IR 05000461/1997005

Insp Rept 50-461/97-05 on 970211-0514.No Violations Noted. Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support

ML20141D723
Person / Time
Site:	Clinton
Issue date:	06/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141D713	List: IR 05000461/1997005 ML20141D708
References
50-461-97-05, 50-461-97-5, NUDOCS 9706270317
Download: ML20141D723 (10)

Text

- . - -- - .- . - . _ = - . - - . - - . . . .- - - - . - - . .

.

.

-

U.S. NUCLEAR REGULATORY COMMISSION

<

REGION lli

Docket No.: 50-461 License No.: NPF-62 i

Report No.: 50-461/97005 i

Licensee: lilinois Power Company i

Facility: Clinton Power Station j Location: Route 54 West I Clinton,IL 61727 Dates: February 11 - February 19,1997 4 April 1 - April 4,1997 May 14,1997 l

Inspector: R. A. Langstaff, Resident inspector

,

l Approved by: Geoffrey C. Wright, Chief

Clinton Special Projects Branch Division of Reactor Projects

.

i

.

i

}

"~

9706270317 970616 PDR ADOCK 05000461 G PDR

. . . .- - _- .- - -- . .- - _ . _ _ - - . _ . .. ..

.

.

-

\

l i

EXECUTIVE SUMMARY Clinton Power Station NRC inspection Report 50-461/97005 This inspection included aspects of licensee operations, engineering, maintenance, and l plant suppor e Plant personnel were able to identify problems using the CR process. However, because of past experience, some individuals were concerned about the long term effectivaness of the CR proces * The Corrective Action Review Board reviews of CR assignment and closure were

. appropriate and conservativ o The existing backlog for CRs did not pose an immediate problem. However, a potential problem existed in that the backlog was growing and timeliness of resolutions could be adversely affecte I e The licensee's audit team members were able to identify issues and ensure that the l issues were appropriately reflected in audit reports. However, a number of individuals expressed limited confidence in how identified issues were addressed by line organization e Audit reports appropriately addressed issues which had been identified. Room for improvement existed in assessment of identified issue !

e Although one audit became contentious, organizational freedom and independence for the audit personnel and organization was maintained. No violations of NRC requirements was identifie >

, - - - - . - - .--- .-.--._- .-_-.-. . - - - , --

.

.

f

i l

'

.

1. Ooerations 01 Conduct of Operations -

01.1 General Comments (40500)

Using Inspection Procedure (IP) 40500, the inspector reviewed how issues were identified and addressed. This inspection was limited in scope and did not i accomplish the full intent of IP 40500. The inspector's reviews included the I maintenance, engineering, and plant support functional areas, in addition to operations. However, for convenience, all functional areas are documented under operations. Personnel were able to raise issues using the condition report (CR)

process, or, in the case of quality assurance personnel, using the audit finding process. However, because of past experience, some individuals were concerned about a iong term effectiveness of the CR process. Quality assurance personnel had sufficient organizational independence to identify issue .2 Plant Personnel Confidence in Condition Reoort Process Mixed Scope:

The inspector interviewed six individuals from maintenance, three individuals from operations, and three individuals from radiation protection with regards to how i issues were identified and addresse l 1 Observations and Findinos:

The licensee used the CR process as the primary means for identifying and addressing issue !

All of the maintenance personnelinterviewed by the inspector stated that if a )

problem was encountered in the field, they would write a CR Most considered the CR process to be effective in resolving problems. However, one individual noted that while CRs were effective in resolving immediate problems, the CRs were not always effective in addressing bigger issues. In addition, the individual voiced a l concern that individuals responsible for resolving the issues were not always sufficiently familiar with the issues. During the interviews, the maintenance personnel demonstrated a good understanding of the CR process and all had received copies of the resolutions for CRs they had writte All of the operations personnelinterviewed by the inspector stated that if a problem was encountered in the field, they would contact the cortrol room. The operators interviewed did not volunteer that they would initiate a CR when a problem was ic'entified. When specifically asked about initiating a CR, all indicated that they v.ould write one, usually in consultation with operations management. One operator noted that he did not routinely write CRs. All three operators interviewed had written CRs before, but two stated that they hadn't always received a copy of

--

- _ - - - -.- ._--- _..- - - -- --. . - - - . -.- -

'

. l

. .

.

. the CR resolutions for the CRs which they had written. In addition, two operators j noted that CR resolutions didn't always fully address the issues identifie Although each of the radiation protection technicians interviewed by the inspector had written CRs before, some were concerned about the CR process long term effectiveness due to previous experiences. (Significant problems in the radiation protection area had previously been identified by NRC and are discussed in l Inspection Report 50-461/96012.) The technicians noted that CRs were not i routinely used to document minor problems in the radiation protection area. Each I technician had received copies of the CR resolutions for CRs they had initiate l l Conclusions:

Plant personnel were able to identify problems using the CR process. However, ;

j some individuals remained skeptical of resolutions being consistently appropriate due to past experiences.

'

01.3 Corrective Action Review Board Reviews Conservative: Scooe:

! The inspector reviewed the actions of the Corrective Action Review Board (CARB)

by attending two CARB meeting Observations and Findinas:

The inspector determined that CARB reviewed initial CR submittals and documentation necessary for closure on all but the least significant CRs. The discussions during the CARB meetings were probing and maintained an appropriate safety focus. The inspector noted that in several cases, the CARB specified l additional actions to be taken or additional documentation be provided to ensure !

that identified issues were appropriately addressed. The inspector concluded that the CARB reviews adequately ensured that CRs were appropriately classified and dispositioned, Conclusions:  :

The CARB reviews were appropriate and conservativ !

01.4 Condition Reoort Backloa Growina Scooe: I The inspector reviewed trending reports provided by the licensee concerning the initiation and closure of CRs.

!

l 4

.

.

.

.- Observations and Findingg:

The inspector noted that the number of CRs initiated had significantly increased during the later part of 1996. During early 1996, typically less than 100 CRs were initiated monthly. However, during the later part of 1996 and early 1997, typically

over 200 CRs were initiated monthly. Although part of the increase could be attributed to an outage, much of the increase appearea to be due to the licensee's intentional lowering of their threshold for initiation of CRs. The inspector considered the increased documentation of problems, as shown by the increase in CRs, to be good. However, the closure rate for CRs had not kept up with the increased number of CRs being initiated. Consequently, the backlog of CRs requiring resolution was growing. The inspector concluded that the backlog was reasonable because most of the open CRs were less than four months ol However, if the growing backlog is not addressed, overall timeliness of corrective actions would be adversely affected. Licensee management was aware of the growing backlog for CR Conclusions:

The existing backlog for CRs did not pose an immediate problem. However, a potential problem existed in that the backlog was growing and timeliness of resolutions could be adversely affecte Quality Assurance in Operations (40500)

07.1 Nuclear Assessment Auditors Able to Raise issues Scooe:

'

The inspector reviewed the ability of individual auditors to raise issues'during the course of audits. The inspector interviewed 20 people who had participated in audits during 1996. In addition to people from the Nuclear Assessment organization, four engineering personnel were interviewed aM one operations person was interviewe Observations and Findinas:

All of the individuais interviewed by the inspector stated tFat the individual issues which they had identified had been appropriately addressed in audit reports. Onl editorial changes were made by audit team leaders and the audit superviso !

Management involvement during the review process was limited to the audit i supervisor. The individuals interviewed stated that they had the opportunity to - )

review the portions of the audit report which they had contributed to before the j report was issued. Two individuals had noted that professional disagreements had j occurred between themselves and the audit team leader during the course of the l audit; however, in both cases, the disagreement was resolved in a professional {

manner with mutual agreemr;nt of how the issues identified were to be addresse a 5 l

. . _ _ . _ _ _ _ _ _ _ _ _ _ _

>

,

.

.

, A number of individuals expressed that while they could identify issues during an

'

audit, their confidence that organizations being audited would take appropriate

^

corrective actions was limited. A few individuals perceived some recent improvement in how line organizations addressed issues identified during audits.

.

Conclusions

. Audit team members were able to identify issues and ensure that the issues were appropriately reflected in audit reports. However, individuals expressed limited confidence in how identified issues were addressed by line organization .2 Audit Reports Acorooriatelv Addressed Identified issues Scope:

The inspector reviewed the following audit reports and associated documentation from 1994 and 1996:

Q38-94-13, Document Control 038-96-03, Maintenance Q38-96-06, Technical Specifications Q38-96-07, Operations Q38-96-09, Nuclear Training Department Q38-96-10, Document Control / Records Management 038-96-14, Corrective Action Q38-96-16, Refueling Outage Audit Q38 96-17, Maintenance Rule implementation Observations and Findinas:

The inspector did not identify any discrepancies between the audit checklists, as documented by individual auditors, and the final audit report The inspector noted that the audit reports, in general, provided minimal assessment of problems beyond identifying that conditions existed which did not meet procedural or regulatory requirements. For example, Audit Q38 96-10 identified numerous document control problems. However, the audit report did not address whether usage problems had occurred due to the problems identified, or the significance of potential usage problem During interviews, individuals had noted that problems has occurred during the performance of audit Q38 96-10. Because of the issues raised, the inspector performed a more detailed review of the audit and made the following observations:

o Based on review of the audit reports and documentation, the inspector determined that audit Q38-9610 was performed with significantly greater depth and scope than the previous audit, Audit Q38-94-13, of the document control and records management areas. Several additional programs and

l

.

_ _ _ _ . . _ _ _ _ _ _ . _ . . _ . _ . _ - _ _ _ _ . . . _ _ _ _ _ . . .. _

'

<

.

J

,

'

,

areas were reviewed during the 1996 audit which had not been reviewed previously with any significant depth. Consequently, the61996 audit resulted in 4 findings,11 CRs, and 2 recommendations in comparison to 1 CR resulting from the 1994 audit. The five individuals from audited organizations interviewed by the inspector agreed that this audit was

performed with considerable more depth and aggressiveness than prior audits. The inspector considered the increased depth to be appropriate.

! -e Based on review of the audit documentation and interviews with members of

{ the audited organizations, the inspector concluded that all of the findings

and CRs identified valid problems. The inspector did not assess the

,

. recommendations.

Conclusions:

.

j Audit reports appropriately addressed identified issues. Room for improvement  ;

! existed in assessment of identified issue '

i

07.3 Oraanizational Indeoendence Maintained for Document Control / Records l MS Siement Audit i

, E' ata:

)

Becsuse of problems which had occurred during the performance of audit 038-96-10, " Document Control / Records Management," Nuclear Assessment

.

(quality assurance) management had initiated a sdf-assessment of the audit. The <

. inspector reviewed the circumstances associated with the self-assessment, in 4 addition to reviewing the audit documentation cod the self-assessment report, the inspector interviewed all five auditors from the audit, five members of the audited i organizations, and three members of Nuclear Assessment management at the tim The findings identified are based on interviews unless otherwise noted. The inspector specifically evaluated the circumstances against the following regulatory j requirements listed belo ]

10 CFR 50.7, " Employee Protection" 10 CFR 50, Appendix B, Criterion I, " Organization" 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" 10 CFR 50, Appendix B, Criterion XVill, " Audits" l

J

l 7 I

!

I a

__ - __ ____ _____ - - __ _ _ _

.

.

. Observations and Findinas:

An audit of document control and records management, audit 038-96-10, was performed in June,1996. The performance of this audit became contentiou During the course of the cudit, management individuals from the audited organizations contacted Nuclear Assessment department management with concerns pertaining to the audit. The concerns included: 1) initiation of condition reports for minor issues,2) greater depth to the audit, and 3) review of the electronic data management system (EDMS) being developed. The inspector considered the first two concerns reflective of changes in philosophy concerning documenting issues for trending purposes and greater rigor associated this audi The inspector considered both changes to be positive. The inspector concluded that the third concern wes vahd because the EDMS system being audited was still under development at s ?m time and was not ready for the type of review being

)

conducted by one of the auditors. However, the results of the auditor's review were appropriately characterized in the final audit repor During the audit, an individual in a Nuclear Assessment management position had discussions with the lead auditor. The inspector determined that at least one of the discussions centered on the lead auditor's performance during the audit. Following the audit, management determined that because of the issues raised during the audit a self-assessment should be performed to identify lessons learned. Some individuals interviewed perceived that the management discussions with the lead auditor and the initiation of the eelf-assessment were not independent action Specifically, the perception existed that these actions were taken to respond to concerns voiced by the audited organizations. This perception was fostered by the following:

• The fact that the audited organization had communicated concems to Nuclear Assessment management regarding the conduct of the audit on a number of occasion * Audit 038 96-10 was the only audit which had been the subject of a specific self-assessment since 1993. Interviews with Nuclear Assessment management indicated that management had not fully communicate the reasons for performing the self-assessment on this specific audit to individuals within the Nuclear Assessment departmen * Nuclear Assessment management judged the success of an audit,in part, upon acceptance of audit findings and issues by the audited organizatio Although some perception existed that independence had been impeded, the inspector concluded that organizational freedom and independence required by 10 CFR Part 50, Appendix B, Criterion I, " Organization," had been maintained as evidenced by the following:

_

. _ _ _ _ _ _ _ . . _ _ . . _ _ ._ _. __ . . _ _ _ . . _ . _ . _ _ _ _

.-

j

.,

i l' o e All the audit team members, when specifically questioned by the inspector,

stated that the issues they identified were appropriately' addresse Furthermore, c!l stated that only editorial changes had been made to their i portiorv nf the audit report. In addition, when other people who had iJ partici in audits were interviewed, none indicated that there was a i proble getting identified issues addresse '

~

e The issues which became contentious were aodressed in the audit report with condition reports and audit findings initiated as appropriate.

,

e Although the extent of manag'ement involvement for this particular audit was unusual, the inspector considered management involvement necessary in light of the contentiousness which arose during the audit. Likewise, the j' inspector considered a self assessment to be appropriate given the contentiousness which arose.

i .. e _ The self-assessment supported the validity of the audit by stating "the audit

,

- appeared technically adequate and was effective in identifying problems with

!

' the Document Control and Records Management programs."

i

, Conclusions: _

?

Although one audit became contentious, organizational freedom and independence for the audit personnel and organization was maintaine ,

i a

i j V. Manaaement Meetjnga X1 Exit Meeting Summary l The inspector presented preliminary inspection results to members of licensee

management on February 19,1997. The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on l

May 14,1997. The licensee acknowledged the findings presented and did not -

identify any of the materials examined as being proprietar l

_ _ _ _ _ _ _ _ _

j

- -. . - . ._ . . . . _ _ _ - . - . . . _ . - -...~. .. .. . - . _ . _ - _ . . . .

'

y

,

-

PARTIAL LIST OF PEr.SOf15 CONTACTED l Licensee

't P. Yocum Manager, Clinton Power Station

, G. Baker Director, Nuclear Assessment Department *

l M. Lyon Asst. Manager, Plant Operations D. Morris Director, Radiation Protection and Chemistry

A. Mueller Asst. Manager, Plant Maintenance i J. Palchak Manager, Nuclear Training and Support

R. Phares Assistant to the Vice President, Executive Staff" l J. Sniezek Director, Nuclear Review and Audit Group M. Stickney Supervisor, Regulatory interface *

D. Thompson Manager, Nuclear Station Engineering Department

Attended exit meeting held May 14,199 I INSPECTION PROCEDURES USED '

,

IP 40500, Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems ITEMS OPENED, CLOSED, AND DISCUSSED None LIST OF ACRONYMS USED CR Condition Report CARB Corrective Action Review Board EDMS Electronic Data Management System IP inspection Precedure '

10