IR 05000461/2013007
| ML13274A698 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/01/2013 |
| From: | Lipa C A NRC/RGN-III/DRP/B1 |
| To: | Pacilio M J Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-13-007 | |
| Download: ML13274A698 (32) | |
Text
October 1, 2013
Mr. Michael Senior Vice President, Exelon Generation Co., LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT: CLINTON POWER STATION PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000461/2013007
Dear Mr. Pacilio:
On August 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at Clinton Power Station. The enclosed report documents the inspection results, which were discussed on August 30, 2013, with Mr. B. Taber and other members of the licensee staff. The inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Clinton Power Station was effective. Licensee identified problems were entered into the corrective action program at a low threshold. Problems were effectively prioritized and evaluated commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from industry operating experience were generally reviewed and applied when appropriate. Audits and self-assessments were effectively used to identify problems and appropriate actions. One NRC-identified finding of very low safety significance (Green) was identified during this inspection. This finding was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Clinton Power Station. If you disagree with the cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III and the NRC Resident Inspector at Clinton Power Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Christine Lipa, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62
Enclosure:
Inspection Report 05000461/2013007
w/Attachment:
Supplemental Information cc w/encl: Distribution via ListServTM Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-461 License No: NPF-62
Report No: 05000461/2013007 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station Location: Clinton, IL Dates: August 12 - 30, 2013 Inspectors: L. Haeg, Senior Resident Inspector, Duane Arnold, Team Lead R. Langstaff, Senior Reactor Inspector D. Lords, Resident Inspector, Clinton Power Station C. Zoia, Operations Inspector S. Mischke, Resident Inspector, Illinois Emergency Management Agency Approved by: Christine Lipa, Chief Branch 1 Division of Reactor Projects 1 Enclosure
SUMMARY OF FINDINGS
Inspection Report (IR) 05000461/2013007, 08/12/13 - 08/30/13; Clinton Power Station; Biennial Baseline Inspection of the Identification and Resolution of Problems. This team inspection was performed by the Duane Arnold Senior Resident Inspector, the Clinton Resident Inspector, two Region III inspectors, and the Clinton Illinois Emergency Management Agency Resident Inspector. One Green finding was identified by the inspectors.
The finding was considered a non-cited violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006. Identification and Resolution of Problems Overall, the Clinton Power Station Corrective Action Program (CAP) was appropriately identifying, evaluating, and correcting issues. Issues were generally being identified at a low threshold, evaluated appropriately, and corrected in the CAP. Overall performance in prioritization and evaluation of issues was acceptable. Issues were appropriately screened by both the Station Ownership Committee and the Management Review Committee and the inspectors had no concerns with those items assigned an apparent cause evaluation or root cause evaluation. Corrective actions were generally appropriate for the identified issues. Those corrective actions addressing selected NRC documented violations were also generally effective and timely. The inspectors' review going back five years of the licensee's efforts to address issues with Service Water (SX) system did not identify any negative trends or inability by the licensee to address long term issues. However, the inspectors determined that corrective actions for some issues had not been effective. In general, operating experience (OE) was effectively utilized at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments and no significant issues were identified during the inspectors' review of licensee OE evaluations. The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold level. The inspectors observed that CAP items had been initiated for issues identified through Nuclear Oversight department audits and self-assessments. The inspectors reviewed the most recent self-assessment performed on the CAP; found no issues, and generally agreed with the overall results and conclusions drawn. The inspectors determined that plant staff were aware of the importance of having a strong safety-conscious work environment and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for raising safety issues or knew of anyone who had failed to raise issues. All plant staff interviewed had an adequate knowledge of the CAP process. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety-conscience work environment.
A. NRC-Identified
and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a finding of very low safety significance associated with the licensee's failure to appropriately evaluate the functionality of the 'B' Diesel Fire Pump (DFP) after identifying a degraded/non-conforming crankcase pressure condition while performing testing on June 13, 2011, and on numerous occasions thereafter, that could have affected the ability of the system to perform a function important to safety. An associated NCV of Clinton Power Station License Condition 2.F was identified. The License Condition required the licensee to implement and maintain in effect all provisions of the approved Fire Protection program as described in the Updated Final Safety Analysis Report (UFSAR). Appendix E, Section 4.0.C.8 of the UFSAR stated that the Clinton Power Station Quality Assurance Program establishes measures for corrective action on conditions adverse to fire protection. Quality Assurance Topical Report (QATR), Chapter 16, Section 2.4 stated that personnel performing the evaluation function of conditions adverse to quality are responsible for considering the cause and the feasibility of corrective action to assure that the necessary quality of an item is not deteriorated. The licensee entered the issues into the CAP and initiated corrective actions to evaluate the functionality of the 'B' DFP. The failure to correctly evaluate a degraded/non-conforming condition potentially affecting the functionality of structures, systems, and components (SSCs) important to safety would become a more significant safety concern if left uncorrected because it could reasonably result in an unrecognized condition of an SSC failing to fulfill a function important to safety. In addition, the finding was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the degraded condition of high crankcase pressure resulted in repeat operational equipment challenges and extended periods of unavailability of the 'B' DFP. Therefore the finding was of more than minor significance. The finding was a licensee performance deficiency of very low safety significance (Green) because it involved only a low degradation of the protection against external factors function due to a redundant train that could supply water. The inspectors concluded that this finding affected the cross-cutting area of problem identification and resolution. Specifically, the licensee failed to thoroughly evaluate problems such that the resolutions addressed causes and extent of condition as necessary for an SSC important to safety when a degraded/non-conforming condition was identified. P.1(c) (Section 4OA2.1.b.(2))
B. Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
The activities documented in Sections
.1 through .4 constituted one biennial sample of Problem Identification and Resolution (PI&R) as defined in Inspection Procedure
(IP) 71152.
.1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the licensee's CAP implementing procedure LS-AA-125, "Corrective Action Program (CAP) Procedure," Revision 17, and other implementing procedures for compliance with the requirements of Title 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion XVI, "Corrective Action," were met. The inspectors observed meetings related to the CAP, such as the Station Oversight Committee (SOC) and Management Review Committee (MRC) meetings, to obtain insights into the licensee's oversight of the CAP. Additionally, several licensee personnel were interviewed to assess their understanding of and their involvement in the CAP at Clinton Power Station (CPS). The inspectors reviewed selected condition reports (CRs) across all seven Reactor Oversight Process cornerstones to determine if problems were being properly identified and entered into the licensee's CAP. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, OE reports, and NRC-documented findings as sources to select items to review. Additionally, the inspectors reviewed CAP items generated as a result of facility personnel performance in daily plant activities, and reviewed a selection of completed investigations from the licensee's various investigation methods, including root, apparent, and common cause evaluations. The majority of risk-informed samples of CRs reviewed were issued after the last NRC biennial PI&R inspection completed in early June of 2011. The inspectors performed a more extensive review of the safety-related service water (SX) system. This review consisted of a five year search of related issues identified in the CAP and discussions with appropriate licensee staff to assess the licensee's efforts in addressing identified concerns. During their reviews, the inspectors evaluated whether the licensee's actions were in compliance with the facility's CAP and Title 10 CFR Part 50, Appendix B requirements.
Specifically, the inspectors evaluated if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the station's CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also assessed whether licensee staff had assigned appropriate investigation methods to ensure the proper determination of root, apparent, and contributing causes.
The inspectors also reviewed the timeliness and effectiveness of corrective actions for selected CRs, completed investigations, and NRC findings, including NCVs.
4 Enclosure b. Assessment (1) Identification of Issues Based on the results of the inspection, the inspectors concluded that, in general, the licensee was effective in identifying issues at a low threshold and entering them into the CAP. The inspectors determined that problems were generally identified and captured in a complete and accurate manner in the CAP. The licensee appropriately screened issues from both NRC generic communications and industry OE at an appropriate level and entered them into the CAP when applicable. The inspectors also noted that deficiencies that were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel were entered into the CAP for resolution. Workers were familiar with the CAP and felt comfortable raising concerns. This was evident by the large number of CAP items generated annually; which were reasonably distributed across the various departments. Based on the interviews of licensee personnel, some individuals expressed confusion regarding station CAP engagement indicators. The confusion related to the perception from some individuals that intermittent declining CR generation rates per person or per department had led to management expecting higher CAP engagement. For example, some individuals stated that they were expected to document at least one issue in the CAP per month. License management informed the inspectors that there was no specific expectation for individuals to document a certain number of issues in the CAP. Although the inspectors recognized the importance of reinforcing engagement in the CAP by all station personnel, they noted that management expectations were not consistent, clear, or well understood. The licensee captured this inspector observation in CR 01555073. The inspectors determined that the licensee was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed. The inspectors performed a five year extensive review of the SX system. As part of this review, the inspectors interviewed the system engineer, reviewed a sample of SX system CRs, operating experience, and causal evaluations. The inspectors reviewed the CAP procedures that provided trending guidance and walked down various portions of the SX system area to visually inspect equipment condition. The inspectors concluded that SX system-related concerns were identified and entered into the CAP at a low threshold, and concerns were resolved in a timely manner commensurate with their safety significance. An observation related to the adequacy of documenting the decision making regarding a declining discharge pressure trend on the Division 3 SX pump is documented in Section 4OA2.1.b.(2) below. Findings No findings were identified.
5 Enclosure (2) Effectiveness of Prioritization and Evaluation of Issues Based on the results of the inspection, the inspectors concluded that, overall, the licensee was effective in prioritizing and evaluating issues commensurate with the safety significance of the identified issue, including an appropriate consideration of risk. The inspectors determined that issues were being appropriately screened by both the SOC and MRC, and issues identified of higher significance were assigned root or apparent cause evaluations. Notably, the inspectors concluded that the licensee's prioritization and evaluation of issues had improved since the prior biennial PI&R inspection considering the documented observations of a declining trend in this area in June of 2011. The inspectors performed a detailed review of issues entered into the Maintenance Rule (a)(1) category over the last two years. The review included the main control room ventilation (VC) system which had experienced a repeat maintenance preventive functional failure. The inspectors reviewed action plans approved by the maintenance rule expert panel, associated causal evaluations, Maintenance Rule evaluations, and other associated CRs. The inspectors noted that the licensee generally showed no reluctance in placing SSCs into Maintenance Rule (a)(1) status if appropriate.
Corrective actions to address the deficiencies were prescribed and in progress.
Additionally, detailed reviews of the SSCs generally occurred before returning SSCs to Maintenance Rule (a)(2) status. The inspectors determined that the licensee usually evaluated equipment operability and functionality requirements adequately after a degraded or non-conforming condition was identified. In general, appropriate actions were assigned to correct degraded or non-conforming conditions. However, the inspectors noted vulnerabilities and deficiencies in the licensee's evaluations of operability, functionality, and reportability for some conditions. These vulnerabilities and deficiencies led to several NRC findings and NCVs over the prior two years. Observations Common Cause Analyses The inspectors reviewed licensee procedure LS-AA-125-1002, "Common Cause Analysis Manual," Revision 7, to determine what criteria were being used to initiate a Common Cause Analysis (CCA). The inspectors noted that the procedure did not contain prescriptive criteria to determine when a CCA was warranted, but rather cognitive trending and/or SOC or MRC requests. Although the inspectors did not identify any significant quantitative trends that warranted a CCA, they were concerned that the lack of more prescriptive criteria could allow for an adverse trend to not be analyzed. The licensee documented this observation in CR 01555046. For the CCAs that were reviewed by the inspectors, the bases for performing the analyses appeared appropriate as well as the evaluation thoroughness and actions taken.
6 Enclosure Division 3 SX Pump Discharge Pressure Trend The inspectors reviewed CR 01049920 regarding a declining discharge pressure trend of the Division 3 SX pump and noted that an Operational Decision Making (ODM) item was created to track the issue; however, the ODM was closed without documenting the basis for closure. After further review, the inspectors verified that the ODM closure was acceptable since actions were completed to obtain a spare pump for eventual replacement, but were concerned that the bases were not documented by the licensee.
The licensee documented the inspector's concern in CR 01550820. Investigation Class Criteria and Trend Coding Issue The inspectors reviewed NCV 05000461/2011009-01 associated with an unsecured fire door. Following the NRC exit meeting for the preliminary NCV in March of 2011, the licensee documented the potential NCV in the CAP and classified the investigation class as level 'D'. Per LS-AA-120, "Issue Identification and Screening Process," Revision 14, a level D investigation class is described as requiring "no formal causal evaluation to determine causes or corrective actions." The inspectors noted that NRC Enforcement Policy states, in part, that the NRC will normally issue an NCV following placement of the violation into the CAP to restore compliance and address recurrence. The inspectors were concerned that labeling a preliminary NCV as investigation class 'D' could result in not performing an evaluation to determine causes or corrective actions, as stated in LS-AA-120. The inspectors performed additional reviews of how the licensee dispositioned the violation following receipt of the inspection report documenting the NCV. The inspectors noted that the cause and corrective actions were straightforward for the violation in this case and subsequent evaluations performed by the licensee addressed recurrence. However, the subjective criteria for determining investigation class per LS-AA-120 had the potential to result in not evaluating violations that NRC inspectors were considering as non-cited. The licensee documented the inspector's observation in CR 01551297. The inspectors also questioned whether the licensee was appropriately applying trend codes to fire door issues when the inability of fire doors to automatically close and/or latch was identified in the CAP. The licensee documented the inspector's question in CR 01550099 to evaluate whether CAP trend coding for fire door issues could be improved to better identify developing adverse trends in human performance aspects versus equipment aspects related to fire door deficiencies. Operability and Functionality Determinations and OE Assessment Weaknesses The inspectors noted an adverse performance trend for the past five years related to NRC findings involving the licensee's evaluation of degraded/non-conforming plant conditions for operability, functionality and/or reportability. While corrective actions were performed to address the adverse trend in accordance with the CAP, the trend appeared to be ongoing. The inspectors reviewed Operations department weaknesses in the areas of Operations' ownership of the operability determination process, review and use of OE, and technical oversight.
7 Enclosure The inspectors noted Operations ownership weaknesses involving the inadequate operability evaluation for hub cracking of VC return fan 0VC04CB in 2011. This failure, which resulted in NRC-identified NCV 05000461/2011004-04, was evaluated by the licensee to have an apparent cause of "Lack of Engineering Judgment" and a contributing cause of "Lack of Management Rigor" for not requiring further equipment inspections. The inspectors noted that the Operations department, the "owner" of the operability process, was not identified to be a significant part of these corrective actions.
The inspectors also noted that eventual hub failure of VC return fan 0VC04CB (and the subsequent incorrect operability evaluation) was avoidable if OE had been more fully utilized. Specifically, similar failures had occurred at Brunswick as noted in OE in March of 2004; in a root cause evaluation from Three Mile Island in March of 2005; and again at Clinton in October of 2006. Although these OE examples did not specifically identify fan blade replacement as the appropriate preventive maintenance (PM)approach, replacement was ultimately found to be needed after numerous attempts to monitor degradation via vibration monitoring were proved to be ineffective (this was documented in ACE 1225739 as being a "Latent Organizational Weakness" and corrected by implementing the replacement PM) after the 2011 failure. Additionally, technical oversight weaknesses were noted for three issues reviewed by the inspectors: hydrogen igniter testing, VC flow oscillations, and reactor coolant system (RCS) pressure isolation valve (PIV) leakage testing. Specifically:
- Hydrogen igniters were to be verified operable every 24 months per Technical Specification (TS) Surveillance Requirement (SR) 3.6.3.2.4. Although the test procedure to perform the SR was not owned by Operations, the results were reviewed by Operations for TS conformance and were found to be incorrect for a period exceeding 10 years. Specifically, several hydrogen igniters specified as
"accessible" were not tested as required by the procedure. When the procedural deficiency was finally identified by the NRC in 2011, five hydrogen igniters were considered inoperable due to missed surveillances and required retesting (reference CR 01164658-02 and NCVs05000461/2011002-02 & -03).
- When presented with VC makeup flow oscillations below the required minimum value per procedure CPS 9070.01, "Control Room HVAC Air Filter Package Operability Test Run," a senior reactor operator (SRO) failed to identify the challenge to VC system operability per TS 3.7.3. In addressing the abnormality, the SRO documented in a CR that there were "Possibly problems with OVC114YA. Investigate and correct issue." When questioned by the NRC in 2011, it was determined that other Operations personnel may have had a similar knowledge deficiency that was ultimately addressed by "Read & Sign" training (reference apparent cause evaluation (ACE) 01239007 and NCV 05000461/2011004-04).
- Contrary to the guidance of SR 3.4.6.1, RCS PIVs were pressurized to a value exceeding the maximum test pressure of 1025 psig during testing. The procedural guidance of CPS 9843.01, "ISI Category A Valve LRT," Revision 35f, had allowed a maximum test pressure of 1025 psig (+25 psig, -0 psig). When the NRC identified this discrepancy in 2011, the licensee found that they had evaluated the procedural error as conservative several years earlier (the error had existed since February of 2002, and was previously evaluated in 2005) (reference NCV 05000461/2011003-02, Clinton Licensee Event Report (LER) 2011-006, and ACE 01212825).
8 Enclosure In summary, it was found that while some recent improvements in the operability and functionality determination process were noted, weaknesses in the utilization of OE and technical oversight continued to exist. At the end of this inspection, the inspectors acknowledged that the licensee had improvement initiatives in place to strengthen the operability and functionality determination process and OE assessments, but emphasized continued efforts due to the apparent slow rate of progress. Effectiveness Review Timeliness The inspectors reviewed root cause report (RCR) 01506929, "Manual Scram Due to Loss of Electro-Hydraulic Control (EHC) Fluid," and identified that the effectiveness review (EFR) to verify lock washers installed, work orders revised, and bill of materials corrected had a due date of April 1, 2015. However, the inspectors noted that the corrective action to prevent recurrence (CAPR) to revise work order documents had been completed by June 28, 2013. The inspectors questioned why the EFR had such a late due date since the CAPRs were complete and could be reviewed for effectiveness. The licensee determined that an administrative change to the CAPR occurred during development of the RCR that removed some actions from the CAPR, but the EFR due date was not changed accordingly. The licensee documented the excessive EFR due date in CR 01549645 to adjust the EFR due date. Findings Failure to Evaluate a Degraded/Non-conforming Condition
Introduction:
The inspectors identified a finding of very low safety significance (Green) and associated NCV of License Condition 2.F for the licensee's failure to appropriately evaluate the functionality of the 'B' diesel fire pump (DFP) after identifying a degraded/non-conforming crankcase pressure condition during testing on June 13, 2011, and on numerous occasions thereafter, which could have affected the ability of the system to perform a function important to safety.
Description:
On June 13, 2011, during a post-maintenance test run of the 'B' DFP, excessive smoke was observed coming from the engine on the pump end as well as coming from underneath the engine on its east end. These issues were documented in the licensee's CAP as CR 01228254 that stated the smoke was most likely due to a positive crankcase pressure condition. The CR recommended that Engineering and Mechanical Maintenance departments either determine whether the condition was acceptable, or determine the feasibility of an engine teardown and replacement of the piston compression rings. At that time, the post-maintenance test was considered a failure and the pump remained non-functional pending the successful completion of CPS 9071.01, "Diesel Driven Fire Pumps Operability Test," as documented in main control room logs. Subsequently, on June 14, 2011, CPS 9377.04, "Battery Operability Test," and a partial performance of CPS 9072.02, "Fire Pump Capacity Test," were satisfactorily completed and the pump was declared functional. No maintenance was performed after the failed test of June 13, 2011, and there was no documented evaluation of the degraded crankcase pressure condition for the 'B' DFP.
9 Enclosure On July 7, 2011, during the next scheduled surveillance test, the 'B' DFP engine oil dipstick unseated and sprayed four to eight ounces of oil. The issue was documented in CR 01237444, and stated in part, that the same event had occurred during that last time the engine was run. A specific question was asked in CR 0123744: "Is there a problem with the 0FP01PB engine that is causing an above normal crankcase pressure?" It was also noted that although the pump subsequently passed its surveillance test, the crankcase pressure was neither an observable parameter nor an acceptance criteria during testing. To answer the question posed in CR 0123744, the following response was provided: "Dipstick was reinstalled and pump surveillance completed SAT; appears to be no problem with crankcase pressure." The inspectors noted that the licensee performed no further evaluation at that time, and that engine crankcase pressure of the
'B' DFP was only first measured on November 12, 2012 (a year and four months later). On August 3, 2011, during a surveillance test of the 'B' DFP, the engine dipstick again ejected and sprayed one to two quarts of oil onto the engine batteries as documented in CR 01247414. The dipstick was replaced several times and eventually secured in place with a zip-tie. The pump was declared non-functional and the CR stated that the possible blow-by of pistons causing crankcase pressurization was a restraint to declaring the subsystem functional. Subsequently, on August 8, 2011, main control room logs stated that although no work had been completed on the 'B' DFP, the condition identified (ejection of the dipstick) had been resolved and tested satisfactory, and the subsystem was declared functional. No evaluation of crankcase pressure was performed by the licensee, nor was there an explanation why the restraint to declaring the 'B' DFP functional for crankcase pressurization was no longer a concern. The pump subsequently passed 13 surveillance tests. During this time there were numerous documented cases of the degraded condition of high crankcase pressure being masked during these surveillance tests either by repeatedly reinserting the dipstick or using a zip-tie to hold it in place. Crankcase pressure was never observed nor measured during any of these surveillance tests. On September 3, 2012, the 'B' DFP received an automatic start signal. Upon entering the area, the pump was observed to be spraying oil into the room and onto its batteries. The engine was secured and left in the OFF position due to no oil level registering on the dipstick when it was reinserted into the engine block. The pump was later placed in AUTO and declared functional due to the addition a quart of oil. Later, on September 5th, 2012, CR 01409202 was written to, again, document the concern of the degraded condition of high crankcase pressure due to leak-by past the piston compression rings. Again, similar to CR 01228254 written on June 13, 2011, the recommended action was for engineering to perform an evaluation of crankcase pressure. This time, in response, Engineering documented on September 12, 2012, that the symptoms were indicative of high crankcase pressure and that the diesel engine vendor representative should be brought on site to measure the crankcase pressure.
Engineering also stated that if the pressure was found to be greater than 22 inches of water, the engine would require a rebuild. On September 20, 2012, the 'B' DFP received another automatic start signal. Once again, the dipstick was ejected and the engine sprayed a quart of oil onto its batteries and other components as documented in CR 01416249. The engine was immediately shut down for personnel safety reasons and declared functional but degraded. Eventually, when 'B' DFP engine crankcase pressure was measured on November 2, 2012, the instrument gauge pegged high greater than 30 inches of water within less than a minute of operation of the engine.
10 Enclosure The diesel engine vendor (Cummins) field engineer stated that if the engine crankcase pressure was found to be higher than 22 inches of water, an engine rebuild was required. High diesel engine crankcase pressure was also a concern for a number of other reasons. Notably, CR 01408355 documented an injury suffered by a licensee operator due to a slip while walking around the engine after it sprayed oil which had covered the floor, and CR 01432868 documented on October 29, 2012, that the 'B' DFP engine had to be secured and disabled due to concerns related to the fire hazard created by oil on the exhaust manifold after the dipstick had dislodged and deposited oil from the dipstick tube. The inspectors also noted that high diesel engine crankcase pressures indicated a potentially explosive condition within the engine. Specifically, the possibility for overheated bearings to ignite hot oil vapors if air was allowed to enter a pressurized crankcase with degraded engine piston compression rings.
Analysis:
The inspectors determined that the licensee's failure to appropriately evaluate the functionality of the 'B' DFP was contrary to the licensee's quality assurance program as described in NO-AA-10, "Quality Assurance Topical Report," Appendix A, and was a performance deficiency. Specifically, after first identifying a degraded condition of high crankcase pressure on June 13, 2011, and on numerous occurrences thereafter where identical symptoms existed, the licensee failed to evaluate the functionality of the 'B' DFP with respect to the underlying degraded condition and instead focused on symptoms (i.e. dipstick ejection and possible operator error). The finding was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events (i.e., fire) to prevent undesirable consequences (i.e., core damage).
Specifically, although incidents involving dipstick ejections had not resulted in the failure of the 'B' DFP, the inspectors could not rule out the possibility of an engine failure due to either accelerated oil loss or potential ignition of oil with associated fire damage. In accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," Table 2, the inspectors determined the finding degraded fire protection defense-in-depth strategies. The inspectors also determined, using Table 3, that it could be evaluated using Appendix F, "Fire Protection Significance Determination Process." The inspectors determined that this finding constituted a "Low Degradation" in accordance with the criteria established in IMC 0609 Appendix F, Attachment 2. Therefore in answering 'yes' to question 'B' of Step 1.4 of IMC 0609 Appendix F, Attachment 1, the inspectors determined that the finding was of very low safety significance (i.e., Green) with no further analysis required. This finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because the licensee did not thoroughly evaluate problems such that the resolutions addressed causes and extent of conditions, as necessary. This included properly classifying, prioritizing, and evaluating for operability (or functionality) conditions adverse to quality. Specifically, the licensee failed to appropriately evaluate the cause of the 'B' DFP dipstick ejections after identifying a degraded/non-conforming crankcase pressure condition while performing testing on June 13, 2011, and on numerous occasions thereafter, which could have affected the ability of the system to perform a function important to safety. P.1(c)
11 Enclosure
Enforcement:
Clinton Power Station License Condition 2.F requires the licensee to implement and maintain in effect all provisions of the approved Fire Protection program as described in the UFSAR as amended and as approved through Safety Evaluation Report (NUREG-0853) dated February of 1982 and Supplement Nos. 1 thru 8. Appendix E, Section 4.0.C of the UFSAR as amended states that portions of the Quality Assurance Program, as delineated in Appendix A of the QATR, apply to fire protection.
Appendix A, Section 2.4 of the QATR, states, in part, that the Quality Assurance Program established for fire protection SSCs that protect SSCs important to safety ensures that corrective actions meet the applicable Quality Assurance guidelines as described in the applicable edition of Branch Technical Position 9.5-1 for each Exelon site. The diesel engines for the fire pumps are fire protection SSCs that protect SSCs important to safety. Appendix E, Section 4.0 of the UFSAR provides the applicable edition of Branch Technical Position 9.5-1 for Clinton Power Station. Appendix E, Section 4.0.C.8, states that the Clinton Power Station Quality Assurance Program establishes measures for corrective action of conditions adverse to fire protection. Chapter 16 of the QATR describes the Company program to identify and correct conditions adverse to quality. Specifically, QATR Chapter 16, Corrective Action, Section 2.4, "Evaluation and Qualification," states, "Personnel performing the evaluation function are responsible for considering the cause and the feasibility of corrective action to assure that the necessary quality of an item is not deteriorated." Contrary to the above, on June 13, 2011, and on numerous occasions thereafter, the licensee failed to implement and maintain in effect all provisions of the approved Fire Protection program as described in the UFSAR as amended. Specifically, the licensee failed to appropriately evaluate the functionality of the 'B' DFP after identifying a degraded/non-conforming crankcase pressure condition. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety significance and was entered into the licensee's CAP as CR 01552494.
The licensee replaced the 'B' DFP engine in December of 2012 under work order 1448046. (NCV 05000461/2013007-01, Failure to Evaluate a Degraded/ Non-conforming Condition on Diesel Fire Pump) (3) Effectiveness of Corrective Action Based on the results of the inspection, the inspectors concluded that the licensee was generally effective in addressing identified issues, and the assigned corrective actions were generally appropriate. The licensee implemented corrective actions in a timely manner, commensurate with their safety significance, including an appropriate consideration of risk. Problems identified using root or apparent cause methodologies were resolved in accordance with CAP procedures and regulatory requirements. Corrective actions designed to preclude repetition were generally comprehensive, thorough, and timely. For example, at the time of this inspection, only three open operator workarounds/burdens were in place; a particularly low number considering that the station was late in the operating cycle. The inspectors sampled corrective action assignments for selected NRC documented violations and determined that actions assigned were generally effective and timely. The inspectors' review going back five years of the licensee's efforts to address issues with SX system did not identify any negative trends or the inability by the licensee to address long term issues.
12 Enclosure Based on the finding and NCV discussed above associated with the failure to evaluate the functionality of the 'B' DFP, the inspectors noted that interim corrective actions taken by the licensee to address the high crankcase pressure condition since 2011 were generally ineffective to eliminate the cause. The inspectors noted that the performance of testing to measure crankcase pressures of the 'B' DFP engine were not timely to properly assess ongoing degradation of the engine that ultimately led to engine replacement. Failure to Take Appropriate Corrective Action for a Condition Adverse to Quality During the review of RCR 01307531, "Chemistry Parameters Exceeded Action Level 1 Limits," the inspectors identified that the licensee's corrective action to resolve Contributing Cause #2, "Reactor Coolant cleanup was not maximized during startup,"
was to code work order 1498918, "Rebuild/Rework reactor water cleanup (RT) filter demineralizer 'B' actuator for 1G36-F006B" as a corrective action. This work order for the RT actuator was completed on December 18, 2011. The action level 1 limits for chemistry parameters were exceeded on December 21, 2011. Therefore the corrective action for the contributing cause of not maximizing RT during startup was to repair a valve actuator which was actually repaired prior to the occurrence of the condition adverse to quality. Inspectors observed that repair of the 1G36-F006B did not in fact prevent chemistry parameters from exceeding limits. Licensee procedure LS-AA-125, "Corrective Action Program (CAP) Procedure," Revision 17, defines a corrective action as "an action taken or planned that restores a condition adverse to quality to an acceptable condition or capability." In this case, the condition adverse to quality was that reactor coolant cleanup was not maximized during startup. The action assigned to correct this condition (coding the work order to repair the 1G36-F006B valve actuator as a corrective action), did not restore the condition adverse to quality to an acceptable condition. In fact, changing the coding of the work order had no actual plant impact. The work itself was completed long before the coding change occurred, and, completing the work did not prevent chemistry parameters from exceeding limits four days later. The inspectors determined that the licensee's failure to have an appropriate corrective action for a licensee-identified condition adverse to quality is a violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," which requires, in part, that measures shall be established to assure that conditions adverse to quality and non-conformances are promptly identified and corrected. Licensee procedure LS-AA-125 states that corrective action assignments are the method by which the licensee restores a condition adverse to quality. Contrary to the above requirements, the corrective action assigned to re-code the work order to rebuild/rework 1G36-F006B did not restore the condition adverse to quality of failing to maximize use of the reactor water cleanup system during startup. The licensee generated CR 01550123, "PI&R - Challenge to Actions from Root Cause #1307531-06," to revise RCR 01307531 to reference ACE 01313140 corrective actions #18, #20 and #27, as well as action items #19 and #34 that clearly address the condition adverse to quality of failing to maximize the use of the reactor water cleanup system during startup. The inspectors determined that the performance deficiency was minor because it was administrative in nature and did not represent a safety concern.
13 Enclosure This failure to comply with the requirements of Title 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," constitutes a violation of minor significance that is not subject to enforcement action in accordance with the NRC's Enforcement Policy. Findings No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed the licensee's implementation of the facility's OE program. Specifically, the inspectors reviewed implementing OE program procedures, observed daily meetings for the use of OE information, and reviewed completed evaluations of OE issues and events. The intent was to determine if the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and implemented effectively and in a timely manner. b. Assessment Based on the results of the inspection, the inspectors concluded that, in general, OE was effectively utilized at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments and no issues were identified during the inspectors' review of licensee OE evaluations. During interviews, several licensee personnel commented favorably on the use of OE in their daily activities. The inspectors identified several examples where OE was identified and documented as part of apparent and root cause evaluations, determined to not apply to the condition being evaluated, but minimal to no discussion was documented as to why the OE was not applicable. For example, RCR 01295617, "Automatic Scram on High Pressure During Approach to Unit Shutdown," RCR 01408282, "Emergency Reserve Auxiliary Transformer and Emergency Reserve Auxiliary Transformer Static Var Compensator Tripped," and ACE 01258926, "NRC Identified Weakness in 0VC04CB Operability Evaluation," each documented OE that was identified as part of a search during the evaluations; however, there was no documentation as to why it did not apply. The inspectors were concerned that the lack of the documented justification for why OE did/did not apply could result in minimizing the importance of reviewing OE when evaluating a condition or event at the station that could have been prevented if OE was considered. The licensee documented the inspectors' observation as CR 01555051.
Findings No findings were identified.
14 Enclosure
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed selected Nuclear Oversight comparative and departmental audits, "check-in" assessments, and focused area self-assessments. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the CAP. In addition, the inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs. b. Assessment Based on the results of the inspection, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold level. The audits and self-assessments were completed by personnel knowledgeable in the subject area. In many cases, these audits and self-assessments had identified numerous issues that were not previously recognized by the licensee. These issues were entered into condition reports as required by CAP procedures. The inspectors reviewed the focused area self-assessment that the licensee had performed for the 2013 biennial PI&R inspection. They noted that the self-assessment, while thorough, may not have reviewed all items intended since it did not consider issues that occurred prior to, or during, the 2011 biennial PI&R inspection. For example, the aforementioned NCV 05000461/2011009-01 was not within the scope of the self-assessment. If it had been reviewed, the licensee may have had the opportunity to identify the investigation class concern. The licensee acknowledged this observation as a potential enhancement to their focused self-assessment process. Findings No findings were identified.
.4 Assessment of Safety-Conscious Work Environment (SCWE)
a. Inspection Scope
The inspectors interviewed selected Clinton Power Station personnel to determine if there were any indications that individuals were reluctant to raise safety concerns to either their management, supervision, the employee concerns program (ECP), or the NRC due to the fear of retaliation. The inspectors reviewed selected ECP activities to identify any emergent issues or potential trends. The inspectors also assessed the SCWE through a review of ECP implementing procedures, discussions with the ECP representative, interviews with personnel from various departments, and reviews of CRs.
The licensee's programs to publicize the CAP and ECP were also reviewed. The inspectors reviewed licensee self-assessments and assessments by external organizations of safety culture to determine if there were any organizational issues or trends that could impact the licensee's safety performance.
15 Enclosure b. Assessment The inspectors did not identify any issues that suggested conditions were not conducive to the establishment and existence of a SCWE. Licensee personnel were aware of and generally familiar with the CAP and other processes, including the ECP, through which concerns could be raised. In addition, a review of the types of issues in the ECP database indicated that personnel were appropriately using the CAP and ECP to identify issues. The staff also indicated that management had been supportive of the CAP by providing time and resources for employees to generate their own condition reports. The staff also expressed a willingness to challenge actions or decisions that they believed were unsafe. All employees interviewed noted that any safety issue could be freely communicated to supervision and safety significant issues were being corrected.
Some employees indicated a number of low level items were not being corrected in a timely manner. The inspectors determined that the timeliness of the planned corrective actions for the examples given were commensurate with their safety significance. Various safety culture assessments had been performed by contractors, the licensee's staff, and a nuclear plant owner/operators organization. The results indicated that there were no impediments to the identification of nuclear safety issues. During inspector interviews of station personnel, the inspectors received feedback from several individuals that they had not received feedback emails in the instances where their supervisor (initiator) had submitted a condition report for issues they (originator) had identified. The inspectors questioned whether CAP feedback was provided to the initiators and originators in order for the personnel to review the actions being taken for issues they were involved with. The licensee's CAP program was automated such that CAP feedback was emailed to the initiator only and not the originator as well. The inspectors questioned whether the licensee had considered this potential deficiency in the CAP feedback process since the originating individual of a CR would not necessarily receive feedback. The licensee documented this question in CR 01555048. Findings No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary On August 30, 2013, the inspectors presented the inspection results to Mr. B. Taber and other members of the licensee staff.
The licensee acknowledged the issues presented.
The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- B. Taber, Site Vice President
- T. Stoner, Plant Manager
- D. Kemper, Site Engineering Director
- J. Stovall, Maintenance Director
- J. Cunningham, Operations Director
- K. Baker, Regulatory Assurance Manager
- R. Frantz, Regulatory Compliance
- K. Brown, Regulatory Compliance
- F. Perryman, Nuclear Oversight Audit Team Lead
- J. Tocco, Engineering Balance of Plant Manager
- W. Padgett, Work Management On-Line Manager
- J. Peterson, Regulatory Programs
- R. Chickering, Corrective Action Process
- D. Shelton, Operations Services Manager
- E. Rodriguez-Ramos, Engineering Balance of Plant Support Nuclear Regulatory Commission
- C. Lipa, Chief, Branch 1, Division of Reactor Projects
- W. Schaup, Senior Resident Inspector, Clinton Power Station
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened/Closed
- 05000461/2013007-01 NCV Failure to Evaluate a Degraded/Non-conforming Condition on Diesel Fire Pump (Section 40A2.1.b.(2))
Attachment
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
- Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
Procedures
- Number Description or Title Revision
- OP-AA-106-101-1006 Operational Decision Making Process 12
- LS-AA-125-1004 Effectiveness Review Manual 5
- LS-AA-125-1001 Root Cause Analysis Manual 10
- LS-AA-125 Corrective Action Program (CAP) Procedure 17 N-CL-OPS-DB-OP-AA-108-115 Document Based Instruction Guide (DBIG) - Operability Determinations 0
- CPS 9070.06 Main Control Room Tracer Gas Test 0b
- OP-AA-108-105 Equipment Deficiency Identification and Documentation 9
- LS-AA-125-1003 Apparent Cause Evaluation Manual 10
- LRT 35f
- CPS 1019.07
- Leakage Reduction and Monitoring Program 5a
- CPS 1019.07D001
- Leakage Reduction Data Sheet 3a
- LS-AA-120 Issue Identification and Screening Process 14
- LS-AA-125-1005 Coding and Analysis Manual 8
- CPS 9071.01 Diesel Driven Fire Pumps Operability Test 40
- CPS 1893.01 Fire Protection Impairment Reporting 20
- CPS 1893.06 Fire Protection Maintenance and Testing Program 12
- Attachment
Condition Reports
- Number Description or Title
- 00824836 1SX025A:
- Valve Body Interior is Degrading
- 00827639 NOS ID Lack of Detail in Issue Report Review
- 00847646 NRC
- NCV 2008004-03:
- Inadequate PM of 1SX014A
- 00906758 Piping Below 85.7% Nominal Wall
- 01019560 1SX010B:
- Found Upper Guide Bearing 180 Degrees Out
- 01115550 1SX169A:
- HX Relief Valve Failure
- 01116033 1SX169A:
- Relief Valves Fail Testing
- 01150345 Perform Thrust Verification Test on MOV 1SX016A
- 01381498 Perform Analysis of Air Compressors
- 01422558 Evaluate Long-Term SX Issues for Procedure Changes
- 01256194 Loss of Power at Valve 1E12F064B
- 01297512 Division 1 EDG Failed to Start due to A3 Speed Pick-up Amphenol Found Disconnected
- 01380555 Apparent Cause Evaluation for Pipe Guide Support 1HP06003G on the High Pressure Core Spray Test Return Line
- 01395861 No Flow Passing Through 1SX024A
- 01444355 Division 1 Diesel Generator MCR Handswitch Failed To Shutdown the
- DG 01164658 Hydrogen Igniters SR 3.6.3.2.4 Op Evaluation
- 01396723 NRC Questions
- EC 387323 for Relief Valve 1E12-F025C
- 01289410 VC Operability Evaluation
- 01196342 0VC114YA Make-up Flow Low
- 01237988 0VC04CB PORC Action Does Not Meet Intent
- 01225739 0VC04CB As-Found Inspection
- Results and ACE (Assignment 2)
- 01395971 1E12F005:
- NRC ID: EC Evaluated Wrong Problem Statement
- 01460158 Ineffective Corrective Actions for
- 01160746 NRC Inspector Questioned ITS Bases For Surveillance
- 01163043 NRC Senior Resident's Questions of H2 Igniter Test
- 01162250 Did Not Directly View 3 DIV 2 Igniters
- 01191200 Potential NRC Finding For H2 Igniter Test Control
- 01409390 1SA029 Found Shut During Walkdown
- 01540518 Turbine Control Valve Oscillations During Power Ascension
- 01495906 1E51F031 - Past Operability Review
- 01509735 NRC
- FIN 2013-002-02, Inadequate Past Operability Evaluation
- 00282084 Discrepancy Between T.S. SR 3.4.6 and
- CPS 9843.01
- Attachment
- 01246826 NRC
- 01305725 Assess 1E12-F042C LLRT Failure for Operability
- 01132555 5 GPM ECCS Leakage Limit Not Tracked
- 01212387 NRC
- GL 2008-01 Lack of Gas Management RHR Discharge Piping Void
- 01219600 0VC04CB Vibration Increased Operability Evaluation
- 00306220 0VC04CB ACE - Cracked Hub
- 00547528 Root Cause Report Mechanical Failure of 0VC03CB
- 01132231 VC Operability Determination
- 01235674 CCA for Operations Crew Performance Gaps
- 01275199 CCA on Operability, Reportability, or Functionality Issues by Operations Licensed Individuals
- 01342208 CCA on Declining Trend in Ventilation System Reliability
- 01390016 CCA on Reactivity Management Performance
- 01490640 CCA on Adherence and Enforcement to Place keeping
- 01335348 ACE:
- CCA Identified Need to Perform
- 01221616 ERO Drill Performance Issues
- 01221661 NRC PI&R: Root Cause
- 979700 Does Not Have EFR as Required
- 01114981 1E22-F035 Small Leak
- 01166610 FASA Gas - New Calculation For Air Pockets Not Prepared
- 01348127 TRNG - Historical Info Found in Simulator
- PPC 01264339 Possible Virus Found On 1F15 Refuel Bridge Computer
- 01406049 Unexpected Entry Into 4005.01 Loss of FW
- HTG 01418618 Request Assistance Developing SPDS Strategy
- 01540522 Operations 4.0 Crew Critique For Downpower
- 01509213 Fuel Conditioning Limit Violation
- 01475884 Root Cause Report Changing Plant Condition Outage Issues
- 01132205 NOS ID:
- 1F12-F075B Operability & ACPS Procedure
- 01132211 NOS ID:
- 1G33F101 Operability / Functionality Not Documented
- 01025236 1G33-F101 Failed To Shut
- 01123852 1VC04001V: VC Piping Floor Support is Deteriorated
- 01325494 EACE:
- VC B Operability Run 9070.01 Flow Unsatisfactory
- 01476647 LER:
- DIV 4 NSPS BUS TRANSFERRED TO RESERVE FEED
- 01326252 NRC Questions Regarding As-Found IST LRT for 1E12-F041A
- 01163088 Old Relief Valve Did Not Pass Bench Test
- 01183403 1DG006B:
- Removed Relief Valve Failed As Found
- 01223745 1DO005B:
- Remove Relief Valve Failed Lift Test
- 01242552 Relief Valve Failure Concerns
- 01247941 Lack of Relief Valve Failure Evaluation Attachment
- 01228580
- IR 01223745:
- RV Failed Lift Test - Additional IST Testing
- 01223723 NRC PI&R:
- Inaccuracies in Reproduced Document
- 01017724 Shaw Employee Contaminated in Drywell
- 01197314 NRC
- GL 2008-01 Inspection Findings at Byron/Braidwood
- 01242250 The ERAT Static VAR Compensator Tripped -
- ECC 01300701 Clearance and Tagging Error Causes the Inappropriate Removal of Shared Tags
- 01305290 Main Turbine Would Not Reset
- 01348186 Transient Combustible Material in Vital Area Storage Areas
- 01376425 APRM 'A' Regulator Monitor Circuit Card Failure
- 01432993 Grade 4 Grease Found on Stem of 1E51F031
- 01428316 Reactor Recirculation Hydraulic Power Unit Filter Inlet Valve Discovered Out-of-Position
- 01187906 NRC Triennial Fire Protection Inspection:
- Division 2 Diesel Generator Fire Door Found Unlatched
- 01211215 NRC
- NCV 2011009-01:
- Failure to Ensure Fire Door Close/Latch
- 01232770 Clinton Power Station Dissatisfied with CAP Performance
- 01226340 Maximum Steady State Voltage for TS 3.8.1 Non-Conservative
- 01224313 TS 3.8.1 Design Basis/Licensing Basis Inconsistency
- 01221661 NRC PI&R:
- Root Cause
- 979700 Does Not Have EFR As Required
- 01223806 NRC PI&R EFRs Not Identified as Required
- 01224057 (NRC Identified) Issue Identified with PMRQ
- 01427242 Missed Reporting of 1VD01YA Damper Failure
- 1214578
- 01262969 Lesson Learned CP Filter 'A' & 'D' Unknowingly in Bypass
- 01307692 0AP16E:
- Adjacent Breaker Bumped During Restoration
- 01318277
- SPC 1289549-02 Rejected by
- MRC 01422357 Equipment Apparent Cause Evaluation Rejected by
- MRC 01336705 Effectiveness Reviews Found Ineffective Corrective Action
- 01282395 NRC:
- Potential Issue with PA Boundary
- 01261166 Effectiveness Review Indicates the CA was Ineffective
- 01529196 ACE for 1CP005B Installation Deficiencies
- 01234386 ECC Failure of 0TICCVC033 Moore 535 Controller
- 01476647 Division 4 NSPS Bus Transferred to Reserve Feed
- 01305725 NRC ID Assess 1E12-F042C LLRT Failure for Operability/Reportability
- 01223512 (NRC Identified) Issue Identified with WO Documentation
- 01299460 1DC01E:
- DC Ammeter Circuit Deficiency - Appendix R Issue
- 01223508 1AP09EH227X1 NRC PI&R Issue - Computation Error in
- IR 919673
- 01550123 PI&R - Challenge to Actions from Root Cause #1307531-06
- 01307531 Action Level 1 Limits Exceeded for Chemistry
- 01215101 Storage of Licensed Operator Respirator Spectacle Kits
- 01335298 NRC Inspection Results in a
- URI 01454976 NRC Review of Extremity Dose Evaluation Attachment
- 01250873 Type A Shipping Container Not Torqued Properly
- 01266430 Work Management Expectations Document Contains Informal Requirements
- 01017724 Shaw Employee Contaminated in Drywell
- 01295617 Reactor Scram During Turbine Trip
- 01297713 Four PCEs from Insulation Removal in the Drywell
- 01289405
- NCV 201104-02, Failure to Implement Package Design Specs
- 01289414
- NCV 201104-06, Missing Respirator Spectacle Kits
- 01289406
- FIN 2011004-03, Failure to Correct Condition Adverse to Quality
- 00093755 Complete Evaluation to Extend 0FP01PA/B 9071.01 to Monthly
- 01228254 0FP01PB Fire Pump 'B' Issues During W/O
- 01348858
- 01237444 B Fire Pump Engine Dip Stick Unseated During Engine Run
- 01408355 EOID - 0FP01PB Oil Leak and Shutdown
- 01408354 Personal Injury
- 01409202 EOID - 0FP01PB Firepump 'B' Dipstick Additional Info
- 01432868 'B' Fire Pump (0FP01PB) Oil Dipstick Not Staying in Engine
- 01435245 Fire Pump B Crankcase Pressure is High Above 30 Inches H2O
- 01512139 EOID 0FP01PB 'B' Diesel Fire Pump Oil Dipstick Ejected
- 01531576 EOID Dipstick Popping Out of Fire Pump 'B' While in Standby
- 01247414 0FP01PB Fire Pump 'B' Oil Dipstick Will Not Stay In
- 01416249 Fire Pump B Oil Dipstick Was Found Not Secured When Pump On
- 01554219 0FP01PA Oil and Coolant Leak From Fire Pump A
- 01557244 Fire Pump 'A' Alternator Drive Belt Broken
- 01557081 Observations From 0FP01PA Cummins Vendor Visit
- 01445750 0FP01PB Diesel Fire Pump Horsepower Discrepancy
- 01455627 EOID:
- 0FP01PB Has a Minor Fuel Oil Leak
- 01487701 0FP01PB:
- Diesel Fire Pump B Engine Speed High Out of Spec
- 01382543 EOID:
- Fire Pump B 0FP01PB Has 20 DPM Oil Leak
- 01421707 EOID:
- 0FP01PB Fire Pump B Oil Leak Rate Doubled
- 01461962 Informal Benchmarking Gap - Actions for Inoperable Fire Pump
- 01409119 NRC Questions Fire Pumps Meeting Single Failure Criterion
- 01552732 0FP01PB:
- EOID Fire Pump 'B' Oil Dipstick Popping Out
- Root Cause Reports
- Number Description or Title
- 01408282 Emergency Reserve Auxiliary Transformer and Emergency Reserve Auxiliary Transformer Static VAR Compensator Tripped
- 01278691 Digital Feedwater Project was Deferred from C1R13
- 01231845 Digital Feedwater Modification SWIL [Software-In-Loop] Test Failure
- 01268638 DFW Simulator SAT [Site Acceptance Test] Milestone Missed 9/23
- Attachment
- 01193900 CPS Personnel Have Inadequate Fire Protection Behaviors
- 01506929 Manual Scram Due to Loss of EHC Fluid
- 01353418 Maintenance and Technical Refresher Training Frequencies Not Fully Met
- 01307531 Chemistry Parameters Exceeded Action Level 1 Limits
- 01247512 CPS Mwe Gross Condenser Vacuum Lower than in Past as a Result of Main Condenser Fouling
- Apparent Cause Evaluations
- Number Description or Title
- 01238704 Potential Non-Safety Oil in a Safety System
- 01258683 DG Air Compressor Relief Valve 1DG005B Lifting Early
- 01276380 Organizational Issues Around Not Stopping DG Air Start Relief Valves From Lifting
- 01281296 PM Deferrals and Retirements Lack Adequate Technical Justification
- 01256194 Loss of Power at Valve 1E12F064B
- 01297512 Division 1 EDG Failed to Start due to A3 Speed Pick-up Amphenol Found Disconnected
- 01380555 Apparent Cause Evaluation for Pipe Guide Support 1HP06003G on the High Pressure Core Spray Test Return Line
- 01395861 No Flow Passing Through 1SX024A
- 01444355 Division 1 Diesel Generator MCR Handswitch Failed To Shutdown the
- DG 01355132 NRC NCV for Unnecessary Preconditioning of 1E12-F-41A During
- LRT 01310612 Unacceptable Preconditioning Identified for 1E51-F040
- 01403682 Received Unexpected Annunciator 5050-5H, Trouble SGTS Elect
- 01301499 NRC Identified Concern on Covered Work
- 01432993 Inadequate MOV Stem Lubrication Practices
- 01475937 Elevated Reactor Coolant Source Term Response - INPO AFI
- RP.1
- 01494203 Employees Unable to Pass Exit Portal Monitors
- 01250873 Type A Shipping Container Not Torqued Properly
- 01255604 Sea-Land Outside RCA with Potential Radioactive Material
- 01309896 Perform ACE for
- IR 1297713 - 4 Insulators PCEs
- 01313140 IR to Track ACE for C1R13 Dose Overage
- 01387718 NOS ID Chemistry Procedure Adequacy is an ARMA
- Attachment
- Common Cause Assessments
- Number Description or Title
- 01111691 Digital I&C Upgraded Components and Equipment Responded in a Manner Not Fully Understood by the Station and Vendor
- 01456116 Security - Perform CCA on Department/Crew Clock Resets
- 01419244 ERO Drill Performance Deficiencies Requires Common Cause
- 01406589 NOS ID:
- Security Personnel Fail to Recognize and Identify Deficiencies
- 01387478 NOS ID:
- Emergency Response Inventories Not Accurate and Complete
- 01332716 CCA on NRC Findings and Violations
- 01329170 C1R13 Security-Related Events
- 01316716 NOS ID:
- 01291740 Security Training - Trend IR on Range Failures
- 01256687 Maintenance CCA on Security Equipment Trends/Issues
- 01434042 Chemistry CCA for Human Performance
- Operating Experience
- Number Description or Title
- NCV 2011003-02; Surveillance Testing Requirement for RCS PIVs OE7945 Degraded Control Room HVAC Declared Inoperable in Redundant Train Outage (Clinton)
- CR 547528 Main Control Room B Fan Catastrophic Failure
- OE 25945 Errors in Operability Evaluation for ESW Cooling Tower Risers (BY)
- OE 17966 Brunswick - Hub Cracks on Buffalo Forge Fan Wheel
- AR 1250696 OPEX Evaluation Timeliness
- AR 1367068 1VD01CA:
- NRC CDBI Findings Compilation June 2011
- Audits, Assessments, and Self-Assessments
- Number Description or Title
- NOSA-CPS-12-05 Engineering Programs and Station Blackout Audit Report
- 01132598 ISI Program Preparedness for C1R13
- NRC 01132711 Check-In (EN) ASME Section XI:
- In-Service Testing
- 01220369 Engineering Work Management
- 01197287 Plan Triennial Permanent Mods/50.59
- 01314264 Level 3 OPEX Evaluations Check-In Self-Assessment
- 01132092 OPEX Program Self-Assessment Check-In
- 01132474 SOER 07-01 Reactivity Management Check-In
- 01132268 Emergency Plan Performance Check-In
- 01132484 Reactor Engineering KT and R Check-In Attachment
- 01132278 Operations Configuration Control Check-In
- 01390203 Operations FP Inappropriate Behaviors Check-In
- 01489640 Readiness Assessment Prior to NRC's Inspection of Procedures and Processes for Responding to Potential Aircraft Threats (TI 2515/186)
- Check-In
- NOSA-CPS-12-03 Emergency Preparedness
- NOSA-CPS-12-06 Training and Staffing
- NOSA-COMP-13-03 Emergency Preparedness Comparative
- NOSA-CPS-12-09 Document Control and Quality Assurance Records Audit
- NOSA-CPS-13-01 Materials Management and Procurements Engineering Audit
- 01132791 Assessment of Calculation Process
- 01133000 Measuring and Test Equipment Program
- 01271545 Radiological Environmental Monitoring Program
- 01302803 3rd Quarter 2012 Chemical Control Check-In
- 01320080 Pre-NRC Underground Piping and Tank Inspections - Phase 1 - Check-In
- 01390203 Fire Protection Inappropriate Behaviors Check-In for
- EFR 01448984 Control Room Habitability FASA
- 01132990 Security FASA Report - Security Drills & Exercises
- 01056011 Security FASA Report
- 01132268
- CHECK-IN Report & Approval (OP) Emergency Plan Performance
- 01131089 Security FASA Report
- 01314257 Check-In Report on Self-Assessment Program
- 01314202 Check-In Report on Overall Health of CAP Program
- 01366663 Safety Culture Survey Check-In Assessment
- NOSA-CPS-12-01 Maintenance Audit Report
- NOSA-CPS-12-02 Security Programs Audit Report
- NOSA-COMP-13-02 Security Programs Comparative Audit Report
- NOSA-COMP-13-04 2013 Corrective Action Program Comparative Audit Report
- NOSA-CPS-13-02 Security Programs Audit Report
- NOSA-CPS-13-03 Emergency Preparedness Audit Report
- NOSA-CPS-13-04 Corrective Action Program Audit Report
- NOSA-CPS-12-04 Chemistry, Radwaste, Effluent, and Environmental Audit Report Attachment
- NOSA-CPS-12-09 Document Control and Quality Assurance Records Audit
Condition Reports
- Generated During the Inspection
- Number Description or Title
- 01550820 Improvement to ODM Closure Documentation
- 01547724
- IR 1408282 RCR Did Not Document EOC for Contributing Causes Correctly
- 01550123 PI&R - Challenge to Actions From Root Cause #1307531-06
- 01550943 PI&R: NRC Inspector Comments From Observed Fire Drill
- 01552494 NRC Identified Potential Violation
- 01555048 PI&R:
- NRC CAP Feedback Opportunities
- 01555051 PI&R:
- NRC OPEX Comment
- 01550099 PI&R:
- Enhancement IR to Drive Fire Door Trend Coding Improvement
- 01549645 EFR for
- RCR 1506929 Pulled Up 13 Months for Performance
- 01551297 NRC PI&R Observation on D Investigation Class
- 01555046 PI&R:
- NRC CCA Comment
- 01555073 PI&R:
- NRC CAP Engagement Ratio Comment
Miscellaneous
- Number Description or Title Date or Revision Work Order
- 01772851 1SX025A:
- Valve Body Interior is Degrading N/A
- EC 384077 0VC114YA Make-up Flow Past Operability 0
- EC 391444 Past Operability of 1E51F031 1 & 2
- EC 384575 0VC04CB High Vibration Levels 0
- EC 387315 Evaluate Past Operability of 1E51-F040 LLRT Failure 0 N/A Safety Culture Monitoring Panel Results for 1Q13 N/A Work Order
- 01498918 Rebuild/Rework RT Filter Demin B Actuator for 1G36-F006B December 19, 2011
- LER 2012-001 Loss of Secondary Containment Differential Pressure Due to Transformer Trip 0
- LER 2011-003 Inadequate Procedure Direction Results in Missed Response Time Testing 0
- LER 2011-009 Missed Surveillance due to Preconditioning Valve prior to Leak Rate Test 0
- Attachment
- Work Order
- 00371390 0FP01PB Fire Pump B Issues During
- WO 1348858June 15, 2011 Work Order
- 00639710-04 OPS/EM PMT Perform Surveillances for 0FP01PB October 14, 2012 Work Order
- 01348858-05 OP PMT Run 0FP01PB Fire Pump June 13, 2011 Work Order
- 01348858-01 MM Perform Maintenance Checks on 0FP01PB June 9, 2011 Work Order
- 01571957-02 Vendor Monitor Fire Pump Performance November 5, 2012
- EC 395009 Fire Pump B Engine With Dipstick Ejected 0
- ECN 15161 Diesel Driven Fire Pumps 0
- ECN 7249 Diesel Driven Fire Pump Contract 0 Work Order
- 01459985-01 0FP01PB Fire Pump 'B' Oil Dipstick Will Not Stay In August 8, 2011 K-2830A Underwriters Laboratory Listed Vertical Fire Pump February 2, 1988
- Attachment
LIST OF ACRONYMS
- USED [[]]
- CA [[]]
PR Corrective Action to Prevent Recurrence
CCA Common Cause Assessment
CFR Code of Federal Regulations
DFP Diesel Fire Pump ECP Employee Concerns Program
EFR Effectiveness Review
IP Inspection Procedure ISI In-service Inspection
LER Licensee Event Report
NCV Non-Cited Violation NRC U.S. Nuclear Regulatory Commission
ODM Operational Decision Making
- PA [[]]
PIV Pressure Isolation Valve PM Preventive Maintenance
psig pounds per square inch gauge
- QA [[]]
SCWE Safety-Conscious Work Environment SDP Significance Determination Process
SOC Station Oversight Committee
SR Surveillance Requirement
- UFS [[]]
AR Updated Final Safety Analysis Report
- NCV , you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission,
DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement,
United States Nuclear Regulatory Commission, Washington,
NRC
Resident Inspector at Clinton Power Station.
If you disagree with the cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region
NRC Resident Inspector at Clinton Power Station.
In accordance with
- NRC 's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the
ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely,
/RA/ Christine Lipa, Chief Branch 1
Division of Reactor Projects
Docket No. 50-461 License No. NPF-62
Enclosure: Inspection Report 05000461/2013007 w/Attachment: Supplemental Information cc w/encl: Distribution via ListServTM