ML11189A129
| ML11189A129 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/08/2011 |
| From: | Ring M NRC/RGN-III/DRP/B1 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-11-008 | |
| Download: ML11189A129 (35) | |
See also: IR 05000461/2011008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
July 8, 2011
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville IL 60555
SUBJECT:
CLINTON POWER STATION NRC PROBLEM IDENTIFICATION AND
RESOLUTION INSPECTION REPORT 05000461/2011008
Dear Mr. Pacilio:
On June 3, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem
Identification and Resolution inspection at your Clinton Power Station. The enclosed report
documents the results of this inspection, which were discussed on June 3, 2011, with
Mr. K. Taber and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
The inspectors concluded that your staff was effective at identifying problems and
incorporating them into the corrective action program (CAP). However, the NRC inspectors
identified degradation in Clinton Power Stations evaluation of issues entered into the CAP.
Operating Experience (OE) was appropriately screened and disseminated. Audits and
self-assessments were determined to be performed at an appropriate level to identify
deficiencies, although there were a few instances where station audits had the opportunity, but
failed to identify issues that were later found by the NRC inspection team. On the basis of
interviews conducted during the inspection, workers at the site expressed freedom to enter
safety concerns into the CAP.
Based on the results of this inspection, three NRC-identified findings of very low safety
significance were identified. One of the findings identified during this inspection was related to
the accuracy of an evaluation performed for an operability determination. The second Green
finding identified during this inspection was related to an inadequate evaluation that led to a
failure to maintain a quality record. The third finding identified during this inspection was related
to a failure to measure the effectiveness of Corrective Actions to Prevent Recurrence (CAPRs)
as required by station procedures. The findings involved violations of NRC requirements.
However, because of their very low safety significance, and because the issues were entered
into your corrective action program, the NRC is treating the issues as non-cited violations
(NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy.
M. Pacilio
-2-
If you contest the subject or severity of these NCVs, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001,
with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III,
2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector
Office at the Clinton Power Station. In addition, if you disagree with the cross-cutting aspect
assigned to any finding 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 the Clinton Power Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response (if any) will be available electronically for public inspection in
the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website
at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Mark A. Ring, Chief
Branch 1
Division of Reactor Projects
Docket No. 50-461
License No. NPF-62
Enclosure:
Inspection Report 05000461/2011008;
w/Attachment: Supplemental Information
cc w/encl:
Distribution via ListServ
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No:
50-561
License No:
Report No:
Licensee:
Exelon Generation Company, LLC
Facility:
Clinton Power Station
Location:
Clinton, IL
Dates:
May 16 through June 3, 2011
Inspectors:
R. Orlikowski, Project Engineer (Team Lead)
A. Dahbur, Senior Reactor Inspector
D. Lords, Resident Inspector, Clinton Power Station
A. Shaikh, Reactor Inspector
S. Mischke, Illinois Emergency Management Agency
Approved by:
Mark A. Ring, Chief
Branch 1
Division of Reactor Projects
Enclosure
TABLE OF CONTENTS
SUMMARY OF FINDINGS ......................................................................................................... 1
REPORT DETAILS .................................................................................................................... 4
4.
OTHER ACTIVITIES .................................................................................................... 4
4OA2
Problem Identification and Resolution (71152B) ................................................. 4
4OA6
Management Meetings ......................................................................................16
SUPPLEMENTAL INFORMATION ............................................................................................. 1
KEY POINTS OF CONTACT .................................................................................................. 1
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED ........................................................ 1
LIST OF DOCUMENTS REVIEWED ...................................................................................... 2
LIST OF ACRONYMS USED .................................................................................................12
1
Enclosure
SUMMARY OF FINDINGS
IR 05000461/2011008, Clinton Power Station; Identification and Resolution of Problems.
This inspection was conducted by three region-based inspectors, the NRC Resident Inspector
at the Clinton Power Station, and the onsite Illinois Emergency Management Agency (IEMA)
inspector. Three Green findings were identified by the inspectors. The findings were
considered non-cited violations (NCVs) 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 NRCs
program for overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
On the basis of the samples selected for review, the team concluded that implementation of the
corrective action program (CAP) at Clinton Power Station was generally effective, although
there has been a degradation in Clintons CAP over the past two years. The licensee had a low
threshold for identifying problems and entering them in the CAP. Items entered into the CAP
were screened and prioritized in a timely manner using established criteria and were generally
implemented in a timely manner commensurate with their safety significance. However, the
inspectors identified degradation in the licensees evaluation of issues entered into the CAP.
Specifically, there were several instances where the corrective actions associated with Action
Requests (ARs) were not adequate or not appropriate for the circumstances. Additionally, the
inspectors identified multiple instances where Effectiveness Reviews (EFRs) were not
performed to assess the effectiveness of Corrective Actions to Prevent Recurrence (CAPRs).
The team noted that the licensee reviewed operating experience for applicability to station
activities. Audits and self-assessments were usually performed at an appropriate level to
identify deficiencies, although there were a few instances where station audits had the
opportunity, but failed to identify issues that were later found by the NRC inspection team.
On the basis of interviews conducted during the inspection, workers at the site expressed
freedom to enter safety concerns into the CAP.
Identification and Resolution of Problems
A.
Cornerstone: Mitigating Systems
NRC-Identified and Self-Revealed Findings
Green
The inspectors determined that this finding was more than minor because it was
associated with the Mitigating Systems Cornerstone attribute of design control and
. The inspectors identified a finding of very low safety significance with an
associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, related to
calculational errors found in the licensees operability determination. Specifically, on four
separate operability determinations, the licensee failed to account for the cable
resistance when determining the maximum allowable contact resistance associated with
the second level undervoltage (UV) relays for the 4.16 kV Buses. The licensee entered
this violation into its CAP as Action Requests (ARs) 1226340 and 1224313 and
performed a preliminary calculation which determined that the error reduced the
available margin in the circuit resistance but did not change the overall conclusions for
the past operability calls made for the four different occasions.
2
Enclosure
adversely affected the cornerstone objective of ensuring availability and reliability of
systems that respond to initiating events to prevent undesirable consequences.
This finding was of very low safety significance (Green) because the licensee was able
to demonstrate that the operability calls that were previously made relating to the second
level UV relays were still valid and acceptable. The inspectors concluded that this
finding affected the cross-cutting aspect of human performance. Specifically, the
licensee failed to use conservative assumptions in decision making related to immediate
operability determinations of conditions adverse to quality. [IMC 0310 H.1(b)
(Section 4OA2.1.b(2)(1))
Green
The inspectors determined the finding was more than minor because, if left
uncorrected, failure to maintain a quality record as evidence of an activity affecting
quality of safety-related equipment due to inappropriate disposition of CAs pertaining
to missing/lost quality records could become a more significant safety concern.
This finding was of very low safety significance because this finding did not represent an
actual loss of any safety function of the Mitigation Systems. The inspectors concluded
that this finding affected the cross-cutting aspect of human performance. Specifically,
the licensee did not ensure complete, accurate and up-to-date design documentation
and work packages. [IMC 0310 P.1(d) (Section 4OA2.1.b(2)(2))
. The inspectors identified a finding of very low safety significance with an
associated NCV of 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance
Records. Specifically, the licensee failed to maintain a quality record documenting a
nondestructive examination (NDE) of a safety-related spreader beam lifting device.
After losing the original NDE report, the licensees corrective action (CA) was to recreate
the report from memory and maintain the recreated report as the quality record.
Upon review and questioning from the NRC, the licensee was able to locate the missing
NDE report in the records archive. This issue was entered into the licensees CAP as
Cornerstone: Initiating Events
Green
The finding was of more than minor significance because it was similar to Example 4a in
IMC 0612, Power Inspection Reports, Appendix E, Examples of Minor Issues, in that,
the licensee routinely failed to perform EFR evaluations on similar CAs related to
significant conditions adverse to quality. The finding was a licensee performance
deficiency of very low safety significance due to answering no to all questions under the
Initiating Events Cornerstone column of IMC 0609 Attachment 4, Phase 1 - Initial
Screening and Characterization of Findings. The inspectors concluded that this finding
affected the cross-cutting aspect of problem identification and resolution. Specifically,
the licensee failed to thoroughly evaluate problems to include conducting EFRs of CAs
to ensure that problems were resolved. [IMC 0310 P.1(c) (Section 4OA2.1.b(3)(1))
. The inspectors identified a finding of very low safety significance with an
associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings. The licensee failed to perform an effectiveness review (EFR) to ensure that
CAs taken to prevent recurrence of a significant condition adverse to quality were
actually effective to preclude repetition. The licensee entered this violation into its CAP
as ARs 1221616, 1221661, and 1223806 to investigate the cause and to identify
appropriate CAs.
3
Enclosure
B.
No violations of significance were identified.
Licensee-Identified Violations
4
Enclosure
4.
OTHER ACTIVITIES
REPORT DETAILS
4OA2 Problem Identification and Resolution
The activities documented in sections .1 through .4 constituted one biennial sample of
problem identification and resolution as defined in Inspection Procdure (IP) 71152.
(71152B)
.1
a.
Assessment of the Corrective Action Program Effectiveness
The inspectors reviewed the licensees CAP implementing procedures and attended
CAP meetings to assess the implementation of the CAP by site personnel.
Inspection Scope
The inspectors reviewed risk and safety-significant issues in the licensees CAP since
the last NRC Problem Identification and Resolution (PI&R) inspection in April 2009.
The selection of issues ensured an adequate review across NRC cornerstones.
The inspectors used issues identified through NRC generic communications, department
self-assessments, licensee audits, operating experience (OE) reports, and NRC
documented findings as sources to select issues. Additionally, the inspectors reviewed
issue reports generated as a result of facility personnels performance in daily plant
activities. In addition, the inspectors reviewed ARs and a selection of completed
investigations from the licensees various investigation methods, which included root
cause, apparent cause, equipment apparent cause, common cause, and quick human
performance investigations.
The inspectors selected one high risk system, the Emergency Diesel Generator System,
to review in detail. The inspectors review was to determine whether the licensee staff
were properly monitoring and evaluating the performance of this system through
effective implementation of station monitoring programs. This five year review on the
Emergency Diesel Generator System was undertaken to assess the licensee staffs
efforts in monitoring for system degradation due to aging aspects.
During the reviews, the inspectors determined whether the licensee staffs actions were
in compliance with the facilitys CAP and 10 CFR Part 50, Appendix B requirements.
Specifically, the inspectors determined if licensee personnel were identifying plant issues
at the proper threshold, entering the plant issues into the stations CAP in a timely
manner, and assigning the appropriate prioritization for resolution of the issues.
The inspectors also determined whether the licensee staff assigned the appropriate
investigation method to ensure the proper determination of root, apparent, and
contributing causes. The inspectors also evaluated the timeliness and effectiveness of
CAs for selected issue reports, completed investigations, and NRC findings, including
NCVs.
b.
(1)
Assessment
Issues were generally being identified at a low threshold, evaluated appropriately, and
corrected in the CAP. Workers were familiar with the CAP and felt comfortable raising
Effectiveness of Problem Identification
5
Enclosure
concerns. This was evident by the large number of CAP items generated annually;
which were reasonably distributed across the various departments. A shared,
computerized database was used for creating individual reports and for subsequent
management of the processes of issue evaluation and response. These processes
included determining the issues significance, addressing such matters as regulatory
compliance and reporting, and assigning any actions deemed necessary or appropriate.
The inspectors determined that the station 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 CAs were ineffective or were inappropriately closed.
As a result of an observation from the 2009 PI&R Inspection that found deficiencies in
security officers' knowledge on initiating Issue Requests, the inspectors specifically
asked security officers if they had received some form of training or instruction on
entering issues into the licensees computer-based CAP. All security officers
interviewed responded that training/instruction had been provided. Additionally, the
officers stated that there was a laminated instruction card available at each computer
workstation with step-by-step instructions on how to initiate issue reports.
The inspectors noted that since the 2009 PI&R Inspection, the Security organization had
generated approximately 2,100 Issue/Action Reports. From these 2,100 issues,
11 trend IRs were initiated. By comparison, the Training organization generated
approximately 750 IRs and 13 trend IRs during the same period. The Training
Department is about one fourth the size of the Security Department. Although the
Security Department meets the requirements for quarterly trending (LS-AA-125-1005),
the inspector felt that, based on numbers alone, the Security organization should be
identifying/initiating more trend IRs. It may be prudent for all departments to examine
their trending program to ensure trends or potential trends are being identified.
Observation
During review of work order (WO) 01277109 Task ID 1, Replace Grounded B RR
[Reactor Recirculation] Pump Motor, referenced from action AR 00988866, RR B
Motor Change Out Spreader Beam NDE INSP Report Missing, the inspectors identified
that contrary to WO 01277109 guidance, the licensee had inappropriately marked N/A
[Not Applicable] on step 4.2 of Task ID 1 and step 4.3 of Task ID 14 in WO 01277109.
These procedure steps required inspection and supervisory oversight of rigging devices
and should not have been marked 'N/A'. However, an earlier procedure step had
accomplished the same function.
Failure to Follow Work Order Instructions
The inspectors determined that the licensees failure to follow instructions in Step 4.2 of
Task ID 1 and Step 4.3 of Task ID 14 in WO 01277109 is a violation of Title 10 CFR 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, which requires, in
part, that activities affecting quality be performed in accordance with instructions,
procedures, and drawings appropriate to the circumstance. Instructions, procedures or
drawings shall include appropriate quantitative or qualitative acceptance criteria for
determining that important activities have been satisfactorily accomplished.
The licensee subsequently addressed this issue of failure to follow WO instructions in
the CAP as AR 1223512, (NRC Identified) Issue Identified with WO Documentation.
6
Enclosure
This failure to comply with the requirements of Title 10 CFR 50, Appendix B, Criterion V,
Instructions, Procedures, and Drawings, constitutes a violation of minor significance
that is not subject to enforcement action in accordance with the NRCs Enforcement
Policy.
No findings were identified.
Findings
(2)
The inspectors concluded that the station was generally effective at prioritizing issues
commensurate with their safety significance. The inspectors observed that the majority
of issues identified were of low-level and were either closed to trend, closed to actions
taken, or characterized at a level appropriate for a condition evaluation. Issues were
being appropriately screened by both the Station Oversight Committee (SOC) and
Management Review Committee (MRC). There were no items in the operations,
engineering, or maintenance backlogs that were risk-significant, individually or
collectively.
Effectiveness of Prioritization and Evaluation of Issues
The inspectors concluded that the stations evaluation of issues was not always
thorough and there had been degradation in this area of Clinton Power Stations CAP.
Specifically, there were several instances where the CAs associated with ARs were not
adequate or not appropriate for the circumstances. This was evidenced by two minor
violations and two findings identified during this inspection.
Observations
During review of AR No. 0092284, NDE Inspection for Strongback Is Not Identified,
the inspectors identified that the licensees CA to resolve this AR was to revise Exelon
procedure MA-AA-716-021, Periodic Inspection of Rigging Equipment. The inspectors
verified that procedure MA-AA-716-021(revision 2) was indeed revised to identify the
special lifting device inspection requirements of ANSI N14.6-1978, American National
Standard for Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds
(4500 kg) or More for Nuclear Materials. However, subsequent to this revision, the
licensee made another revision to procedure MA-AA-716-021 (revision 3), which
essentially removed ANSI N14.6-1978 requirements for periodic inspection of special
lifting devices from the procedure. The licensee maintained that upon evaluation at the
time of revising MA-AA-716-021, Rev. 2, the licensee determined that the special lifting
device periodic inspection requirements as described in ANSI N-14.6-1978 would be
more appropriately captured in equipment specific documents such as Preventative
Maintenance Requests (PMRQs) and vendor specific work orders. Upon review of
these special lifting device (equipment specific) documents, the inspectors identified that
the licensee had not adequately included the ANSI N14.6 requirements into these
documents. Specifically, the inspection requirements and periodicity of inspection of
special lifting devices was not adequately addressed in these equipment specific
documents.
Failure to Adequately Maintain Regulatory Requirements in Design Basis Procedures
and Instructions
7
Enclosure
The inspectors determined that the licensees failure to have adequate
procedures/documents for inspection of special lifting devices per
ANSI Code N14.6-1978 is a violation of Title 10 CFR 50, Appendix B, Criterion III,
Design Control, which requires, in part, that measures shall be established to assure
that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2
and as specified in the license application, for those structures, systems, and
components to which this appendix applies are correctly translated into specifications,
drawings, procedures, and instructions.
The licensee generated AR 1224057, Submit Service Requests to revise PMRQs
156877 & 156886 to be Consistent with the Requirements from ANSI N14.6.
Document Service Request Approval and PMRQ Changes Results as Closure, and
Create Additional Actions as Required, to revise the equipment specific documents,
such that they adequately capture the appropriate ANSI N14.6 requirements for periodic
inspection of special lifting devices.
This failure to comply with the requirements of Title 10 CFR 50, Appendix B, Criterion III,
Design Control, constitutes a violation of minor significance that is not subject to
enforcement action in accordance with the NRCs Enforcement Policy.
The inspectors identified a minor violation of 10 CFR Part 50, Appendix B, Criterion III,
Design Control, for the licensees failure to demonstrate by calculation that the
Technical Specifications (TS) upper voltage limits for the emergency diesel generator
(EDG) surveillance tests were adequate to support operability of all safety-related loads.
Specifically, the licensee failed to provide adequate evaluation for AR 670088670088Non-
Conservative TS for 4.16 kV Vital Bus Voltage, initiated in 2007 during a Component
Design Basis Inspection (CDBI) self-assessment. The self-assessment raised a concern
regarding the upper limit for the 4.16 kV safety-related bus voltage of 4580 volts as
being non-conservative. The maximum analytical limit in the design calculation was
4454 volts due to potential overvoltage on the 120 volt components. The AR evaluation
concluded that the current administrative limit of 4300 volts in the surveillance
procedures was adequate to limit the safety-related bus voltages to ensure their safety
function. However, the inspectors determined that the licensees evaluation failed to
correctly address the concern regarding the non-conservative TS voltage limits.
The current design basis analysis did not support the TS upper voltage limit (4580 volts)
for the safety-related buses. The licensee entered this issue into their CAP as
AR 1226340, Maximum Steady State Voltage for TS 3.8.1 Nonconservative.
Failure to Demonstrate by Calculation Operability of Safety-Related Loads When
Powered from the EDGs
This failure to comply with 10 CFR Part 50, Appendix B, Criterion III, Design Control,
constitutes a violation of minor significance that is not subject to enforcement action in
accordance with the NRC=s Enforcement Policy.
(1)
Findings
Introduction: The inspectors identified a finding of very low safety significance (Green)
with an associated NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the
licensee's failure to account for the cable resistance in immediate operability
Failure to Account for Cable Resistance in Operability Determinations
8
Enclosure
determinations. Specifically, on four different occasions, the licensee failed to account
for the cable resistance when determining the maximum allowable circuit resistance to
ensure that adequate minimum voltage was available for the trip coils associated with
the 4.16 KV buses.
Description: On the following four different occasions, during the performance of
CPS 9333.20 and CPS 9333.30, "4.16 kV Degraded Voltage Trip Functional Test,"
for Division I and Division II respectively, contact resistance for the undervoltage (UV)
relays was found unacceptable. UV relays 227X1-21A1-2 and 227X1-21B1-2 were
found to have higher than expected resistance readings across the closed contacts used
to trip the Reserve Auxiliary Transformer (RAT) Feed Breaker upon initiation of a
degraded voltage signal. Typically, closed contact readings should read significantly
less than 1 ohm.
During the performance of CPS 9333.30 on May 14, 2009, contacts
between 4 and 5 on relay 227X1-21B1-2 read approximately 3.6 ohms.
Immediate operability determined that the trip coil was operable and would
perform its function. This issue was documented in AR 919673919673
During the performance of CPS 9333.30 on July 15, 2009, contact between
4 and 5 on relay 227X1-21B1-2 again showed higher contact readings; anywhere
from 14 to 48 ohms. Immediate operability determined that the trip coil was
inoperable and subsequently, the associated emergency diesel generator was
also declared inoperable. This issue was documented in AR 947824947824
During the performance of 9333.20 on July 30, 2009, contact between 11 and 20
on relay 227X1-21A1-2 read approximately 2.43 ohms. Immediate operability
determined that the trip coil was operable. This issue was documented in
AR 947581947581
During the performance of CPS 9333.30 on December 17, 2009, contacts
between 4 and 5 on relay 227X1-21B1-2 again showed higher contact resistance
readings of 19.4 ohms across the contacts. Immediate operability determined
that the trip coil was inoperable. This issue was documented in AR 1006888.
The operability determination in all four occasions listed above was based on a
simplified calculation showing that as long as the resistance between the contacts was
less than 13.1 ohms, then adequate voltage of greater than 70 Vdc would be available
for the trip coil to perform its function in a worst case scenario. The inspectors noticed
that this acceptance criterion for the maximum contact resistance was not listed in the
surveillance procedure CPS 9333.20 or CPS 9333.30. The inspectors also noticed that
the equation used in the simplified calculation that determined the maximum acceptable
resistance between the contacts did not account for the cable resistance for the control
cables associated with the trip coil control circuitry. Subsequent to the inspector
identification of this deficiency, the licensee identified the length of the cables associated
with these affected circuits as a total of 860 feet and 1114 feet for Division I and II
respectively. The licensee recalculated the maximum acceptable resistance value using
the cable length/resistance and determined that the original calculated value of 13.1
ohms was reduced by 2.07 ohms and 2.7 ohms for Division I and II respectively.
9
Enclosure
The inspectors determined that the new calculated values for the maximum resistance
between the contact would not have changed the past operability determinations for the
above four occasions. In addition, the licensees two Equipment Apparent Cause
Evaluations (EACEs), which were performed for AR 947581947581and AR 1006888, also
determined that the apparent cause of the high contact resistance readings was due to
the improper measuring technique and not actual degraded relay contact.
Analysis: The inspectors determined that the failure to account for the cable resistance
in four different operability determinations was a performance deficiency warranting a
significance evaluation. The performance deficiency was determined to be more than
minor because the finding was associated with the Mitigating Systems Cornerstone
attribute of design control and adversely affected the cornerstone objective of ensuring
the availability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, on two of the four immediate operability determinations, the
licensee failed to ensure that adequate voltage would be available for the trip coils when
the contact resistance for the second level under-voltage relays was reading higher than
expected. The inspectors performed a Phase 1 SDP review of this finding using the
guidance provided in IMC 0609, Attachment 0609.04, Phase 1 - Initial Screening and
Characterization of Findings. In accordance with Table 4a, Characterization
Worksheet for IE, MS, and BI Cornerstones, the inspectors determined that this finding
was a design deficiency confirmed not to result in loss of operability or functionality.
Specifically, the licensee was able to demonstrate that the operability calls that were
previously made, when the operability of the second level under-voltage relays was in
question, were still acceptable when the cable resistance was added.
The inspectors concluded that this finding affected the cross-cutting aspect of human
performance, Decision Making. Specifically, the licensee failed to use conservative
assumptions in decision making affecting the operability of the second level under-
voltage relays when conditions adverse to quality were identified. (IMC 0310 H.1(b)).
Cross-Cutting Aspects
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires,
in part, that measures shall be established to assure that applicable regulatory
requirements and the design basis are correctly translated into specifications, drawings,
procedures, and instructions.
Contrary to the above, in 2009, on four different occasions, the licensee failed to ensure
that applicable regulatory requirements and design basis related to second level UV
relay circuits were correctly translated into calculations used in immediate operability
determinations. Specifically, the licensee failed to ensure that the cable resistance was
accounted for when determining the maximum allowable circuit resistance to ensure that
adequate minimum voltage was available for trip coils associated with the 4.16 kV
buses. Because this violation was of very low safety significance and it was entered
into the licensees CAP as AR 01223508, this violation is being treated as an NCV,
consistent with Section 2.3.2 of the NRC Enforcement Policy.
(NCV 05000461/2011008-01, Failure to Account for Cable Resistance in Operability
Determinations). The licensee entered this into their CAP as ARs 1226340 and
1224313.
10
Enclosure
(2) Failure to Maintain a Quality Record as Evidence of an Activity Affecting Quality of
Safety-Related Equipment Due to Inappropriate Corrective Actions
The inspectors identified a finding of very low safety significance and a NCV of
10 CFR 50, Appendix B, Criterion XVII, Quality Assurance Records, for the licensees
failure to maintain sufficient quality records that provide evidence of activities affecting
quality of safety-related equipment.
Introduction
During review of AR 00988866, RR B Motor Change out Spreader Beam NDE INSP
Report Missing, the inspectors identified that the licensee did not have in their
completed work order documents the NDE report that is required to qualify the spreader
beam used to lift the reactor recirculation motor during the change out process in the
drywell. The NDE of the critical welds of the spreader beam, which is considered a
special lifting device, is required by ANSI N14.6-1978, American National Standard for
Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or
More for Nuclear Materials, prior to each use.
Description
AR 00988866 dated November 4, 2009, states that the NDE was performed on the
spreader beam prior to use in lifting the reactor recirculation B motor, however no
record of the NDE existed in the completed work order documents. The licensee
proposed three recommended actions in AR 00988866 as resolution of this CR:
1) Personnel who were involved should search their working areas to locate the missing
NDE inspection report, 2) Duplicate report may be generated based on recollection of
the inspection, 3) Perform NDE inspection for the used spreader beam again and
document the results per this AR (if #1 and #2 are not feasible). On November 23,
2009, the missing NDE report was recreated based on recollection from memory of the
individual who conducted the examination and approved by licensee corporate NDE.
Upon review and further questioning from the inspectors, the licensee attempted to find
the missing original NDE report. After extensive searching, the licensee did find the
missing original NDE report dated October 18, 2009, which differed in certain
parameters from the recreated NDE report dated November 23, 2009.
The inspectors determined that the licensees failure to maintain a quality record
documenting an NDE on safety-related equipment due to inappropriate CAs is a
performance deficiency that impacted the Mitigation Systems Cornerstone.
Analysis
The inspectors determined that this performance deficiency was more than minor
because, if left uncorrected, failure to maintain a quality record as evidence of an activity
affecting quality of safety-related equipment due to inappropriate disposition of CAs
pertaining to missing/lost quality records, could become a more significant safety
concern. Absent NRC identification, the licensee would deem it acceptable practice to
recreate from memory, quality records of activities that affect quality of safety-related
equipment in lieu of more appropriate CAs available to the licensee.
The inspectors completed a significance determination, in accordance with IMC 0609,
Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening
11
Enclosure
and Characterization of Findings, Table 4a for the Mitigation Systems Cornerstone.
Based on answering 'no' to each of the Phase 1 screening questions identified in the
Mitigation Systems Cornerstone column of Table 4a, the finding was determined to be of
very low safety significance. Specifically, this finding did not represent an actual loss of
any safety function of the Mitigation Systems.
This finding has a cross-cutting aspect in the area of Human Performance, Resources
because the licensee did not ensure complete, accurate and up-to-date design
documentation, procedures, and work packages, and correct labeling of components.
Cross-Cutting Aspects
Title 10 CFR 50, Appendix B, Criterion XVII, Quality Assurance Records, requires, in
part, that sufficient records shall be maintained to furnish evidence of activities affecting
quality. The records shall include at least the following: Operating logs and the results
of reviews, inspections, tests, audits, monitoring of work performance, and materials
analyses. The records shall also include closely-related data such as qualifications of
personnel, procedures, and equipment. Inspection and test records shall, as a
minimum, identify the inspector or data recorder, the type of observation, the results, the
acceptability, and the action taken in connection with any deficiencies noted. Records
shall be identifiable and retrievable. Consistent with applicable regulatory requirements,
the applicant shall establish requirements concerning record retention, such as duration,
location, and assigned responsibility.
Enforcement
Contrary to the above requirements, on November 23, 2009, during resolution of
AR 00988866, RR B Motor Change out Spreader Beam NDE INSP Report Missing,
the licensee approved a decision to recreate from recollection of memory the missing
NDE report and, therefore, failed to maintain a sufficient quality record providing
evidence of the NDE. Failure to maintain a sufficient record that provides evidence of
the NDE affecting quality of the safety-related spreader beam was a violation of
10 CFR 50, Appendix B, Criterion XVII. Because this violation was of very low safety
significance and was entered into the CAP, this violation is being treated as an NCV
consistent with Section VI.A.1 of the NRC Enforcement Policy.
(NCV 05000461/2011008-02 Failure to Maintain Quality Record as Evidence of
Activity Affecting Quality of Safety-Related Equipment). The licensee entered this
issue into the CAP as AR 1223723.
(3)
The effectiveness of corrective actions for the items reviewed by the inspectors was
generally appropriate for the identified issues. Over the two year period encompassed
by the inspection, the inspectors identified no significant examples where problems
recurred. The inspectors did identify one weakness associated with the stations use of
EFRs to evaluate Corrective Actions to Prevent Recurrence (CAPR). While reviewing
Root Cause Evaluations performed since the last biennial PI&R inspection in 2009, the
inspectors identified six examples where Clinton Power Station failed to perform EFRs
as required by the station's CAP procedures.
Effectiveness of Corrective Actions
12
Enclosure
(1)
Findings
Failure to Perform Effectiveness Review
Inspectors identified a finding of very low safety significance with an associated NCV of
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings.
The licensee failed to perform an EFR to ensure that CAs taken to prevent recurrence of
a significant condition adverse to quality were actually effective to preclude repetition.
Introduction
Inspectors performed a review of the licensees CAP with a focus, in particular, on how
significant conditions adverse to quality are addressed. Exelon procedure LS-AA-120,
Issue Identification and Screening Process, defines a significant condition adverse to
quality to include severe operating abnormalities or large deviations from expected plant
performance of safety-related structures, systems, or components; [and] events such
as described in the plant Technical Specifications. 10 CFR 50 Appendix B Criteria XVI
requires, in part, that In the case of significant conditions adverse to quality the
measures shall ensure that the cause of the condition is determined and CA taken to
preclude repetition. LS-AA-125, Revision 15, Corrective Action Program Procedure,
Step 1.3 states that significant conditions adverse to quality and conditions adverse to
quality are resolved through direct action, the implementation of CAPRs and Corrective
Actions (CAs).
Discussion
Inspectors then focused their review upon how the licensee identifies CAPRs to resolve
significant conditions adverse to quality. The licensees method to accomplish this was
through its highest level of investigation, a Root Cause Analysis. During a general
review of the licensees Root Cause Reports completed within the previous two years,
inspectors identified six examples where the licensee failed to follow its processes for
correcting significant conditions adverse to quality.
On October 23, 2009, the licensee completed Root Cause Report (RCR) 972235,
Valve Packing Failure inside Drywell Resulted in Plant Shutdown Due to Increasing
Unidentified Leakage Rate. The conclusion of the licensees report was that there were
two root causes for the plant shutdown event: 1) That the 1E51F063 valve stem was off
center with the stuffing box with the potential to cause packing side loading and
accelerated loss of packing load, and 2) Inadequate work instruction did not require the
packing in 1E51F063 to be torqued to the as-left value from the original installation.
The investigation also identified two CAPRs, one to address each root cause identified.
Licensee procedure LS-AA-125-1001, Root Cause Analysis Manual, Revision 8,
Attachment 12 identifies the attributes of a CAPR; specifically, CAPRs are intended to
address the root cause(s) in a manner to prevent recurrence, therefore, CAPRs should
have the following attributes: specific, measurable, accountable, reasonable, timely,
effective, reviewable, actionable, linked to a root cause, [etc]. RCR 972235 was
approved by the licensee with the EFR portion blank, other than the statement that
An Effectiveness Review to address the effectiveness of the Root Cause CA is not
necessary. The root cause is limited to a single valve, 1E51F063, with an off center
stem to stuffing box condition. The work order to investigate and correct the condition is
sufficient assurance the condition is corrected and will no longer cause accelerated loss
of packing load. This statement addresses only one of the two identified root causes
13
Enclosure
and also appears contrary to the licensees procedural guidance that a CAPR should be
measurable and reviewable. After questions from inspectors, the licensee determined
that its MRC had approved this RCR with comments to be incorporated, one of which
was to add EFRs for the CAPRs. This action was later closed without initiating any EFR.
Further review by inspectors identified five additional examples where the licensee failed
to follow their procedures with respect to CAPRs and EFRs.
1. RCR 979700, 1B33C001B: RR B Trip - Resulting in Reactor Scram, identified a
Special Plant Condition as a CAPR which included the instruction to generate
additional actions as needed and include the identified Root Cause, Extent of
Condition/Cause, CAPRs, and EFR. No EFR was ever created.
2. RCR 1017724, Contract Employee Contaminated in Drywell, identified one root
cause, one CAPR, and did include one EFR. However, this EFR was performed
to address a separate CA and not the CAPR which was identified.
3. RCR 1023530, Gate Seal Leakage during Containment Isolation Valve System
Functional Test, identified two root causes and two CAPRs. An EFR was
assigned to the first CAPR and none was assigned to the second. However, on
April 19, 2011, AR 1204691 was written by the licensees Nuclear Oversight
(NOS) organization which identified this omission of a required EFR. In this AR,
NOS stated that failing to create and document individual EFRs could result in
not identifying whether a single CAPR effectively resolved an identified cause.
At the time of inspection the RCR was provided in final form to inspectors with no
correction made for this identification from NOS.
4. RCR 1147568, Re-Evaluation Exam Provided Did Not Meet Expectations,
identified one root cause and two CAPRs. The licensee assigned two EFRs to
one of the CAPRs, however the EFR was marked N/A for the other CAPR
which was identified.
5. RCR 1157980, WANO Identified Area for Improvement for Relays and Power
Supplies, identified two root causes, one CAPR and assigned two EFRs to be
completed. However, these two EFRs were assigned to CAs and not the
identified CAPR. Notably, in the EFR section of this report a preface was added
which stated There is no specific EFR action for the CAPR, and no specific
effectiveness criteria can be developed. Therefore no specific EFR action is to
be completed. This was reviewed with and approved by MRC.
The inspectors determined that the licensees failure to perform EFRs which verify that
CAs taken for significant conditions adverse to quality successfully prevent their
reoccurrence was a performance deficiency warranting a significance evaluation.
The finding was of more than minor significance because it was similar to Example 4a in
IMC 0612, Power Inspection Reports, Appendix E, Examples of Minor Issues, in that
the licensee routinely failed to perform EFR evaluations of CAs taken to prevent
recurrence of significant conditions adverse to quality. The inspectors performed a
Phase 1 SDP review of this finding using the guidance provided in IMC 0609,
Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings.
Analysis
14
Enclosure
In accordance with Table 4a, Characterization Worksheet for IE [Initiating Events],
MS [Mitigating Systems], and BI [Barrier Integrity] Cornerstones, the inspectors
determined that this finding was a licensee performance deficiency of very low safety
significance (Green) due to answering no to all questions under the Initiating Events
Cornerstone column.
Inspectors concluded that this finding affected the cross-cutting aspect of problem
identification and resolution. Specifically, the licensees CAP did not thoroughly evaluate
problems to include, for significant problems, conducting EFRs of CAs to ensure that
problems are resolved. (IMC 0310 P.1(c))
Cross-Cutting Aspects
10 CFR 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, requires,
in part, that activities affecting quality shall be prescribed by documented instructions,
procedures, or drawings, of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, or drawings. Licensee
procedure LS-AA-125, Corrective Action Program Procedure, Step 1.3 states that
significant conditions adverse to quality and conditions adverse to quality are resolved
through direct action, the implementation of Corrective Actions to Prevent Recurrence
and Corrective Actions. Step 4.4.8 of this procedure states Perform Effectiveness
Reviews in accordance with LS-AA-125-1004, Effectiveness Review Manual.
Revisions 4 and 5 of LS-AA-125-1004, Effectiveness Review Manual, in effect during
this time period of review, contain requirements that all CAPRs are to be evaluated in
the EFR and to Initiate Attachment 1, Individual Effectiveness Review for each of the
CAPRs identified.
Enforcement
Contrary to the above, on the six separate occasions previously described, the licensee
failed to perform EFRs in accordance with its procedures to verify that CAs taken for
significant conditions adverse to quality successfully prevented their reoccurrence.
Because of the very low safety significance, this violation is being treated as an NCV
consistent with Section 2.3.2 of the NRC Enforcement Policy
(NCV 05000461/2011008-03, Failure to Perform Effectiveness Review). The licensee
entered this violation into its CAP as ARs 01221616, 01221661, and 01223806.
.2
a.
Assessment of the Use of Operating Experience (OE)
The inspectors reviewed the licensees implementation of the facilitys OE program.
Specifically, the inspectors reviewed implementing operating experience program
procedures, attended CAP meetings to observe the use of OE information, and
completed evaluations of OE issues and events. The inspectors review was to
determine whether 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 licensees 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 CAs, as a result of OE experience, were
identified and implemented in an effective and timely manner.
Inspection Scope
15
Enclosure
b.
In general, OE was effectively used 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.
Assessment
No findings were identified.
Findings
.3
a.
Assessment of Self-Assessments and Audits
The inspectors assessed the licensee staffs ability to identify and enter issues into the
CA program, prioritize and evaluate issues, and implement effective CAs, through efforts
from departmental assessments and audits.
Inspection Scope
b.
The inspectors concluded that self-assessments, NOS audits, and other assessments
were typically effective at identifying most issues. The inspectors concluded that these
audits and self-assessments were generally completed in a methodical manner by
personnel knowledgeable in the subject area. Corrective Actions associated with the
identified issues were implemented commensurate with their safety significance.
Assessment
There were a few issues identified by the inspectors that were not identified during
station self-assessments and/or audits. NOS previously identified one of the RCEs that
did not include EFRs for the CAPRs. However, NOS did not identify the other five
instances where EFRs were not included to review CAPRs. Additionally, as preparation
for this inspection, an assessment team comprised of Clinton employees along with one
Quad Cities and one Robinson Nuclear Plant employee performed a focused self
assessment (FASA) on Clintons CAP. The FASA identified no strengths,
19 recommendations, and 21 standards deficiencies. However, the FASA did not
identify any of the issues and weaknesses that were identified by the NRC inspection
team. Additionally, the FASA did not identify the decline in performance of Clintons
CAP that was identified by the NRC inspection team.
No findings were identified.
Findings
.4
a.
Assessment of Safety-Conscious Work Environment
The inspectors assessed the licensees safety-conscious work environment (SCWE)
through reviews of the facilitys employee concerns program (ECP) implementing
procedures, discussions with ECP coordinators, interviews with personnel from various
Inspection Scope
16
Enclosure
departments, and reviews of issue reports. The inspectors also reviewed the results of
licensee safety culture surveys.
b.
The inspectors determined that the plant staff were aware of the importance of having a
strong SCWE and expressed a willingness to raise safety issues. No one interviewed
had experienced retaliation for safety issues raised or knew of anyone who had failed to
raise issues. All persons interviewed had an adequate knowledge of the CAP process.
These results were similar with the findings of the licensees safety culture surveys.
Based on these limited interviews, the inspectors concluded that there was no evidence
of an unacceptable SCWE.
Assessment
The inspectors determined that the ECP process was being effectively implemented.
The inspectors noted that the licensee had appropriately investigated and taken
constructive actions to address potential cases of harassment and intimidation for raising
issues.
No findings were identified.
Findings
4OA6
.1
Management Meetings
On June 3, 2011, the inspectors presented the inspection results to Mr. B. K. 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.
Exit Meeting Summary
ATTACHMENT: SUPPLEMENTAL INFORMATION
1
Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
W. Knoll, Site Vice President
Licensee
B. K. Taber, Plant Manager
A. Khanifar, Site Engineering Director
S. A. Gackstetter, Training Director
S. J. Fatora, Maintenance Director
R. E. Zacholski, Nuclear Oversight Manager (Acting)
B. W. Davis, Regulatory Assurance Manager
R. S. Frantz, Regulatory Assurance
K. Brown, Regulatory Assurance
J. M. Stovall, Radiation Protection Manager
T. P. Veitch, Chemistry Manager
J. E. Cunningham, Security Manager
T. R. Stoner, Outage Manager
R. A. Schenck, Manager Site Project Manager
D. J. Kemper, Sr. Manager Plant Engineering
C. D. Dunn, Shift Operations Superintendant
Nuclear Regulatory Commission
Mark A. Ring, Chief, Branch 1, Division of Reactor Projects
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened and Closed 05000461/2011008-01
Failure to Account for Cable Resistance in Operability
Determinations (4OA2.1.b(2)(1)05000461/2011008-02
Failure to Maintain a Quality Record As Evidence of an
Activity Affecting Quality of Safety-related Equipment Due to
Inappropriate Corrective Actions (4OA2.1.b(2)(2)05000461/2011008-03
Failure to Perform Effectiveness Review (4OA2.1.b(3)(1)
Discussed
None.
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.
PLANT PROCEDURES
Number
Description or Title
CPS 9333.20
Date or Revision
Division I 4.16 kV Bus Undervoltage Relay
(Degraded Voltage) Functional Test
December 9, 2009
CPS 9333.30
Division II 4.16 kV Degraded Voltage Trip -
Functional Test
December 9, 2009
PMRQ 159638-05
Perform Voltage Measurement at 1PL12JB
PMRQ 158714-08
Perform Voltage Measurement at 1PL12JA
HPP-1342-10
Procedure for Onsite Handling and Installation of
Cask Pit Racks for the Clinton Nuclear Plant
Revision 1
Control of Heavy Loads Program
Revision 8
MA-CL-716-022-
1001
Handling of Heavy Loads
Revision 0F
Predefine Process
Revision 3
EC 376454 R/0
Design Considerations Summary
American National Standard for Special Lifting
Devices for Shipping Containers Weighing 10,000
Pounds (4500 kg) or More for Nuclear Materials
February 15, 1978
Exelon Procedure; Rigging and Lifting Program
Revision 17
CPS 8106.03
Crane Inspection, Maintenance, and Testing
(Including Special Lifts)
Revision 22e
MA-CL-716-021-
1001
Periodic Inspection of Rigging Equipment
Revision 2
MA-CL-716-021-
1001
Periodic Inspection of Rigging Equipment
Revision 3
Issue Identification and Screening Process
Corrective Action Program Procedure
Revision 15
Root Cause Analysis Manual
Apparent Cause Evaluation Manual
Effectiveness Review Manual
Focused Area Self-Assessments
Containment System Leakage Testing
Requirements
Industry Guideline for Implementing Performance-
based Option of 10 CFR Part 50, Appendix J
Regulatory Guide
1.163
Performance-Based Containment Leak-Test
Program
3
Attachment
PLANT PROCEDURES
Number
Description or Title
CPS 1305.01
Date or Revision
Primary Containment Leakage Rate Testing
Program
CPS 1305.01F001
Type 'B' Local Leak Rate Summary Sheet
CPS 9861.04
MSIV Local Leak Rate Test (MC-5,6,7,8)
CPS 9861.04D002
MSIV B Local Leak Rate Test Data Sheet (1MC-8)
Employee Concerns Program Process
Revision 10
Employee Concerns Program
Revision 9
Personnel Exposure Investigations
Revision 6
Procedure Use and Adherence
Revision 4
Radiological Air Sampling Program
Revision 4
Personnel Contamination Monitoring,
Decontamination, and Reporting
Revision 9
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
Non-Conservative TS for 4.16 kV Vital Bus Voltage
Division II Higher than Expected Ohmic Value on Second Level UV
Relay
Higher than Expected Ohmic Value on Second Level UV Relay
High Ohmic Value on Second UV Relay
Higher than Expected Ohmic Value on Second Level UV Relay
Issue with Auto Start of Division 3 Diesel Following Manual Stop
Division I DG 16 Cylinder Engine Heat Exchanger Coolant Leak
UFSAR Statement Regarding Shunt Tripped Loads Incorrect
Division II Diesel Generator Tripped During 9080.02
NRC Information Notice 2009-16 Spurious Relay Actuations Cause
Loss of Power
NRC Information Notice 2009-10 Transformer Failures Recent
Operating Experience
NRC Information Notice Failure of MOVs Due to Degraded Stem
Lubricant
EACE 947581
Higher than Expected Ohmic Value on Second Level UV Relay
EACE 1006888
High Ohmic Value on Second UV Relay
EACE 985349
Division I EDG did not go to rated Speed and Voltage During Monthly
Surveillance Testing
EACE 969157
Incorrect Installation of K-8A and K-32 Relays in 1E22S001B
ACE 1113608
Evaluated Division II EDG Quick Start Time
RCI 916815-09
RCIC Tripped During Startup
RCI 1157980-10
WANO Identified Area for Improvement for Relays and Power Supplies
01032794-02
1DG01KA/B - Diesel Generators Fuel Oil Consumption, Revision 0
970557-02
Issue with Auto Start of Division 3 Diesel Following Manual Stop
670088-02
Non-Conservative TS for 4.16 kV Vital Bus Voltage
4
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
Key Calculation Review Issue in an Instrument Calculation
Fuel Handling Components Not Matching Design Configuration
1DG02KE Replace DIV 3 EDG Governor Hydraulic Lines
W/O Tasks for ASME Work Not Routed to ISI for Review/Approval
1DG12AA: DIV 1 DG 16 CYL Engine Heat Exchanger Coolant Leak
Inspection Results from 0TF01B-6 Boroscope
Requesting Cantera to Reclassify CAT D Weld to CAT A
Equivalency EC for H2 Igniter Did Not Identify Calc Impact
CISI Work Order Closed Without Completing All Work
NDE Did Not Perform UT for Accumulated Air on LPCS and LPCIA
Flow Accelerated Corrosion Program Rated Yellow
Non Conservative Analysis of Hanger Support Plate
Excessive External Corrosion on Valve 1W0305
Vibration Aging Not Performed Per Approved Test Procedure
Safety-related ASME SEC. III Bolting vs. Quality Level 1
NDE Inspection for Strongback is Not Identified
FW Heater Shell Thickness Acceptance Criteria Based on INAPP
Nonsafety O-Rings Installed in Safety-related/EQ Valves
Potential Buried Line Leak Identified at NW Corner of TB
Pipe 1WS11D below Acceptance Criteria for Wall Thickness
Perform NDE Inspection of 1SXC3A
Perform NDE Inspection of 1SXB9A
Perform NDE Inspection of 1SXJ4A
1WS09AA: Perform MT on Pipe to Evaluate Extent of Cracking
RR B Motor Change out Spreader Beam NDE Inspection Report
Missing
Main Condenser Tube Bundle Supports Have Erosion Damage
0SY09EA, MOD4508, Replacement Part Not Like for Like
NRC CDBI Calculation Used Incorrect Cooling Capacity
Leakage from Insulation at 6 Condenser Nozzle
Minor Imperfections Discovered During NDE of MSIV Poppet
Need Code Minimum Thickness Requirements for UTS
South Main Condenser Waterboxes Have Patches of Corrosion
Significant Rust on Both South CW Waterbox Expansion Joints
Valves 1CD098B and D are Badly Corroded
C1R12 - 1FP48S Nozzles Eliminated Without Site ENG Approval
Potential NRC NCV for Weld Accessibility for Examination
NRC Observation of NDE Activities in C1R12
Degraded Coatings/Rust on Liner Plates Inside Containment
Floor Coating Degraded Inside Drywell Near AZ 325, EL 723
OE30955 - Clinton Could Have Vulnerabilities for Exposed Pipe
0WS51-8 Piping Wall Thickness below Screening Criteria
5
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
UT of 1SX93EA Finds 1 Location below the Calculated MIN
1B21-F032B Fails LLRT Not Identified
1WS45AA: Degraded Trend on WS Pipe Wall Thickness
Alert Alarm Trend 1RIXPR023
Non Low Carbon Welding Filler Material Needs Removed
ACE 1032794
Calculation 01DO06 Contained Non-Conservative Inputs
CCA 1164913
Potential Trend - Chemical Control
ACE 1026020
Issues Identified During C1R12 Drywell Close-Out
EACE 00951748
MCR Alarmed On SA Header Pressure Drop Due to a Failed Air Dryer
Purge Check Valve
RCI 972235
Valve Packing Failure Inside Drywell Resulted in Plant Shutdown Due
to Increasing Unidentified Leakage Rate
ACE 01024981
Restraining Device Placed on 1CW01PB Failed
NRC Indentified Issues with PMRQ
Late Scope Addition Of 1B21F022C
Bypassed QV Hold Point
Newly Rebuilt Compensator Found With Damaged O-rings
1E51N501 Procedure Deficiency 9432.49
1E22S001B-K8A For DIV III D.G. Incorrect Installation
1B33F067B - Discovered Cracked Limitorque Housing
Multiple Eng. Issues With Perm Shielding Mod
Restraining Device Placed on 1CW01PB Failed
CCP 1SA01D: Dryer Inlet And Purge Valves Open At Same Time
1AP75E1F: Inadvertent Loss of 1VX04CB
Potential Trend On Rad Monitor Failures
Procedure Adherence Fundamental As A Maint Focus Area
CCA For Online Maintenance/Work Week Adverse Trend
Review Of Human Performance Actions on Declining Performance
ODCM Table 3.9.2-1 Item 1.F Deleted Without Updating 9432.42
1SX027B 1VY006 System Test Cannot Be Completed In Full
1SM001A: No HBC Lubrication Inspection Port
Found Voltage Discrepancy In App B For 9080.21 And 9080.22
PMRQ Scope Change Could Have Lead To Missed PMT
Gaps Identified During EFR For Part Segregation Walkdowns
Transmitter Installed Upside Down
1DG12AA Packing Leak On DIV. 1 EDG Heat Exchanger
1DG006C: Valve Failed As Found Pressure Test
1GC01PB: Corrective Action Not Performed
1DG01KA: Fuel Leak Discovered During Maint PMT
1DG01KA16: Unable To Perform Section Of 8207.09 For Diesel
Unexpected Readings On Voltage And Ripple For Temp P/S
Drywell Pressure Rise/Floor Drain Leak Rate
Division 1 DG Slow Start Time
TDRFP 1B Unloaded When Placing TDRFP 1A In Service
Data Missed In Operating Logs For 9080.03 DIV 3 DG Run
6
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
RAT Tripped
Secondary Containment LCO Action Not Entered When Required
LCO Action Not Previously Identified
1E12F064A: RHR[Residual Heat Removal] A Min Flow F064A Failed
To Stroke Shut
9000.02D001 SURVEILLANCE REQUIREMENTS
Missed Opportunity To Identify TS Actions For Bypassed Rod
C1R12 LL NRC Resident Observation Regarding FP Behaviors
Double Blade Guide Removed With Rod Inserted
DIV 2 EDG Quick-Start Time > 9080.02 STEP 9.1.6 Criteria
Perform Reactivity Management CCA
Perform CCA On Documented Gaps Within Operations
Perform Reactivity Management CCA
Adverse Trend In Fire Protection Barrier Impairment Process
1DG01KB DIV 2 DG Oil Leak Needs Revisited
CPS 3506.01 Needs Revised For Fuel Oil Sampling Criteria
Inadequate Risk Perception Displayed By Crew D Supervision
HPCS INOP due to DIV 4 DC Voltage Low
Entered Abnormal Reactor Flow Offnormal
Potential Adverse Trend In Operations Work Control
Fuel Pool Cooling PMRQs Past Late Date Due To Failed 1FC004A
1FC004A Continued To Stroke Open After Full Open Indication
IRs Routinely Routed To OPS Not Per LS-AA-120
NRC Identified Disposition IR Not Properly Documented
Backup Bottle For Upper Pool Gates Cannot Be Verified
IR Action Not Timely
Ineffective Implementation Of Corrective Actions
RCR 917094
Perform A Root Cause Analysis on EHC Pump Quality Resolution
RCR 972235
Valve Packing Failure Inside Drywell Resulted in Plant Shutdown
RCR 979700
1B33C001B: RR B Trip - Resulting in Reactor Scram
RCR 1017724
Contract Employee Contaminated in Drywell
RCR 1021241
Late Identification of Work Scope for 1B21F022C, Inboard Main Steam
Line C Isolation Valve
RCR 1023530
Gate Seal Leakage During Containment Isolation Valve System
Functional Test
RCR 1147568
Re-Evaluation Exam Provided Did Not Meet Expectations
RCR 1157980
WANO Identified Area for Improvement for Relays and Power Supplies
EACE 490449
A' Electro-Hydraulic Control System Pump Erratic Pressure Control
ACE 802707
1EH01PB Has Pencil Size Leak From Compensator
ACE 910239
Recurrence of Inadequately Refurbished EHC Pump Compensators
EACE 1017464
Investigate Failure of 'B' MSIVs
AR 802707802707
1EH01PB Has Pencil Size Leak From Compensator
AR 900700900700
1EH01S: Declining Main EHC Header Pressure Trend
AR 905167905167
1EH01PA Pump Pressure Erratic During Pump Jog
AR 908262908262
1EH01PA Pressure Oscillating 1400 - 1500 psig
AR 910239910239
Newly Rebuilt Compensator Found With Damaged Orings
7
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
AR 914589914589
1EH01S: EHC Pump Test Results & Findings at Vendor Facility
AR 917094917094
Perform a Root Cause Analysis on EHC Pump Quality Resolution
AR 927530927530
Results of Effectiveness Review for AR 490449490449
AR 950746950746
1EH01PA: Main EHC Pump A Discharge Pressure Lowering
AR 950753950753
1EH01S: Main EH Pump Discharge Filter DP Increasing Trend
AR 983138983138
1EH01PA: Main EHC Pump A Making Occasional Abnormal Noise
AR 993685993685
1EH01PA: EH Pump A Discharge Pressure Degrading
AR 993974993974
1EH01PA: Pressure Compensator Needs Adjustment
AR 994192994192
EH 'B' Pump Local Discharge Pressure Gauge Reading Low
AR 997711997711
1EH01FB: EH Pump 'B' Discharge Pressure Has Decreasing Trend
NOS ID MSIV LLRT Test Data Anomalies
EHC 'A' Pump (1EH01PA) Not Operating Properly
Received PPC Alarm on EH-DA201 Main EHC Pressure
1EH01PA: Unexpected Low Pressure Main EHC (PPC Alarm)
Steam Bypass EHC 'B' Pump Oscillating Pressure
SB EHC Pump 'B' Oscillating Pressure
Inadequate Response to NER NC-10-036
Low Discharge Pressure 1EH01PB During Weekly Jog
1C85D002PB: Bypass EHC Skid Pressure Oscillating
EHC Pump Repair/Overhaul by Pump OEM to Reduce Problems
NOS ID Root Cause Report Does Not Contain EFR or EFRS
1H13-U703: Spurious Halon Alarms are a Distraction
1B21F028A: 9861.04 LLRT on MSL A, B, and C Test Failure
NOS ID MSIV As-Found Results Re-Evaluate Reportability
CA 1033113-03 Extension Paperwork
Potential Creep Away from Meeting Regulatory Requirements
Depth of Investigation for NRC Findings and Violations
Possible Gap IDd During SOER 02-04 Effectiveness Review
Potential Degrading Trend in Human Performance
NOS ID Security Program Performance Rated Yellow
NOS ID Elevation of Operations of Automatic Vehicle Barriers
Identified Trend un Human Error Prevention Fundamental
CCA 905077
Negative Trend in Human Performance Events in 2009
Potential Low Level Internal Contamination
Individual Contaminated in RT Hold Pump Room
Identified Trend with Errors made by Security Supervision
Security: Evaluate for CCA in Security Declining HU
CCA 913798
Trng-Potential Trend-Clock Reset
CCA 937393
Trng - Potential Trend Training Records Issues
CCA 1089222
Trng - Check-In Assess ID'd Deficiency In DTC Performance
CCA 1125966
Clinton Training Dept Performance Common Cause Analysis
CCA 1167605
Trng-Potential Trend ID'd During NTD Qtrly C&A
CCA 915153
Increase In HU Events Tracking IR
CCA 965371
Potential Trend-Security Regulation Violations
CCA 1037104
Security Identified Organizational Issues Requiring CCA
8
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
CCA 1167779
Identified Trend With Errors Made By Security Supervision
CCA 1120908
Trend IR: IRs Associated With Weapons And Ammunition
CCA 1051723
Security - Adverse Trend In Firearms Qualifications
CCA 1185699
Identified Trend In Human Error Prevention Fundamental
CCA 1185701
Identified Trend With Physical Security Fundamental
RCE 1101545
Trng- 5 Of 6 ILT Students Failed Comp Exam #2
ACE 935792
Trng - Final Exam Failures
ACE 1077324
Trng- Unqualified Instructor Performed Evaluation
ACE 1108724
Trng - Ineffective CA On Trng Records Quality
ACE 1122532
Trng: Consequential Exam Security Event While Performing JPM
ACE 1021622
Questions Regarding Search At Unitech Laundry Facility
ACE 1041649
Inadvertent AVB Manipulation
ACE 1052555
Potential Inattentive Security Officer
ACE 1077623
Violation Of Work Hour Rules (WHR)
CCA 969936
Trng - Analysis Of Exam Failures For A Common Cause
IR 924558
Trng: FASA Deficiency For Training Request Action Response
IR 937396
Trng - Peat Missing Disposition To Recommended Actions
IR 944094
Controlled Copy Number Not Marked On Controlled Copy Binder
IR 954980
Trng - CRC Meeting Cancelled Due To Illness
IR 967010
Trng - Ops Procedures Reference A Superseded Procedure
IR 978652
Trng Clearance Writer/Preparer TPE Template Error
IR 996224
Trng: Critical Task Wording Needs Improved
Trng - Scenario Critical Step Enhancement
Broken Tabs On 1E31-R551 Recorder
HPCS Test Prep Switches
C1R12 Ll - Perform Auto Act/Isol Tests At Front Of Outage
Trng Component Changed In Employee's LMS History Panel
Trng - One EP Quiz Question Had Two Possible Answers
Trng Chemistry Training Reschedule
NTD - Category 2 Parts Found At Maint. Learning Center
MRC Rejected NTD CCA On Question Quality
Trng - Instructor Late For Class
Contin Training ID Potential CPOS Bus Damage Vulnerability
OIO - Benchmarking Accrediting Board Chairman Feedback
Trng-PCRA- Cps 4004.01 Loss Of IA
IR 908802
Security PIDS Zone Is Locked On
IR 911659
Detect Lane MSO At Risk Of Inattentiveness At Nonpeak Times
IR 920462
1JB05-STI-2: STI02 Alarm Point Locked On
IR 922993
PZ 18/19 Malfunction Locked On
IR 930689
Gate Will Not Close
IR 936894
BRE #1 Interior Folding Wall Table Disconnected From The Wall
IR 954911
IR 970224
Brake And Signal Light Out
IR 992652
Security X-Ray #3 Inoperable
Enhancement For Intake At Screenhouse
789' Ctmt Level 2 Personal Contamination Event
9
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
Level 1 PCE 2010-01
Reforecast Of C1R12 Exposure Goal And Stretch Goals
Potential Adverse Trend Identified
USAR Table Needs Updated
Procedure Change Needed For Cps 3822.07 C002
IR Not Written For Ed Dose Alarm
Reoccurring Loss Of Power
Inadequate Closure Of EFR
Inadequate Closure Of EFR
Water Backing Up In Floor Drains
OPERATING EXPERIENCE
Number
Description or Title
910219
TRNG-CPS 3304.04 Requires Revision Per OpEx 25417 - OIO
1099404
Enhancement To SOER 02-4 (Davis-Besse) Continuing Training
1127685
EMD SOER 98-2 Training IDD Unnecessary Work Performed
1102960
Security OpEx: Oyster Creek Schedule Concerns - OIO
1149784
OpEx Review: OE 32446 Security Drill SGI/Sensitive [Sic] Documents
AUDITS, ASSESSMENTS, SELF-ASSESSMENTS, AND EVALUATIONS
Number
Description or Title
CL-2009-E-013
Revision
50.59 Evaluation - Deferral of Division 3 DG Fuel
Oil Storage Tank Cleaning to September 2009
and a 25% Interval Extension to Regulatory Guide
1.137 10 Year FOST Cleaning Frequency for all
3 Division EDGs
Revision 0
CL-2010-S-029
50.59 Review - Temporary Modification to Lift
Input from A10 Device to A11 Device for the
Division I Diesel Generator
Revision 0
CL-2009-S-054
50.59 Review - Division III DG Auto Start
Immediately Following LOOP [Loss of Offsite
Power] After Manual Stop
Revision 0
CL-2009-S-004
50.59 Review - Replacement of the Existing A3
Speed Relay Switch Assembly for the Division I
Revision 0
Report No. C1R12-
078
Liquid Penetrant Examination Report for Weld
CRDH-210%
January 24, 2010
Magnetic Particle Examination
Revision 3
Magnetic Particle Examination
Revision 4
Records Management Program
Revision 8
Commitment Management
Revision 7
Self Assessment
(SA) 887965-02
Operations Burden Aggregate Process
10
Attachment
AUDITS, ASSESSMENTS, SELF-ASSESSMENTS, AND EVALUATIONS
Number
Description or Title
SA 1056012-03
Revision
SA 1147578-21
MCR Deficiency & B Priority Work Process
NOSA-CPS-10-06
Training & Staffing (AR# 995676)
June 8, 2010
NOSA-CPS-10-07
FFD, Access Authorization & Corporate Security
(AR# 995688)
August 20, 2010
AR 699108699108
Ops Training Objectives 1, 2, 3, 4, 5, 6 FASA
June 2, 2009
AR 861208861208
Safeguards Control FASA
April 30, 2009
AR 860982860982
Equip Performance Testing & Maint & OCA FASA
August 4, 2009
AR 904733904733
Training - Admin & Records Check-In Report
September 22, 2009
Training - Technical Human Performance Check-
In Report
January 5, 2011
DTC Roles & Responsibilities Check-In Report
March 10, 2011
Firearms Practice & Range Check-In Report
December 21, 2010
Turnover & Briefings Check-In Report
March 16, 2011
QHPI 971566
Trg - Consequential Exam Security Event
QHPI 993075
Trng: Improper Instructor Use Of HU Tools
During JPMs
QHPI 1013316
NEIT Consequential Exam Security Event
QHPI 909344
Handgun Fell From Holster During Arming
Process
QHPI 941815
Security First Aid Injury Elevated To OSHA
Recordable
QHPI 1041285
Dropped Handgun
QHPI 1089400
AVB Inappropriately Lowered
QHPI 1099266
Security Officer On Post Without Contingency
Equipment
QHPI 1140526
Security Training - Loss Of Exam Control
FASA 1056012-03
976693-02
Check-In Self-Assessment: Site safety Culture
861223-02
Check-In Self-Assessment: Safety Culture
Procedure Implementation
WORK ORDERS AND DRAWINGS
Number
Description or Title
Work Order (WO)
01277109
Revision
Replace Grounded B RR Pump Motor
/PMRQ 156877
MM Inspect System Dryer/Separator Strongback
/PMRQ 156886
MM Inspect Strongback Carousel Hoists,
Tensioners
Training Request
2010-02-0013A
Chemistry CRC - The use of Fixatives
Revision 0
Training Request
Chemistry CRC - The use of Gel Fixatives
Revision 0
11
Attachment
WORK ORDERS AND DRAWINGS
Number
Description or Title
2010-02-0012A
Revision
CONDITION REPORTS GENERATED DURING INSPECTION
Number
Description or Title
Computation Error in IR 919673
Closure of IR 670088 Action 04 not Clearly Documented
NRC PI&R: WO 988866-99 Has Two NDE Exams for Same Item
NRC Identified Issue With WO Documentation
NRC PI&R: Root Cause 972235 Does Not Have EFR As Required
NRC PI&R: Root Cause 979700 Does Not Have EFR As Required
NRC PI&R EFRs Not Identified As Required
NRC PI&R: As-Found LRT For Each MSIV Not Performed In C1R12
NRC PI&R: Inaccuracies in Reproduced Document
1AP9EH227X1 NRC PI&R Issue - Computation Error in IR 919673
Maximum Steady State Voltage for TS 3.8.1 Nonconservative
TS 3.8.1 Design Basis/Licensing Basis Inconsistency
Inaccurate Information Provided to NRC in License Amendment
(NRC Identified) Issue Identified with PMRQ
12
Attachment
LIST OF ACRONYMS USED
Agencywide Document Access Management System
Action Request
American Society of Mechanical Engineers
CA
Corrective Action
Corrective Action Program
Corrective Action to Prevent Recurrence
Component Design Basis Inspection
Clinton Power Station
CFR
Code of Federal Regulations
Direct Current
Diesel Generator
Division of Reactor Projects
Equipment Apparent Cause Evaluation
Employee Concerns Program
EFR
Effectiveness Review
Focused Area Self Assessment
Final Safety Analysis Report
Illinois Emergency Management Agency
IMC
Inspection Manual Chapter
IP
Inspection Procedure
IR
Inspection Report
Inservice Inspection
kV
Kilovolt
LCO
Limiting Condition for Operation
Management Review Committee
N/A
Not Applicable
Non-Cited Violation
NOS
Nuclear Oversight
NRC
U.S. Nuclear Regulatory Commission
Operating Experience
Publicly Available Records System
Problem Identification and Resolution
Preventative Maintenance Request
Reserve Auxiliary Transformer
Root Cause Report
Reactor Feed Pump
Reactor Recirculation
Safety-Conscious Work Environment
Significance Determination Process
Station Oversight Committee
TS
Technical Specification
13
Attachment
Vdc
Volts Direct Current
Work Order
M. Pacilio
-2-
If you contest the subject or severity of these NCVs, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001,
with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III,
2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector
Office at the Clinton Power Station. In addition, if you disagree with the cross-cutting aspect
assigned to any finding 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 the Clinton Power Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response (if any) will be available electronically for public inspection in
the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website
at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Mark A. Ring, Chief
Branch 1
Division of Reactor Projects
Docket No. 50-461
License No. NPF-62
Enclosure:
Inspection Report 05000461/2011008;
w/Attachment: Supplemental Information
cc w/encl:
Distribution via ListServ
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OFFICE
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E
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NAME
MRing for ROrlikowski
MRing:cs
DATE
07/08/11
07/08/11
OFFICIAL RECORD COPY
Letter to M. Pacilio from M. Ring dated July 8, 2011
SUBJECT:
CLINTON POWER STATION NRC PROBLEM IDENTIFICATION AND
RESOLUTION INSPECTION REPORT 05000461/2011008
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