, 1990, the licensee identified that a particulate filter was not installed in heating, ventilating and air conditioning

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(HVAC) stack discharge process radiation monitor 0RIX-PR002.

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missing particulate filter rendered the iodine and particulate

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channels of the monitor inoperable.

The monitor had been required by Technical Specification 3.3.7.12 to be operable from 9:15 a.m. on March 21, when the. monitor was incorrectly declared operable after maintenance, until 10:45 p.m._on March 22, when the filter was

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installed.

The licensee reported the event to the NRC as.LER 90-006.

The event

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was not considerd ?afety significant because the plant was shutdown j

during the time u.at the monitor was inoperable and other monitors

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capable of monitoring releases under design basis conditions were

operable.

The cause of the event was attributed to personnel error.

A modification to install a mass flow meter in the monitor had just-been completed.

The maintenance planner who specified the post i

maintenance test to'be performed after the modification specified that certain steps in the monitor's calibration procedure-be-performed.- The steps specified included a step which removed the particulate filter but did not include the step to reinstall the filter.

The licensee's corrective actions included a planned revision to Administrative Procedure CPS 1502.01, " Conduct of

Maintenance," to provide guidance for specifying the use of partial-i procedures for maintenance activities.

Training for maintenance planners on the use of partial procedures was also to be held.

In addition, monitor calibration procedures were to be reviewed and revised as necessary to insure that verification of. filter j

reinstallation steps are in the appropriate places in the procedure.

The LER indicated that LER 87-040 discussed a similar event in which-the particulate filter was missing from the HVAC common stack high range gaseous effluent monitor.

That event was discussed in Inspection Report No. 461/87031, paragraph 10.c.(2), and was considered a licensee-identified, non-cited violation (461/87031-08).

Although not mentioned in LER 90-006, the event was also similar to an event reported in LER 87-068 in which the particulate filcer was-discovered missing from the standby gas treatment exhaust high range radiation monitor.

This event was discussed in Inspection Report No. 461/87039,. paragraph 9.b (2) and was one part of Violation 461/87039-01.

The inspectors reviewed these two previous events to determine if corrective actions for those violations should have prevented the l

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event on March 22, 1990. - Co'rrective actions for the previous events--

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~ t calibration procedures to verify that the particulate filters were

installed.

In the March 22 event, the procedural steps.were

available but were not specified to be performed by the maintenance planner.

For this reason, the inspectors determined that the March-22 event was not one that should have been prevented by

corrective actions on previous violations and the event was considered a " licensee-identified" violation (NCV 461/90006-01).

The violation was not cited because the criteria specified in Section V.G.1-of the Enforcement Policy were satisfied.

This issue-is considered closed.

The inspectors intend.to review completion.

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of the long term corrective actions when the LER is closed.

b.

On April 18 1990, during a post maintenance test run of the division III diesel generator, the test was aborted when it was

noted that one of ',he' air start motors.did not disengage.

An..

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investigation determined that the air start motor had been installed-incorrectly in that it.was canted slightly in its mounting..This caused excessive binding between the air sta'rt motor bendix gear and the bull gear on'the diesel.

This was the first failure of this:

type experienced at Clinton..

The cause appeared;to be an isolated

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maintenance' error.

The licensee considered the diesel t?st to be'

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an invalid test performed for troubleshooting in accordance with

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Regulatory Guide 1.108, Revision 1, and thus did not consider the event-to be. reportable as a diesel failure in:accordance.with

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Technical; Specification 4.8.1.1.3.

Air start motor-installation procedures were being reviewed to determine if.the installation instruction could be improved to prevent recurrence..

c.

On April 27, 1990, the licensee identified:that the particulate filter paper in drywell. fission product monitor 1E31-P002 wcs not advancing on its take-up reel.

The licensee's_ investigation determined that the paper had probably not been advancing since-at least April 4, 1990.

This period included about.12 days in which r

L the plant was in Operational Conditions 1 or 2 and the monitor was required to'be operable, q

The licensee was investigating the finding and intended to submit

theirfanalysis in LER 90-009.

The inspectors intend to review the u

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event in more detail when the.LER is issued and determine if a Notice of Violation is appropriate.

No deficiencies were identified, however, one non-cited violation was identified.

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Engineering and Technical Support L

Several engineering issues.were reviewed by the inspectors during this

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inspection period, but all were being followed up by regional inspectors

and were documented in other reports.

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a.

The inspectors spent considerable time following the licensee's

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actions to resolve.the' issues of shutdown service water-flow.

Inspection Report 461/90005 (DRS) reported the inspectors'

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findings concerning this issue, b.

As discussed in Inspection Report 461/90001, paragraph 7.b.(2), the

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licensee: discovered that certain Automatic Switch Company (ASCO).

solenoid valves in safety-related applications could fail due to

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failure of nonsafety-related air regulators providing air to them.

The licensee reported the results of their investigation and

corrective actions for thi: finding as LER 90-004.

Inspection-

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Report 461/90007(DRS) documented the NRC review of this issue.

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During the inspectors'Lfollowup of the issue, they reviewed Quality

Assurance Surveillance Report Q-13833.

The surveillance was performed to verify the adequacy of the proposed corrective actions for Condition Report 1-90-03-056 which tracked the ASCO issue.. The.

inspectors noted that the surveillance indicated that the ASCO solenoid valves-internal to the hydrogen / oxygen monitors were'

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considered not to have a post accident function.

The' inspectors i

informed the QA supervisor that the monitors were required to be

operable for post accident mitigation and the surveillance was revised to require Nuclear Station Engineering to address those

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valves in their corrective action.

No violations or deviations were identified.

6.

Safety Assessment / Quality Verification a.

Regional Request (92700)

j On April 1'8, 1990, the~ inspectors provided the~1icensee with information from another utility concerning problems with speed-

'v control of Model-8271-2301 Woodward governors used on emergency diesel generators.

Regional management requested that the inspectors determine _whether Clinton had the same model governors and whether they had experienced any-problems.with speed control.

The licensee provided the requested information to the-inspectors on

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April. 20, 1990.

The governors on Clinton's emergency diesel

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generators are Woodward Model 8271-2301A.

They had.Model' 8271-2301

, governors installed originally but problems were encountered with speed oscillations during startup testing due to circuit noise.in the power supply.

The governors were subsequently replaced with the

"A" model.

The "A" model had updated electronic circuits, a

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different power supply which did not use dropping resistors, and other improvements.

Since that time no problems of the same nature as those described in the regional request have been experienced.

The licensee's response to the NRC's safety concern was very prompt and demonstrated due regard to followup of industry events. The system engineer for the diesel generators was especially cognizant of the issue and thoroughly researched the event.

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b.

Inadequate Safety Evaluation of Temporary Modification (37828)

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On April-26, 1990, while following up the licensee's-actions in response to a. turbine runback discussed in paragraph 3.c.(3), the inspectors identified a concern with the safety evaluation for a.

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' temporary modification. Temporary Modification 90-21 had been l:

approved and installed on April 26 to prevent an inadvertent runback l

of the turbine generator due to a faulty generator stator cooling low-low flow transmitter.

The Safety Evaluation Screening Form SE-1

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for the temporary modification justified not performing a written

~ full safety. evaluation in accordance with 10 CFR 50.59 because the J'

generator' runback circuit affected by the temporary modification was not described in the Clinton Updated Safety Analysis Report (USAR)

and generator functional characteristics and'its protection were not

affected.

L The inspectors reviewed Section 10.2.2.5, " Turbine Protection f

System," of the USAR and noted that although the runback feature was

I not described, a turbine trip was described on " prolonged loss of.

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generator stator cooling at loads in excess of a preset value."

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This. feature was intended'to protect the generator if a runback a

failed to clear a problem in stator cooling within a preset time.

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The' runback and potential trip would occur on either low stator cooling water pressure, high stator cooling water temperature, or low stator cooling water flow for a given load.

Thus by disabling the low flow comparator runback, the licensee effectively changed the turbine trip described in the USAR.

The-inspecto's discussed their concern with the Staff Assistant Shift Superv!sor who issued Condition Report 1-90-04-082 and j

. returned the safety evaluation screening to Engineering for further_

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review.

Engineering personnel told the-inspectors that they had-realized that the temporary modification would remove one of-the inputs to the turbine runback / trip system, but that_the other two diverse-inputs insured that the trip feature described in the USAR'

was still operable and thus a written safety evaluations was not

necessary.

The inspectors reviewed the USAR and references used in developing the design basis of the-trip system in the USAR and could find no-

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specific description of the logic.

Thus, technically a written

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safety evaluation was not required but the inspectors pointed out that-since the screening sheet did not even mention that generator stator cooling low flow could <:ause a turbine trip, it may have misled the licensed Senior Reactor Operator who approved the

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installation of the temporary modification.

The licensee agreed to perform a written safety evaluation for the temporary modification and the Manager Clinton Power Station established a policy to perform written safety evaluation of all temporary modifications until the procedure for screening changes was reevaluated.

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No violations or deviations were identified.

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Management Changes On April 2,1990,: Mr. R. Freeman, Manager - Nuclear Station Engineering.

. Department left the Illinois Power Company.

He was replaced by Mr. Jc Miller, formerly Manager - Scheduling and Outage Management.

Mr.- Miller was replaced by R. Morgenstern, formerly Director - Plant Technical Staff.

Mr. Morgenstern was replaced by K. Moore, formerly

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a supervisor in the Technical Staff.

8.

Items For Which A " Notice Of Violation" Will Not Be Issued A

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 initiative in the.

-self-identification and correction of problems, the NRC will not generally

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issue a Notice of' Violation for an issue that meets the tests of 10 CFR 2, Appendix C, Section V.G.I.

These tests are: 1) the issue was identified i

by the licensee; 2) the issue would be categorized as Severity Level IV

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or V violation; 3) the issue was reported to the NRC, if required; 4) the issue will be corrected, including measures to prevent recurrence, within a reasonable time period; and 5) it was not a issue that could reasonably be expected to have been prevented by the licensee's corrective action for a previon violation.

In addition, in accordance with Section V. A. of the enforcement policy, for isolated Severity Level V violations, a Notice of-

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Violation normally will not be issued regardless of who identifies the

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-violation provided that_the licensee has initiated appropriate corrective

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action before the inspection ends.

An issue involving the failure to meet regulatory requirements, identified during the inspection, for.which a Notice of Violation was not issued is discussed in paragraph-4.a.

9.

Meetings a.

Management Meetings (30702).

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On April-12, 1990, Messrs. A. Bert Davis, Regional Administrator,.

l R. C. Knop, Chief, Reactor Projects Branch'3, F. L. Brush, and the j'

NRC resident inspectors met with Messrs. W. J. Kelley, Chairman and

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CEO, J. S. Perry, Vice President, and licensee managers and supervisors l-denoted in paragraph 1 of this report.

This meeting was held for.

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the licensee to provide information on the shutdown service water l

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flow findings, air operated valve questions and other technical topics of. interest.

The licensee also provided information of the i

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L the status of.their initiatives' for 1990.

The Regional Administrator L

acknowledged the information and expressed his concern about the l

performance of licensed operators during the recent improper rod

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withdrawal event and with the response to date of the licensee.

b.

Exit Interview (30703)

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'The inspectors met with the licensee representatives denoted in

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paragraph'1 at the conclusion of the inspection on May 11, 1990.

The inspectors summarized the purpose and scope of the inspection

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informational-content of the inspection report; with regard t)_

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documents or processes reviewed by the inspectors during the H,

inspection.- The licensee did not identify any such documents 1r q

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processes-as proprietary, t

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