IR 05000461/1998020
| ML20206S106 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 01/22/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206S099 | List: |
| References | |
| 50-461-98-20, NUDOCS 9901280121 | |
| Download: ML20206S106 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli License No:
NPF-62 Docket No:
50-461 Report No:
50-461/98020(DRP)
Licensee:
lilinois Power Company Facility:
Clinton Power Station Location:
Route 54 West
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Clinton, IL 61727 Dates:
November 18,1998 - January 6,1999 Inspectors:
T. W. Pruett, Senior Resident inspector K. K. Stoedter, Resident inspector C. E. Brown, Resident inspector D. E. Zemel, Illinois Department of Nuclear Safety
' Approved by:
- Thomas J. Kozak, Chief Reactor Projects Branch 4
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9901280121 990122 PDR ADOCK 05000461 1-.
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EXECUTIVE SUMMARY Clinton Power Station NRC Irspection Report 50-461/98020(DRP)
This inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 7-week period of resident inspection.
Operations The inspectors concluded that an effective program to identify, track, and resolve main
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control room (MCR) deficiencies and operator workarounds (OWAs) was not sufficiently implemented to warrant closure of NRC Case Specific Checklist Restart item IV.1.
Portions of the program that were not fully implemented included the performance of -
periodic assessments and maintaining accurate MCR deficiency and OWAs lists (Section O.1.1).
The inspectors concluded that interviewed operators were not aware of the overall
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status of deficient control room equipment and OWAs (Section 01.1).
The inspectors concluded that weaknesses in the implementation of the operability
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determination program still existed in that operations personnel had not conducted eight safety evaluations for long standing use-as-is nonconforming conditions. In addition, three maintenance activities associated with operability determinations had not been scheduled for completion prior to restart of the facility (Section 01.2).
The inspectors identified one violation, for which enforcement discretion was exercised,
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concerning the failure of control room operators to enter nonconforming conditions into the licensee's corrective action program. Specifically, operations personnel documented four nonconforming conditions in the MCR journal but did not initiate a condition report.
The issues involved an unanticipated loss of fill and vent on the residual heat removal system, a human performance error during maintenance on a station air compressor, a maintenance rule functional failure affecting the Division I switchgear heat removal unit, and three unplanned entries into a limiting condition for operation (Section O3.1).
The inspectors identified one violation, for which enforcement discretion was exercised,
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that involved the failure of operations personnel to annotate a late entry in the MCR journal and the repeated failure to document the completion of shiftly compensatory actions (Section O3.1).
Maintenance Maintenance personnel conducted activities with the procedures present and in active
use. Technicians were knowledgeable of the tasks and closely followed the procedure or maintenance work request (Sections M1.1 and M8.1).
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s Enaineerina Quality assurance personnel conducted a thorough evaluation of the contractor control
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The inspectors identified one violation, for which enforcement discretion was exercised,
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that involved the repeat failure to ensure design requirements for the MCR breathing air system were translated into plant procedures (Section E8.1).
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o Report Details Summarv of Plant Status
' The facility remained shutdown during the inspection period. Major maintenance activities
~ included completion of a Division 11 maintenance outage and continued installation of degraded voltage modifications.
LQperations
Conduct of _ Operations 01.1 Review of Main Control Room Deficiencies and Operator Workarounds a.
Inspection Scope (71707)
The inspectors conducted a review of the program implemented to identify, track, and resolve main control room (MCR) deficiencies and operator workarounds (OWAs) to determine if the licensee effectively implemented corrective actions to resolve concerns regarding this program listed in Confirmatory Action Letter Rlll-97-001, NRC Inspection Report 50-461/98003, and NRC Manual Chapter 0350, Case Specific Checklist (CSC)
Item IV.I, " Establish Program to Reduce and Maintain Control Room Deficiencies."
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Observations and Findinas Corrective Actions Taken To Address MCR Deficiencies and OWAs On October 2,1998, the licensee submitted a closure package for CSC Restart item IV.1 to the NRC. The corrective actions implemented by the licensee included, in part Restart Goals: The licensee developed plant restart goals for MCR deficiencies and OWAs. The licensee planned to reduce MCR deficiencies to 25 non-outage and no outage deficiencies and reduce OWAs to none. As of December 1998, the management review team had authorized four outage related MCR deficiencies and two outage related OWAs to exist without resolution prior to restart of the facility.
Performance Indicators: The licensee developed performance indicators for MCR deficiencies and OWAs. The indicators have been reviewed weekly during the daily plant leadership meeting, monthly during the performance indicator meeting, and quarterly during the senior management review meeting of long term material deficiencies.
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Programmatic Controls: The licensee proceduralized requirements for processing and dispositioning MCR deficiencies and OWAs in
Procedure 1401.09," Control of System and Equipment Status." The licensee revised Procedure 1151.11, " Scope Control," to ensure MCR deficiencies were
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scheduled on an expedited basis and worked within 4 weeks of identification
when parts were available.
Physical Identifier: The licensee revised Procedure 1029.01, " Preparation of i
Maintenance Work Documents," to replace maintenance work requests (MWRs)
with action requests (ARs) to initiate the maintenance planning process for plant
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deficiencies. The AR form includes a deficiency sticker that can be affixed to the
applicable MCR panelin order to provide a positive indication of the discrepancy
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to operations personnel.
The licensee assessed the effectiveness of the corrective actions and determined that i
management commitment to reducing MCR deficiency and OWA backlogs existed because aggressive goals for restart had been established, additional resources had
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been assigned to reduce the backlog, and frequent assessments of performance i
indicators were conducted.
i Inspectors' Review of Actions Taken to Address Main Control Room Deficiencies Licensee perfc,rmance measures indicated that the total number of MCR deficiencies
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were reduced from over'200 in December 1997 to approximately 90 in December 1998.
During a comparison of the items specified on the MCR deficiency list to MWR and AR tags located in the MCR, the inspectors determined that some items described on the MCR deficiency list did not have an identifier in the MCR and that on-shift operations personnel did not have access to the MCR deficiency list. In addition, some MWR and AR tags displayed in the MCR were not on the MCR deficiency list. Further, numerous MWR and AR tags in the MCR remained in place after the deficiencies had been repaired. Lastly, periodic assessments of the MCR deficiency and OWA program were not conducted.
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l In response to the inspectors observations, the director-operations initiated an audit of the MCR deficiency program. The audit confirmed that approximately 60 MWRs and ARs were closed but had tags remaining in the MCR,25 MCR deficiencies did not have
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identifiers in the MCR, and eight MCR deficiencies identified by tags were not included l
in the MCR deficiency list. The licensee initiated Condition Report (CR) 1-98-12-279, placed a copy of the MCR deficiency list in the MCR, removed tags for deficiencies that had been repaired, and updated the MCR deficiency list.
Inspectors' Review of Actions Taken to Address Operator Workarounds j
The inspectors determined that the licensee's definition of an OWA differed from the definition in NRC Inspection Manual Temporary instruction 2515/138, " Evaluation of the l
Cumulative Effect of Operator Workarounds." Specifically, Procedure 1401.09 specified an OWA as an equipment deficiency and its required compensatory actions that impair
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the operator's ability to control the plant during transient conditions. Temporary
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i Instruction 2515/138 specified an OWA as a degraded or nonconforming condition that complicates the normal operation of plant equipment and is compensated for by operator action.
The licensee's August 1998 performance indicator documented 24 OWAs. In November 1998, the licensee reassessed the performance indicator and reduced the OWA backlog from 23 to 11 by closing 1 OWA, combining 2 OWAs, and reclassifying 10 OWAs as operator challenges. Examples of reclassified OWAs included:
Challenge 98-64: Breathing air system has leaks that require refilling bottles multiple
times per week.
Challenge 98-Es. Standby liquid control suction valves repeatedly leak by seats.
- Challenge 98-72: The fold-down platform for reactor recirculation hydraulic control
Unit B has no safety railing and requires operators to don a safety harness which inhibits rapid response to transients.
The inspectors noted that minimal progress had been made between August 1998, and November 1998, in reducing actual plant deficiencies involving OWAs. Instead, the licensee administratively reduced the number of OWAs by developing a new category of
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operator deficiencies called operator challenges. In addition, the inspectors noted that as of December 30, procedural controls for defining, prioritizing, and controlling operator challenges did not exist.
On December 15,1998, the inspectors questioned operations personnel about OWAs and determined that control room operators were not aware of existing OWAs or that an OWA list had been placed in the MCR. Additionally, the inspectors noted that the MCR copy of the weekly OWA list had not been updated since November 12,1998.
With the exception of not performing periodic assessments and defining the requirements for an operator challenge, the inspectors determined that the changes made in the MCR deficiency and OWA programs should have been effective if properly implemented. Because of the extent of the weaknesses identified during the inspectors'
assessment of the MCR deficiency and OWA programs in December 1998, CSC Restart item IV.I will remain open pending an additional review of program implementation prior to restart of the facility.
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Conclusions The inspectors concluded that an effective program to identify, track, and resolve MCR
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deficiencies and OWAs was not sufficiently implemented to warrant closure of CSC Restart item IV.1. Portions of the program that were not fully implemented included the performance of periodic assessments and maintaining accurate MCR deficiency and OWAs lists. The inspectors also concluded that interviewed operators were not aware j
of the overall status of deficient equipment and OWAs.
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O1.2 Review of Safety Evaluations for Ooerability Determinations a.
Inspection Scope (37551 and 71707)
The inspectors conducted a review of operability determinations (ODs) to determine if the licer,see had developed a safety evaluation for each OD as required by Procedure 1014.06, " Operability Determination," and Revision 1 to Generic Letter (GL) 91-18, "Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions."
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Observations and Findinas in July 1998, the inspectors identified that safety evaluations had not been conducted for several ODs and documented the concern in NRC Inspection Report 50-461/98014.
In response to the inspectors' observations, the licensee initiated a review of each OD to determine if a safety evaluation was required and assigned a shift manager to oversee closure of all active ODs. In July 1998, the licensee acknowledged that several safety evaluations were required and stated that, prior to restart, all conditions described in ODs would be corrected or a safety evaluation would be processed. In July 1998, the licensee estimated a restart date of December 1998.
On November 30,1998, the inspectors' determined that at least eight safety evaluations had not been conducted for ODs which described conditions which did not conform with the Updated Safety Analysis Report (USAR) (use-as-is ODs) and that work activities to correct the degraded conditions associated with three additional ODs were not included within the outage scope of maintenance activities. Five of tne eight ODs lacking a safety evaluation and two of the three maintenance activities that had not been scheduled were identified during the inspectors' July 1998 review and had yet to be acted on. Examples of use-as-is conditions for which a safety evaluation had not been completed included: non-seismic MCR displays, incorrect heat transfer compound on power supply modules, improper testing of molded case circuit breakers, an unaccounted loss of 100 gpm of shutdown service water through the post-accident sample system, and instrument inaccuracies involving emergency diesel generator frequency.
The inspectors determined that weaknesses in implementation of the OD program still existed in that operations personnel had not ensured safety evaluations were performed or that maintenance activities were scheduled to be completed prior to restart of the facility. In response to the inspectors' concern, the licensee initiated CR 1-98 12-005 and commenced a review of all active ODs. As of January 1,1999, the licensee had either completed safety evaluations for use-as-is nonconforming conditions or scheduled a maintenance activity to repair the nonconforming condition prior to restart of the facility.
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Conclusions The inspectors concluded that weaknesses in implementation of the OD program still existed in that the licensee had not conducted eight safety evaluations for use-as-is nonconforming conditions. In addition, three maintenance activities associated with ODs had not been scheduled for completion prior to restart of the facility.
O3 Operations Procedures and Documentation 03.1 Review of Main Control Room Journal a.
Inspection Scope f71707)
The inspectors conducted periodic reviews of the MCR journal.
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Observations and Findinas in general, the MCR journal adequately documented shift activities including completion of surveillance testing, entry into Technical Specifications (TS) limiting conditions for operation, and nonconformances occurring during plant operations. However, the inspectors identified that several instances of licensee identified issues were not entered into the corrective action program as required and certain shiftly compensatory actions were not documented in the MCR journal.
Initiation of Condition Reports Between December 18 and 28,1998, the inspectors identified four nonconforming conditions _in the MCR journal which were not appropriately entered into the licensee's,
corrective action program. The issues involved the actuation of the residual heat removal (RHR) train B low discharge pressure alarm during filling and venting of RHR train C, the failure to reinstall an oil instrument line on station air compressor 2SA01C, a low pressure suction trip on switchgear heat removal condensing Unit 1VXO6CB, and three successive losses of an MCR central control terminal (CCT) due to a repetitive failure of process radiation monitor OPR012. The licensee initiated a CR for each of the items following the inspectors' discussion of the issues with an operations department shift manager.
The inspectors determined that the failure to initiate a CR for each of the nonconforming issues involved a misapplication or misunderstanding of the requirements in Procedure 1016.01, " CPS Condition Reports," and Procedure 1029.01, " Preparation of Maintenance Work Documents." Specifically, the actuation of the RHR train B low discharge pressure alarm during filling and venting of RHR train C was outside the anticipated performance of the system and further analysis was needed to determine the cause. The failure to reinstall an oil instrument line on station air compressor 2SA01C and the subsequent oil spray during testing occurred due to human error in that mechanical maintenance personnel failed to reinstall the sensing line which may have involved a procedural non-adherence. The low pressure suction trip on switchgear heat removal condensing Unit 1VX06CB due to an inadequate freon charge following
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maintenance resulted in a maintenance rule functional failure, reflected an equipment problem caused by a human performance error, and may have involved a procedure non-adherence. The three successive losses of the MCR CCT, due to failure of process l
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radiation monitor OPR012, resulted in three unplanned entries into an offsite dose calculation manuallimiting condition for operation. Procedure 1029.01 or Procedure 1016.01 required these items to be entered into the corrective action program or to have ARs generated for each case.
Criterion XVI of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected. Multiple operations personnel had the opportunity to question the discrepancies mentioned above and to ensure the appropriate corrective action program documents were initiated. The inspectors determined that the f ailure to initiate CRs to ensure conditions adverse to quality were appropriately identified and corrected was a violation of Criterion XVI of Appendix B, to 10 CFR Part 50. However, because this violation satisfies the criteria in Section Vll.B.2, " Violations identified During Extended Shutdowns or Work Stoppages," of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, a Notice of Violation is not being issued for this Severity Level IV violation (NCV 50-461/98020-01).
Documentation of Compensatory Actions On December 22,1998, the inspectors identified that operations personnel had not documented the completion of all shiftly compensatory actions on December 18 and 21.
In response to the inspectors' observation, the shift manager initiated a CR and ensured operations personnel were aware of the requirement to document the completion of shiftly compensatory actions. On December 28, the inspectors again identified the failure to document the completion of shiftly compensatory actions on December 27. In response to the inspectors' observation, the shift manager reviewed the MCR journal and noted that on December 28, the affected reactor operator had added a sentence to an MCR journal entry initially made at 6:35 p.m., on December 27, annotating that shiftly compensatory actions were completed. In addition, the shift manager determined that the MCR journal entry was made without following the procedural guidance for annotating a late entry condition. The inspectors verified that all shiftly compensatory actions had been completed on December 18,21, and 27.
Section 8.1.4, of Procedure 1401.05, " Operator Logs and Records," specified that missed entries should be markud with " late entry" at the beginning of the statement with the actual time of the event str ted in the narrative. Section 8.2.3 of Procedure 1406.01.
" Procedures and Operator Air.s," specified that the B reactor operator shall verify that
compensatory actions for annunciators are complete and that an MCR journal entry l
shall be made to this effect.
Technical Specification 5.4.1.a requires, in part, that written procedures be established, l
implemented, and maintained covering the applicable procedures recommended in l
Regulatory Guide (RG) 1.33, " Quality Assurance Program Requirements," Appendix A,
" Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors,"
Revision 2, February 1978. Section 1 of Appendix A to RG 1.33, recommends
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administrative procedures be implemented for log entries. The inspectors determined -
that the failure to correctly annotate a late entry in the MCR journal and the repeated failure to document completion of shiftly compensatory actions was a violation of l
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TS 5.4.1.a. However, because this violation satisfies the criteria in Section Vll.B.2,
" Violations identified During Extended Shutdowns or Work Stoppages," of the " General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement
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Policy), NUREG-1600, a Notice of Violation is not being issued for this Severity Level IV violation (NCV 50-461/98020-02).
l In response to the inspectors' observations, an operations department shift manager j
initiated a level 2 CR to conduct a root cause analysis on the use and review of the
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MCR journal. In addition, night order instructions were issued and crew briefs were conducted emphasizing the importance of making complete and accurate log entries in the MCR journal.
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Conclusions The inspectors concluded that operators did not properly implement procedural I
requirements to enter nonconforming conditions into the licensee's corrective action program and to properly document the completion of compensatory actions in the l
MCR journal.
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Miscellaneous Operations issues (92901)
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i 08.1 LClosed) Violation NCV 50-461/98003-01a: This was a violation for which enforcement discretion was exercised which concerned improper manipulation of control room l
computer screen. This issue involved the inspectors' identification that operations i
personnel had improperly blanked out information provided on an MCR computer
screen. In response to this issue, the licensee counseled the individuals involved and conducted an operations department stand down to inform operations personnel of
operational errors. Simulator training was also enhanced to emphasize the importance
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of control room decorum and proper manipulation of control room equipment. The licensee planned to monitor improvements in control room decorum by implementing an operations department coaching and monitoring program. The inspectors considered the corrective actions adequate to close this issue.
08.2 (Closed) Violation NCV 50-461/98003-01b: This was a violation for which enforcement discretion was exercised which concerned the failure to restore control room breathing l
air system (RA) header pressure. This issue involved the inspectors' identification that operations personnel had not restored RA pressure or implemented compensatory actions following the receipt of low pressure annunciators for the Division I and il RA headers, Corrective actions involved the repair of the normal air compressor used to recharge the RA compressed air bottles, the initiation and completion of several MWRs to improve the material condition of the system, and developing procedural guidance on the use of alternate air compressors to recharge RA compressed air bottles. The inspectors considered the corrective actions adequate to close this issue.
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i 08.3 (Closed) Violation NCV 50-461/98003-02: This was a violation for which enforcement
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discreijon was exercised which concerned the failure to implement corrective actions to prevent another unmonitored increase in MCR deficiencies. This item is being i
administratively closed in that it is a duplicate of NRC Manual Chapter 0350, " Staff
Guidelines for Restart Approval," Case Specific Checklist Restart Item IV.I " Establish
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Program to Reduce and Maintain Control Room Deficiencies."
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i 08.4 (Closed) Violation 50-461/98003-04: This was a violation for which enforcement discretion was exercised which concerned the failure to operate traveling screens during
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cold weather to prevent ice blockage. This issue involved the failure of operations l
personnel to operate the traveling screens when ambient temperature decreased below t
35 F during extended plant outages. Corrective actions included revisions to plant procedures to include guidance for preventing frazilice. The inspectors considered the i
corrective actions adequate to close this issue.
I 08.5 (Closed) Violation 50-461/98003-06: This was a violation for which enforcement l
discretion was exercised which concerned the failure to implement a timely procedure
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revision to prevent barring over one emergency diesel generator (EDG) while in l
Mode 4 or 5 when the remaining EDGs were inoperable. In response to this issue, the
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licensee issued a revised procedure in February 1998, and assigned an individual to oversee the operations procedure revision process. The inspectors considered the corrective actions adequate to close this issue.
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i ll. Maintenance M1 Conduct of Maintenance M1,1 General Comments (61726 and 62707)
Portions of the following maintenance and surveillance activities were observed or reviewed by the inspectors-Procedure 8630.31 Nuclear System Protection System (NSPS) Untested j
islands Load Driver Procedure 8801.10 Division lli NSPS Card Select Decoder Calibration Procedure 9030.01 Analog Trip Module Channel Functional and Calibration Checks Procedure 9430.30 NSPS Untested Islands / Calibration (1-999 second) Time Delay l
AR F0632 Investigate 4160Vac - 1 A Reserve Feed Breaker Failure to Close l
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r AR F01096 Verify Calibration of Auxiliary Building Ventilation Differential Pressure Switch OPDSVA022
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MWR D25076 Conduct Exhaust Valve Timing on Division II Emergency Diesel Generator MWR D74382, --383 Install in-service Testing Artcelerometers on RHR-B and RHR-C per engineering change notices 30275 and 30276 I
MWR D82080 Terminate Cables in Reactor Core isolation Cooling Junction Box 1JB618K j
MWR D84409 Resize First-Step Orifice 1SX08M for Division i Shutdown l
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MWR D86986 Troubleshoot Erroneous Heating, Ventilation and Air
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Conditioning Offgas Release Rate Readings
i PMMVCA211 Inspect Control Room Ventilation Damper OVC34YB
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i The inspectors determined that observed activities were conducted with the procedure
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present and in active use. Additionally, technicians closely followed procedure i
requirements.
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M8 Miscellaneous Maintenance issues (92902)
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M8.1 (Closed) Violation NCV 50-461/98008-03: This was a violation for which enforcement discretion was exercised which concerned the failure to follow procedure during calibration of EDG VAR meter. This issue involved the change in work scope of a
maintenance activity on two occasions without returning the associated maintenance j
document to planning personnel for review and approval. The licensee determined that at the time of the inspectors' observation, it was acceptable for technicians to *N/A" job steps and change the method of performing tasks without prior approval. Corrective actions involved reinforcement of management expectations during shop meetings, issuance of a memorandum from the maintenance manager, and revision to maintenance procedures to provide guidance on following instructions in work documents. In addition, following the subject observation in May 1998, the inspectors have noted improvement in the use of maintenance documents by maintenance personnel and the quality of those documents. The inspectors considered the corrective actions adequate to close this issue.
M8.2 (Closed) Non-Cited Violation 50-461/98008-04: Failure to provide a procedure for l
safety-related switch gear maintenance. This issue involved the inspectors' observation j
of engineering and electrical maintenance personnel performing work without an I
approved procedure. The inspectors determined that the licensee developed Nuclear Station Engineering Department Procedure R.15, * CPS Motor Monitor," to provide
guidance on collection of motor data. The licensee also counseled the involved
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individuals and promulgated information regarding the requirements to use approved b
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E7 Quality Assurance in Engineering Activities E7.1 Review of Quality Assurance Assessment of Control of Contractors During the inspection period, the inspectors planned to review the Nuclear Station
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Engineering Department's (NSED's) contractor control program. However, the
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inspectors were informed that quality assurance (QA) personnel were conducting assessment 98-12-6399 to determine the adequacy and effectiveness of NSED's contractor control program. The inspectors reviewed the assessment results and determined that QA personnel identified several weaknesses in the program.
Specifically, the retrieval of purchase orders and resumes was difficult, multiple quality records were not properly vaulted, contractor assignments delineated on task assignment cards contained broad scopes instead of specific scopes, and contract managers were not being appropriately assigned. The inspectors concluded that the QA assessment was thorough and accurately depicted the state of NSED's contractor control program.
Quality assurance personnel informed the inspectors that the results of assessment 98-12-6399 were similar to a previous assessment of the training department's contractor control program. As a result, QA personnel planned to conduct another assessment in a different department to determine if weaknesses in the contractor control program were site-wide or departmental specific.
E8 Miscellaneous Engineering issues E8.1 (Olosed) Violation NCV 50-461/98003-03: This was a violation for which enforcement discretion was exercised which concerned the failure to ensure design requirements were translated into specifications for the RA system. This issue involved the lack of design documentation to support the bases for the low pressure alarm associated with RA header pressure. In February 1998, the licensee initiated CR 1-98-02-408 to complete calculations that determined the minimum pressure required to refill RA compressed air bottles as well as to determine the basis for the low pressure alarm setpoint.
Engineering personnel determined that a minimum of 1,850 psig was needed to ensure j
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of air supply for seven personnel as required by USAR Section 6.4.4.2. In
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addition, engineering personnel determined that the 400 psig low pressure alarm setpoint provided a warning to operations personnelindicating that approximately 27 minutes remained to change or refill RA compressed air bottles. The inspectors noted that the calculations conducted by engineering personnel adequately supported the bases of the minimum air pressure requirements.
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a On December 30,1998, the inspectors reviewed Procedure 5041.03, " Alarm Panel 5041 Annunciators - Row 3," and determined that the procedure had been revised on October 15,1998, to state, "The air bottles are INOP at less than 300 psig (less than 6-hour supply)." The inspectors noted that the revision to Procedure 5041.03 had not implemented the design basis for the minimum pressure requirements of 1,850 psig and 400 psig as determined in calculations developed by engineering personnel.
Criterion 111. " Design Control," of Appendix B to 10 CFR Part 50, requires, in part, that the design basis be correctly translated into specifications, drawings, procedures, and instructions. The failure to ensure design requirements for the RA system low pressure alarm setpoint were translated into plant procedures is a repeat violation of Criterion 111 of Appendix B to 10 CFR Part 50. However, because this violation satisfies the criteria in Section Vll.B.2, " Violations identified During Extended Shutdowns or Work Stoppages," of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, a Notice of Violation is not being issued for this Severity Level IV violation (NCV 50-461/98020-03).
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in response to the inspectors' observation, the licensee initiated a revision to
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Procedure 5041.03 to ensure the correct information regarding RA system pressure was i
reflective of the design calculations.
E8.2 LClosed) Licensee Event Report 50-461/98-023: Failure to adequately satisfy the TS surveillance requirement for the Division ll1 EDG. This issue was documented in NRC
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inspection Report 50-461/98014 and a violation, for which enforcement discretion
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was exercised, was identified due to the failure to satisfy TS surveillance
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requirement 3.8.1.17. In response to this issue, the licensee submitted a TS Bases change to the NRC for approval. The NRC should complete its review of the TS Bases
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change by mid-January 1999. No new issues were identified in the licensee event
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report.
E8.3 (Closed) Licensee Event Report 50-461/98-031: Surveillance procedures do not adequately consider accuracy of installed instrumentation in meeting TS surveillance j
requirements for EDG loading. In May 1997, the licensee identified that instrument inaccuracies had not been considered when determining EDG surveillance testing i
loading limitations. In response to this issue, engineering personnel initiated a review to j
determine the applicable worst case tolerances to be appiied to the kilowatt meters
utilized during EDG surveillance testing. When the tolerances were applied to the most recent EDG surveillance testing results, the licensee determined that the EDGs remained operable.
During a subsequent review, licensee personnelidentified that one of the assumptions used in the initial engineering review was invalid. Engineering personnel completed another review and concluded that the EDGs remained operable. However, based on a review of EDG surveillance tests completed prior to 1996, the licensee identified that the Division 11 and 111 EDGs failed to meet the 110 percent loading requirements specified in TS surveillance requirement (SR) 3.8.1.14.
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Technical Specification SR 3.8.1.14, requires that the licensee verify the ability of the i
Division 11 EDG to operate at greater than or equal to 4263 kilowatts for greater than or i
equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and the ability of the Division lli EDG to operate at greater than or equal to 2200 kilowatts for greater than or equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, every 18 months. The failure to test the EDGs at 110 percent of rated load is a violation of TS SR 3.8.1.14.
However, tds non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-6 ?/98020-04).
In response to this issue, the licensee implemented procedure changes to incorporate instrument inaccuracies into the acceptance criteria and to ensure that the all EDG loading requirements were met. However, a subsequent event disclosed that implementation of the new acceptance criteria resulted in potentially exceeding the allowed short term rating of the EDGs. To resolve this issue, the licensee submitted and the NRC approved a TS amendment which incorporated the provisions of Revision 3 to RG 1.9, " Selection, Design, and Qualification of Diesel-Generator Units used as Standby (Onsite) Electric Power Systems at Nuclear Power Plants,"into the EDG testing methodology. Specifically, RG 1.9 allowed EDG testing to be conducted at 90 to 100 percent of the continuous rating instead of 100 percent, and at 105 percent of the continuous rating instead of 110 percent to allow for the incorporation of instrument inaccuracies. The inspectors considered the licensee's corrective actions adequate to close this item.
IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Review of Radioloaical Postinas (71750)
On December 1 and 30,1998, the inspectors conducted tours of portions of the radiologically controlled area to determine the adequacy of radiological postings. No discrepancies were noted.
R8 Miscellaneous Radiological Protection and Chemistry Controls issues (92904)
R8.1 (Closed) Inspection Followup Item 50-461/97014-04: Labeling / Tagging of radioactive material. This issue involved the inspectors' observation of untabeled bags of radioactive material. Following the inspectors' observation in June 1997, several tours of the radiologically controlled area were conducted without the identification of similar occurrences.
R8.2 (Closed) Inspection Followuo item 50-461/97999-09: Vendor quality control (QC)
measurements were not reviewed by the licensee. This issue involved the integrated safety assessment team and special evaluation team observations that the QC program needed improvement for the analytical chemical measurements conducted by vendor and in-house technicians. Specifically, the results of vendor acceptance audits were not provided to the chemistry department. Further, chemistry department personnel had
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neither requested nor reviewed vendor laboratories' QA/QC programs to ensure the l-quality of vendor measurements in response to these issues, the licensee revised l
Procedure 6000.01, " Quality of Chemistry Activities,' to require that the chemistry
cross-check program be used by chemistry management to evaluate analytical procedures and chemistry technician performance. The inspectors considered the licensee's corrective actions adequate to close this item.
F8 Miscellaneous Fire Protection Issues (92904)
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l F8.1 (Closed) Violation NCV 50-461/98003-01d: This was a violation for which enforcement I
discretion was exercised which concerned the failure to perform adequate fire watch tours of EDG space. Corrective actions included training of fire watch personnel on touring spaces for emergent fire hazards and relocating the bar codes used to verify that the areas' fire watch inspection had been completed to locations that require entry into the affected space. During tours of the facility, the inspectors noted that bar codes had been relocated to locations that require a complete tour of the affected space. The
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inspectors considered the corrective actions adequate to close this item.
V. Manaaement Meetinas
X1 Exit Meeting Summary
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The inspectors presented the inspection results to members of licensee management at l
the conclusion of the inspection on January 6,1999. The licensee acknowledged the
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findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
X3 Management Meeting Summary On December 17,1998, a meeting was held on-site to discuss licensee restart activities i
and improvement initiatives as well as NRC activities associated with implementation of Manual Chapter 0350," Staff Guidelines for Restart Approval." Specific topics included operations performance, emergency preparedness, corrective action program, circuit
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breakers', and work item backlog management.
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l INSPECTION PROCEDURES USED IP 37551; Engineering Observations IP 61726: Surveillance Observations iP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support and Observations IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901: Followup - Operations IP 92902: Followup - Engineering IP 92903: Followup - Maintenance IP 92904: Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-461/98020-01 NCV Enforcement Discretion: Failure of operations personnel to initiate condition reports.
50-461/98020-02 NCV Enforcement Discretion: Failure to document completion of shiftly compensatory actions and make appropriate late entry in MCR journal.
50-461/98020-03 NCV Enforcement Discretion: Failure to translate the design information for the breathing air system into plant procedures.
50-461/98020-04 NCV Failure to test the Division ll and 111 EDGs at 110 percent load.
l Closed 50-461/97014-04 IFl Labeling / Tagging of radioactive material.
50-461/97999-09 IFl Vendor quality control measurements not reviewed by the l
licensee.
50-461/98003-01a NCV improper manipulation of control room computer screen.
50-461/98003-01b NCV Failure to restore control room breathing air header pressure.
50-461/98003-01d NCV Failure to perform adequate fire watch tours of EDG space.
50-461/98003-02 NCV Failure to implement corrective actions to prevent another unmonitored increase in MCR deficiencies.
50-461/98003-03 NCV Failure to ensure design requirements were translated into specifications for the RA system.
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50-461/98003-04 NCV Failure to operate traveling screens during cold weather to
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prevent ice blockage.
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50-461/98003-06 NCV Failure to implement a timely procedure revision to prevent
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barring over one EDG while in Mode 4 or 5 when the remaining EDGs were inoperable.
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l 50-461/98008-03 NCV Failure to follow procedure during calibration of EDG Var meter.
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50-461/98008-04
.NCV Failure to provide a procedure for safety-related switch gear
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maintenance.
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'50-461/98020-01 NCV Enforcement Discretion: Failure'of operations personnel to initiate
condition reports.
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50-461/98020-02 NCV ' Enforcement Discretion: Failure to document completion of shiftly j
compensatory actions and make appropriate late entry in MCR L
journal.
50-461/98020-03 NCV Enforcement Discretion: Failure to translate the design information for the breathing air system into plant procedures.
50-461/98020-04 NCV Failure to test the Division 11 and lit EDGs at 110 percent load.
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50-461/98-023 LER Failure to adequately satisfy the TS surveillance requirement for
the Division ill EDG.
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50-461/98-031 LER Surveillance procedures do not adequately consider accuracy of installed instrumentation in meeting TS surveillance requirements for EDG loading.
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PERSONS CONTACTED -
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l-Licensee
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t J. McElwain - Chief Nuclear Officer G. Hunger, Plant Manager - Clinton Power Station-E W. Romberg, Manager - Nuclear Station Engineering Department
' R. Phares, Manager - Nuclear Safety and Performance Improvement G. Baker, Manager - Quality Assurance
--J. Goldman, Manager - Work Management V. Cwietniewicz, Manager - Maintenance J. Gruber, Director - Corrective Action
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W. Maguire, Director - Operations
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J. Sipek, Director - Licensing D. Smith, Director - Security and Emergency Planning l
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.'J LIST OF ACRONYMS
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'AR -
l Action Request CCT'
Central Control Terminal..
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- CR
' Condition Report i
CSC.
Case Specific Checklist l
EDG-Emergency Diesel Generator
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GL Generic Letter-l
'MCR Main Control Roorn
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MWR?
Maintenance Work Request i
NSED Nuclear Station Engineering Department NSPS
' Nuclear System Protection System
.OD Operability Determination OWA-
. Operator Workaround QA Quality Assurance i
OC Quality Control RA Breathing Air i
RG Regulatory Guide
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SSC System, Structure or Component
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.TS Technical Specification
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USAR Updated Safety Analysis Report l
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