ML11189A129

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IR 05000461-11-008, on 05/16/2011 - 06/03/2011, Clinton Power Station; Identification and Resolution of Problems
ML11189A129
Person / Time
Site: Clinton Constellation icon.png
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

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-561

License No: NPF-62

Report No: 05000461/2011008

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

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.

Identification and Resolution of Problems

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.

A. NRC-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

  • Green. 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.

The inspectors determined that this finding was more than minor because it was

associated with the Mitigating Systems Cornerstone attribute of design control and

1 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 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

AR1223723.

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))

Cornerstone: Initiating Events

  • Green. 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.

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))

2 Enclosure

B. Licensee-Identified Violations

No violations of significance were identified.

3 Enclosure

REPORT DETAILS

4. OTHER ACTIVITIES

4OA2 Problem Identification and Resolution (71152B)

The activities documented in sections .1 through .4 constituted one biennial sample of

problem identification and resolution as defined in Inspection Procdure (IP) 71152.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees CAP implementing procedures and attended

CAP meetings to assess the implementation of the CAP by site personnel.

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. Assessment

(1) Effectiveness of Problem Identification

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

4 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

Failure to Follow Work Order Instructions

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.

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.

5 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.

Findings

No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues

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.

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

Failure to Adequately Maintain Regulatory Requirements in Design Basis Procedures

and Instructions

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.

6 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.

Failure to Demonstrate by Calculation Operability of Safety-Related Loads When

Powered from the EDGs

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 670088 Non-

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.

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.

Findings

(1) Failure to Account for Cable Resistance in Operability Determinations

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

7 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 919673.

  • 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 947824.

  • 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 947581.

  • 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.

8 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 947581 and 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.

Cross-Cutting Aspects

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)).

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.

9 Enclosure

(2) Failure to Maintain a Quality Record as Evidence of an Activity Affecting Quality of

Safety-Related Equipment Due to Inappropriate Corrective Actions

Introduction

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.

Description

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.

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.

Analysis

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.

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

10 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.

Cross-Cutting Aspects

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.

(IMC 0310 P.1(d))

Enforcement

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.

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) Effectiveness of Corrective Actions

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.

11 Enclosure

Findings

(1) Failure to Perform Effectiveness Review

Introduction

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.

Discussion

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).

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

12 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.

Analysis

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.

13 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.

Cross-Cutting Aspects

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))

Enforcement

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.

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 Assessment of the Use of Operating Experience (OE)

a. Inspection Scope

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.

14 Enclosure

b. Assessment

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.

Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

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.

b. Assessment

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.

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.

Findings

No findings were identified.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

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

15 Enclosure

departments, and reviews of issue reports. The inspectors also reviewed the results of

licensee safety culture surveys.

b. Assessment

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.

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.

Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

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.

ATTACHMENT: SUPPLEMENTAL INFORMATION

16 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

W. Knoll, Site Vice President

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 NCV Failure to Account for Cable Resistance in Operability

Determinations (4OA2.1.b(2)(1)05000461/2011008-02 NCV 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 NCV Failure to Perform Effectiveness Review (4OA2.1.b(3)(1)

Discussed

None.

1 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 Date or Revision

CPS 9333.20 Division I 4.16 kV Bus Undervoltage Relay December 9, 2009

(Degraded Voltage) Functional Test

CPS 9333.30 Division II 4.16 kV Degraded Voltage Trip - December 9, 2009

Functional Test

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 Revision 1

Cask Pit Racks for the Clinton Nuclear Plant

MA-AA-716-022 Control of Heavy Loads Program Revision 8

MA-CL-716-022- Handling of Heavy Loads Revision 0F

1001

WC-AA-111 Predefine Process Revision 3

EC 376454 R/0 Design Considerations Summary

ANSI N14.6-1978 American National Standard for Special Lifting February 15, 1978

Devices for Shipping Containers Weighing 10,000

Pounds (4500 kg) or More for Nuclear Materials

MA-AA-716-021 Exelon Procedure; Rigging and Lifting Program Revision 17

CPS 8106.03 Crane Inspection, Maintenance, and Testing Revision 22e

(Including Special Lifts)

MA-CL-716-021- Periodic Inspection of Rigging Equipment Revision 2

1001

MA-CL-716-021- Periodic Inspection of Rigging Equipment Revision 3

1001

LS-AA-120 Issue Identification and Screening Process

LS-AA-125 Corrective Action Program Procedure Revision 15

LS-AA-125-1001 Root Cause Analysis Manual

LS-AA-125-1003 Apparent Cause Evaluation Manual

LS-AA-125-1004 Effectiveness Review Manual

LS-AA-126-1001 Focused Area Self-Assessments

Containment System Leakage Testing

ANSI/ANS 56.8-2002 Requirements

Industry Guideline for Implementing Performance-

NEI 94-01 based Option of 10 CFR Part 50, Appendix J

Regulatory Guide Performance-Based Containment Leak-Test

1.163 Program

2 Attachment

PLANT PROCEDURES

Number Description or Title Date or Revision

Primary Containment Leakage Rate Testing

CPS 1305.01 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)

EI-AA-101-1001 Employee Concerns Program Process Revision 10

EI-AA-101 Employee Concerns Program Revision 9

RP-AA-203-1001 Personnel Exposure Investigations Revision 6

HU-AA-1004-101 Procedure Use and Adherence Revision 4

RP-AA-301 Radiological Air Sampling Program Revision 4

RP-AA-350 Personnel Contamination Monitoring, Revision 9

Decontamination, and Reporting

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

AR 0067088 Non-Conservative TS for 4.16 kV Vital Bus Voltage

AR 00947824 Division II Higher than Expected Ohmic Value on Second Level UV

Relay

AR 00947581 Higher than Expected Ohmic Value on Second Level UV Relay

AR 0100688 High Ohmic Value on Second UV Relay

AR 00919673 Higher than Expected Ohmic Value on Second Level UV Relay

AR 00970557 Issue with Auto Start of Division 3 Diesel Following Manual Stop

AR 01155992 Division I DG 16 Cylinder Engine Heat Exchanger Coolant Leak

AR 00904590 UFSAR Statement Regarding Shunt Tripped Loads Incorrect

AR 01214578 Division II Diesel Generator Tripped During 9080.02

AR 00977050 NRC Information Notice 2009-16 Spurious Relay Actuations Cause

Loss of Power

AR 00953437 NRC Information Notice 2009-10 Transformer Failures Recent

Operating Experience

AR 01031112 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

3 Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

AR 01152745 Key Calculation Review Issue in an Instrument Calculation

AR 01158094 Fuel Handling Components Not Matching Design Configuration

AR 01152397 1DG02KE Replace DIV 3 EDG Governor Hydraulic Lines

AR 01151739 W/O Tasks for ASME Work Not Routed to ISI for Review/Approval

AR 01155992 1DG12AA: DIV 1 DG 16 CYL Engine Heat Exchanger Coolant Leak

AR 01155146 Inspection Results from 0TF01B-6 Boroscope

AR 01155313 Requesting Cantera to Reclassify CAT D Weld to CAT A

AR 01167888 Equivalency EC for H2 Igniter Did Not Identify Calc Impact

AR 01163955 CISI Work Order Closed Without Completing All Work

AR 01169808 NDE Did Not Perform UT for Accumulated Air on LPCS and LPCIA

AR 01176939 Flow Accelerated Corrosion Program Rated Yellow

AR 01183047 Non Conservative Analysis of Hanger Support Plate

AR 01197929 Excessive External Corrosion on Valve 1W0305

AR 00909586 Vibration Aging Not Performed Per Approved Test Procedure

AR 00925421 Safety-related ASME SEC. III Bolting vs. Quality Level 1

AR 00922844 NDE Inspection for Strongback is Not Identified

AR 00929815 FW Heater Shell Thickness Acceptance Criteria Based on INAPP

AR 00950308 Nonsafety O-Rings Installed in Safety-related/EQ Valves

AR 00954857 Potential Buried Line Leak Identified at NW Corner of TB

AR 00953213 Pipe 1WS11D below Acceptance Criteria for Wall Thickness

AR 00952602 Perform NDE Inspection of 1SXC3A

AR 00952609 Perform NDE Inspection of 1SXB9A

AR 00952621 Perform NDE Inspection of 1SXJ4A

AR 00952631 1WS09AA: Perform MT on Pipe to Evaluate Extent of Cracking

AR 00988866 RR B Motor Change out Spreader Beam NDE Inspection Report

Missing

AR 01016954 Main Condenser Tube Bundle Supports Have Erosion Damage

AR 01023478 0SY09EA, MOD4508, Replacement Part Not Like for Like

AR 01082774 NRC CDBI Calculation Used Incorrect Cooling Capacity

AR 01014784 Leakage from Insulation at 6 Condenser Nozzle

AR 01019707 Minor Imperfections Discovered During NDE of MSIV Poppet

AR 01001385 Need Code Minimum Thickness Requirements for UTS

AR 01015209 South Main Condenser Waterboxes Have Patches of Corrosion

AR 01015184 Significant Rust on Both South CW Waterbox Expansion Joints

AR 01015202 Valves 1CD098B and D are Badly Corroded

AR 01020386 C1R12 - 1FP48S Nozzles Eliminated Without Site ENG Approval

AR 01020871 Potential NRC NCV for Weld Accessibility for Examination

AR 01020881 NRC Observation of NDE Activities in C1R12

AR 01017558 Degraded Coatings/Rust on Liner Plates Inside Containment

AR 01017544 Floor Coating Degraded Inside Drywell Near AZ 325, EL 723

AR 01062663 OE30955 - Clinton Could Have Vulnerabilities for Exposed Pipe

AR 01103870 0WS51-8 Piping Wall Thickness below Screening Criteria

4 Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

AR 01107529 UT of 1SX93EA Finds 1 Location below the Calculated MIN

AR 01025446 1B21-F032B Fails LLRT Not Identified

AR 00947143 1WS45AA: Degraded Trend on WS Pipe Wall Thickness

AR 0106221 Alert Alarm Trend 1RIXPR023

AR 01039946 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

AR 01224057 NRC Indentified Issues with PMRQ

AR 01021241 Late Scope Addition Of 1B21F022C

AR 01148122 Bypassed QV Hold Point

AR 00910239 Newly Rebuilt Compensator Found With Damaged O-rings

AR 00949402 1E51N501 Procedure Deficiency 9432.49

AR 00969157 1E22S001B-K8A For DIV III D.G. Incorrect Installation

AR 01016173 1B33F067B - Discovered Cracked Limitorque Housing

AR 01016831 Multiple Eng. Issues With Perm Shielding Mod

AR 01024981 Restraining Device Placed on 1CW01PB Failed

AR 01048311 CCP 1SA01D: Dryer Inlet And Purge Valves Open At Same Time

AR 01069590 1AP75E1F: Inadvertent Loss of 1VX04CB

AR 01179979 Potential Trend On Rad Monitor Failures

AR 00907001 Procedure Adherence Fundamental As A Maint Focus Area

AR 01095255 CCA For Online Maintenance/Work Week Adverse Trend

AR 01066830 Review Of Human Performance Actions on Declining Performance

AR 01150089 ODCM Table 3.9.2-1 Item 1.F Deleted Without Updating 9432.42

AR 01152747 1SX027B 1VY006 System Test Cannot Be Completed In Full

AR 01159237 1SM001A: No HBC Lubrication Inspection Port

AR 01160216 Found Voltage Discrepancy In App B For 9080.21 And 9080.22

AR 01165412 PMRQ Scope Change Could Have Lead To Missed PMT

AR 01172939 Gaps Identified During EFR For Part Segregation Walkdowns

AR 01173198 Transmitter Installed Upside Down

AR 01182519 1DG12AA Packing Leak On DIV. 1 EDG Heat Exchanger

AR 01191512 1DG006C: Valve Failed As Found Pressure Test

AR 01035683 1GC01PB: Corrective Action Not Performed

AR 01122813 1DG01KA: Fuel Leak Discovered During Maint PMT

AR 01120781 1DG01KA16: Unable To Perform Section Of 8207.09 For Diesel

AR 01143877 Unexpected Readings On Voltage And Ripple For Temp P/S

AR 00972235 Drywell Pressure Rise/Floor Drain Leak Rate

AR 01194749 Division 1 DG Slow Start Time

AR 00925961 TDRFP 1B Unloaded When Placing TDRFP 1A In Service

AR 00922711 Data Missed In Operating Logs For 9080.03 DIV 3 DG Run

5 Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

AR 00925880 RAT Tripped

AR 00939875 Secondary Containment LCO Action Not Entered When Required

AR 00938683 LCO Action Not Previously Identified

1E12F064A: RHR[Residual Heat Removal] A Min Flow F064A Failed

AR 00948468 To Stroke Shut

AR 00959835 9000.02D001 SURVEILLANCE REQUIREMENTS

AR 00974412 Missed Opportunity To Identify TS Actions For Bypassed Rod

AR 01013399 C1R12 LL NRC Resident Observation Regarding FP Behaviors

AR 01017904 Double Blade Guide Removed With Rod Inserted

AR 01113608 DIV 2 EDG Quick-Start Time > 9080.02 STEP 9.1.6 Criteria

AR 01159858 Perform Reactivity Management CCA

AR 00958957 Perform CCA On Documented Gaps Within Operations

AR 01075686 Perform Reactivity Management CCA

AR 01092787 Adverse Trend In Fire Protection Barrier Impairment Process

AR 01152838 1DG01KB DIV 2 DG Oil Leak Needs Revisited

AR 01157160 CPS 3506.01 Needs Revised For Fuel Oil Sampling Criteria

AR 01173770 Inadequate Risk Perception Displayed By Crew D Supervision

AR 00926130 HPCS INOP due to DIV 4 DC Voltage Low

AR 00934528 Entered Abnormal Reactor Flow Offnormal

AR 00939898 Potential Adverse Trend In Operations Work Control

AR 00946058 Fuel Pool Cooling PMRQs Past Late Date Due To Failed 1FC004A

AR 00946549 1FC004A Continued To Stroke Open After Full Open Indication

AR 00959329 IRs Routinely Routed To OPS Not Per LS-AA-120

AR 00964540 NRC Identified Disposition IR Not Properly Documented

AR 01023864 Backup Bottle For Upper Pool Gates Cannot Be Verified

AR 01042194 IR Action Not Timely

AR 01104238 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

Late Identification of Work Scope for 1B21F022C, Inboard Main Steam

RCR 1021241

Line C Isolation Valve

Gate Seal Leakage During Containment Isolation Valve System

RCR 1023530

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 802707 1EH01PB Has Pencil Size Leak From Compensator

AR 900700 1EH01S: Declining Main EHC Header Pressure Trend

AR 905167 1EH01PA Pump Pressure Erratic During Pump Jog

AR 908262 1EH01PA Pressure Oscillating 1400 - 1500 psig

AR 910239 Newly Rebuilt Compensator Found With Damaged Orings

6 Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

AR 914589 1EH01S: EHC Pump Test Results & Findings at Vendor Facility

AR 917094 Perform a Root Cause Analysis on EHC Pump Quality Resolution

AR 927530 Results of Effectiveness Review for AR 490449

AR 950746 1EH01PA: Main EHC Pump A Discharge Pressure Lowering

AR 950753 1EH01S: Main EH Pump Discharge Filter DP Increasing Trend

AR 983138 1EH01PA: Main EHC Pump A Making Occasional Abnormal Noise

AR 993685 1EH01PA: EH Pump A Discharge Pressure Degrading

AR 993974 1EH01PA: Pressure Compensator Needs Adjustment

AR 994192 EH 'B' Pump Local Discharge Pressure Gauge Reading Low

AR 997711 1EH01FB: EH Pump 'B' Discharge Pressure Has Decreasing Trend

AR 1020527 NOS ID MSIV LLRT Test Data Anomalies

AR 1021798 EHC 'A' Pump (1EH01PA) Not Operating Properly

AR 1056553 Received PPC Alarm on EH-DA201 Main EHC Pressure

AR 1060386 1EH01PA: Unexpected Low Pressure Main EHC (PPC Alarm)

AR 1160255 Steam Bypass EHC 'B' Pump Oscillating Pressure

AR 1165585 SB EHC Pump 'B' Oscillating Pressure

AR 1179468 Inadequate Response to NER NC-10-036

AR 1188640 Low Discharge Pressure 1EH01PB During Weekly Jog

AR 1193664 1C85D002PB: Bypass EHC Skid Pressure Oscillating

AR 1198169 EHC Pump Repair/Overhaul by Pump OEM to Reduce Problems

AR 1204691 NOS ID Root Cause Report Does Not Contain EFR or EFRS

AR 1211557 1H13-U703: Spurious Halon Alarms are a Distraction

AR 1017464 1B21F028A: 9861.04 LLRT on MSL A, B, and C Test Failure

AR 1059673 NOS ID MSIV As-Found Results Re-Evaluate Reportability

AR 1099320 CA 1033113-03 Extension Paperwork

AR 1207467 Potential Creep Away from Meeting Regulatory Requirements

AR 1207487 Depth of Investigation for NRC Findings and Violations

AR 1090813 Possible Gap IDd During SOER 02-04 Effectiveness Review

AR 0792128 Potential Degrading Trend in Human Performance

AR 1046015 NOS ID Security Program Performance Rated Yellow

AR 1050574 NOS ID Elevation of Operations of Automatic Vehicle Barriers

AR 1185699 Identified Trend un Human Error Prevention Fundamental

AR 1089919 RP 2nd Quarter HU Events

CCA 905077 Negative Trend in Human Performance Events in 2009

AR 0989128 Potential Low Level Internal Contamination

AR 1017853 Individual Contaminated in RT Hold Pump Room

AR 1167779 Identified Trend with Errors made by Security Supervision

AR 1099410 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

7 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

IR 1007200 Trng - Scenario Critical Step Enhancement

IR 1019320 Broken Tabs On 1E31-R551 Recorder

IR 1020492 HPCS Test Prep Switches

IR 1023625 C1R12 Ll - Perform Auto Act/Isol Tests At Front Of Outage

IR 1026054 Trng Component Changed In Employee's LMS History Panel

IR 1036041 Trng - One EP Quiz Question Had Two Possible Answers

IR 1067400 Trng Chemistry Training Reschedule

IR 1083426 NTD - Category 2 Parts Found At Maint. Learning Center

IR 1093396 MRC Rejected NTD CCA On Question Quality

IR 1095615 Trng - Instructor Late For Class

IR 1152017 Contin Training ID Potential CPOS Bus Damage Vulnerability

IR 1178145 OIO - Benchmarking Accrediting Board Chairman Feedback

IR 1190426 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 NSSS BOP Training Needed

IR 970224 Brake And Signal Light Out

IR 992652 Security X-Ray #3 Inoperable

IR 1005909 Enhancement For Intake At Screenhouse

IR 00939150 789' Ctmt Level 2 Personal Contamination Event

8 Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

IR 01012816 Level 1 PCE 2010-01

IR 01020244 Reforecast Of C1R12 Exposure Goal And Stretch Goals

IR 00968090 Potential Adverse Trend Identified

IR 01147953 USAR Table Needs Updated

IR 01158522 Procedure Change Needed For Cps 3822.07 C002

IR 01172431 IR Not Written For Ed Dose Alarm

IR 00923067 Reoccurring Loss Of Power

IR 01039689 Inadequate Closure Of EFR

IR 01039691 Inadequate Closure Of EFR

IR01083224 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 Revision

CL-2009-E-013 50.59 Evaluation - Deferral of Division 3 DG Fuel Revision 0

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

CL-2010-S-029 50.59 Review - Temporary Modification to Lift Revision 0

Input from A10 Device to A11 Device for the

Division I Diesel Generator

CL-2009-S-054 50.59 Review - Division III DG Auto Start Revision 0

Immediately Following LOOP [Loss of Offsite

Power] After Manual Stop

CL-2009-S-004 50.59 Review - Replacement of the Existing A3 Revision 0

Speed Relay Switch Assembly for the Division I

EDG

Report No. C1R12- Liquid Penetrant Examination Report for Weld January 24, 2010

078 CRDH-210%

ER-AA-335-003 Magnetic Particle Examination Revision 3

ER-AA-335-004 Magnetic Particle Examination Revision 4

RM-AA-101 Records Management Program Revision 8

LS-AA-110 Commitment Management Revision 7

Self Assessment

(SA) 887965-02 Operations Burden Aggregate Process

9 Attachment

AUDITS, ASSESSMENTS, SELF-ASSESSMENTS, AND EVALUATIONS

Number Description or Title Revision

SA 1056012-03 Pre-NRC PI&R Inspection FASA

SA 1147578-21 MCR Deficiency & B Priority Work Process

NOSA-CPS-10-06 Training & Staffing (AR# 995676) June 8, 2010

FFD, Access Authorization & Corporate Security August 20, 2010

NOSA-CPS-10-07 (AR# 995688)

AR 699108 Ops Training Objectives 1, 2, 3, 4, 5, 6 FASA June 2, 2009

AR 861208 Safeguards Control FASA April 30, 2009

AR 860982 Equip Performance Testing & Maint & OCA FASA August 4, 2009

AR 904733 Training - Admin & Records Check-In Report September 22, 2009

Training - Technical Human Performance Check- January 5, 2011

AR 1106585 In Report

AR 1071455 DTC Roles & Responsibilities Check-In Report March 10, 2011

AR 1011842 Firearms Practice & Range Check-In Report December 21, 2010

AR 1132993 Turnover & Briefings Check-In Report March 16, 2011

QHPI 971566 Trg - Consequential Exam Security Event

Trng: Improper Instructor Use Of HU Tools

QHPI 993075 During JPMs

QHPI 1013316 NEIT Consequential Exam Security Event

Handgun Fell From Holster During Arming

QHPI 909344 Process

Security First Aid Injury Elevated To OSHA

QHPI 941815 Recordable

QHPI 1041285 Dropped Handgun

QHPI 1089400 AVB Inappropriately Lowered

Security Officer On Post Without Contingency

QHPI 1099266 Equipment

QHPI 1140526 Security Training - Loss Of Exam Control

FASA 1056012-03 Pre-NRC PI&R Inspection FASA

976693-02 Check-In Self-Assessment: Site safety Culture

Check-In Self-Assessment: Safety Culture

861223-02 Procedure Implementation

WORK ORDERS AND DRAWINGS

Number Description or Title Revision

Work Order (WO) Replace Grounded B RR Pump Motor

01277109

WO 00336929 MM Inspect System Dryer/Separator Strongback

/PMRQ 156877

WO 00014659 MM Inspect Strongback Carousel Hoists,

/PMRQ 156886 Tensioners

Training Request Chemistry CRC - The use of Fixatives Revision 0

2010-02-0013A

Training Request Chemistry CRC - The use of Gel Fixatives Revision 0

10 Attachment

WORK ORDERS AND DRAWINGS

Number Description or Title Revision

2010-02-0012A

CONDITION REPORTS GENERATED DURING INSPECTION

Number Description or Title

AR 1223508 Computation Error in IR 919673

AR 1217584 Closure of IR 670088 Action 04 not Clearly Documented

AR 1223723 NRC PI&R: WO 988866-99 Has Two NDE Exams for Same Item

AR 1223512 NRC Identified Issue With WO Documentation

AR 1221646 NRC PI&R: Root Cause 972235 Does Not Have EFR As Required

AR 1221661 NRC PI&R: Root Cause 979700 Does Not Have EFR As Required

AR 1223806 NRC PI&R EFRs Not Identified As Required

AR 1224527 NRC PI&R: As-Found LRT For Each MSIV Not Performed In C1R12

AR 1223723 NRC PI&R: Inaccuracies in Reproduced Document

AR 1223508 1AP9EH227X1 NRC PI&R Issue - Computation Error in IR 919673

AR 1226340 Maximum Steady State Voltage for TS 3.8.1 Nonconservative

AR 1224313 TS 3.8.1 Design Basis/Licensing Basis Inconsistency

AR 1225436 Inaccurate Information Provided to NRC in License Amendment

AR 1224057 (NRC Identified) Issue Identified with PMRQ

11 Attachment

LIST OF ACRONYMS USED

ADAMS Agencywide Document Access Management System

AR Action Request

ASME American Society of Mechanical Engineers

CA Corrective Action

CAP Corrective Action Program

CAPR Corrective Action to Prevent Recurrence

CDBI Component Design Basis Inspection

CPS Clinton Power Station

CFR Code of Federal Regulations

DC Direct Current

DG Diesel Generator

DRP Division of Reactor Projects

EACE Equipment Apparent Cause Evaluation

ECP Employee Concerns Program

EDG Emergency Diesel Generator

EFR Effectiveness Review

FASA Focused Area Self Assessment

FSAR Final Safety Analysis Report

IEMA Illinois Emergency Management Agency

IMC Inspection Manual Chapter

IP Inspection Procedure

IR Inspection Report

ISI Inservice Inspection

kV Kilovolt

LCO Limiting Condition for Operation

LLRT Local Leak Rate Testing

LOOP Loss of Offsite Power

MRC Management Review Committee

MSIV Main Steam Isolation Valve

MSL Main Steam Line

N/A Not Applicable

NCV Non-Cited Violation

NDE Nondestructive Examination

NOS Nuclear Oversight

NRC U.S. Nuclear Regulatory Commission

OE Operating Experience

PARS Publicly Available Records System

PI&R Problem Identification and Resolution

PMRQ Preventative Maintenance Request

RAT Reserve Auxiliary Transformer

RCR Root Cause Report

RFP Reactor Feed Pump

RHR Residual Heat Removal

RR Reactor Recirculation

SCWE Safety-Conscious Work Environment

SDP Significance Determination Process

SOC Station Oversight Committee

TS Technical Specification

UV Undervoltage

12 Attachment

Vdc Volts Direct Current

WO Work Order 13 Attachment

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

DISTRIBUTION:

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DOCUMENT NAME: G:\DRPIII\1-SECY\1-WORK IN PROGRESS\CLINTON BIENNIAL PIR 2011.DOCX

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl

"E" = Copy with attach/encl "N" = No copy

OFFICE RIII E RIII E RIII RIII

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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