ML20058N813

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Package Consisting of App a to Ti 2500/028, Employee Concerns Programs
ML20058N813
Person / Time
Site: Clinton Constellation icon.png
Issue date: 08/24/1993
From: Brush F
NRC
To:
References
NUDOCS 9312220275
Download: ML20058N813 (4)


Text

{{#Wiki_filter:. .. d - Attachment 1 TI 2500/028 Appendix A EMPLOYEE CONCERNS PROGRAMS f PLANT NAME:_Clinton LICENSEE:_Ill . Power _ DOCKET #:_50-461 NOTE: Please circle yes or no if applicable and add comments in the space , provided. i A. PROGRAM:

1. Does the licensee have an employee concerns program?

(Yes E No/ Comments) - Yes. They have a number of methods for

  • personnel to identify concerns. Two main ones are the Quality Concern Hotline and Quality Report System. The hotline is an answering machine and the report system is forms with suggestion type boxes placed around the site. ,

Other methods include face-to-face meetings with corporate officers, ' and minority, union, employee issues, and women's comittees.

2. Has NRC inspected the program? Report # N0 ,

B. SCOPE: (Circle all that apply) .

1. Is it for:
a. Technical? (Yes, No/ Comments) YES i
b. Administrative? (Yes, No/ Comments) YES
c. Personnel issues? (Yes, No/ Comments) YES
2. Does it cover safety as well as non-safety issues?

(Yes E No/ Comments) YES  ;

3. Is it designed for:

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a. Nuclear safety? (Yes, No/ Comments) YES
b. Personal safety? (Yes, No/ Comments) YES
c. Personnel issues - including union' grievances? l (Yes o_t No/Coments) YES - However, union grievances are turned -

over to labor relations with a response to the person. t I 8

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200006 d W\ 9312220275 930824 ^ \ PDR ADOCK 050004 1.- P -

F Attachment 1 .

4. Does the program apply to all licensee employees? .

(Yes or No/ Comments) YES , 4

5. Contractors?

(Yes or No/ Comments) YES 4 l.

6. Does the licensee require its contractors and .their subs to have a similar program? ,

(Yes or No/ Comments) NO- .

7. Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns?

(Yes or No/ Comments) YES - Done by employee relations. - i C. INDEPENDENCE: l

1. What is the title of the person in charge?

Manager - Nuclear Assessment e

2. Who do they report to?

Senior Vice President ' P

3. Are they independent of line management?

YES

4. Does the ECP use third party consultants?

YES .

5. How is a concern about a manager or vice president followed up?

i It is taken to the next higher level, bypassing _the person. - D. RESOURCES:

1. What is the size of staff devoted to'this program?

One full time person. Various people used for investigations depending .; on the subject area. L

2. What are ECP staff qualifications (technical training, interviewing training, investigator training, other)? i Personal integrity is the number one qualification.

A private-investigator is sometimes used. The majority of the investigations are done by people in the nuclear assessment group. p a E. REFERRALS: i

1. Who has follow-up on concerns (ECP staff, line management, .

Other)? ECP Staff. ' t 9 s

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Attachment 1 F. CONFIDENTIALITY:

1. Are the reports confidential?

(Yes or No/ Comments) YES

2. Who is the identity of the alleger made known to (senior management, ECP staff, line management, other)?

(Circle, if other explain) ECP Coordinator, typist, Senior VP, Manager - Nuclear Assessment, Supervisor - Quality Systems

3. Can employees be:
a. Anonymous? (Yes, No/ Comments)

YES

b. Report by phone? (Yes, No/ Comments)

YES G. FEEDBACK:

1. Is feedback given to the alleger upon completion of the follow-up?

(Yes or No - If so, how?) YES - By written report unless they don't want one, then a copy of the response just goes to file.

2. Does program reward good ideas?

N0

3. Who, or at what level, makes the final decision of resolution?

Senior Vice President

4. Are the resolutions of. anonymous concerns disseminated?

Yes - unless it involves a personnel attack or it involves redundant concerns such as the smoking policy.

5. Are resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)? YES H. EFFECTIVENESS:
1. How does the licensee measure the effectiveness of the program? 4 By trending and reviewing the issues.
2. Are concerns:
a. Trended? (Yes or No/ Comments) YES N
b. Used? (Yes or No/ Comments) YES_  !

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.. i Attachment 1

3. In the last three years how many concerns were raised? 649 Closed? 642 What percentage were substantiated? Don't know, but they are looking at that.
4. How are follow-up techniques used to measure effectiveness (random survey, interviews, other)? No formal mechanism. There is.

i some follow-up if the allegation was not anonymous.

5. How frequently are internal audits of the ECP conducted and 'by '

whom? No formal audits have been conducted t I. ADMINISTRATION / TRAINING:

1. Is ECP prescribed by a procedure? (Yes or No/ Comments) YES
2. How are employees, as well as contractors, made aware of this program (training, newsletter, bulletin board, other)?

General Employee Training and bulletin boards. The person completing this form please provide the following information to the Regional Office Allegations Coordinator and fax it to Richard Rosano at 301-504- ' 3431. NAME: TITLE: PHONE #: Frank Brush __/Res. Insp. /217-935-9521_ DATE COMPLETED:8/24/93_ l 1 l s l

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                               ,,                  NUCLEAR RESULATORY COMMISSION                         ~
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SEP 2 81993 1 Docket No. 50-461 Illinois' Power Company ATTN: Mr. J. S.' Perry.. ^

                                  - Senior Vice President

_ Clinton-Power Station' f Hail Code V-275~ Post Office Box 678  ; Clinton, IL 61727

SUBJECT:

NRC It!SPECTION REPORT NO. 50-461/93017(DRP)'

Dear Mr. Perry:

This refers to the inspection conducted by Messrs. P. G. _Brochman, F. L. Brush;- '

                      -and C. J. Phillips of this office on August 10 through September 13, 1993. LThe                                              ;

inspection included a review of authorized activities i for:your Clinton Power ~ Station facility. At the conclusion of the - inspection, the f findings were  ; discussed. with those members of your staff identified _in 'the enclosed _ report. 1 Areas examined during the inspection are identified in the report. Within these'. < - areas, the inspection consisted of a selective examination of proceduresf and representative records, observations of activities in progress, and' interviews. with personnel. 3 No violations Ef NRC requirements _ were identified during the course Lof this " inspection. However, weido nota two areas for your continued attention. First . the depthl of:

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the engineering department's recent evaluations of;the_ plant., fire zone _ loadings! and the- pressure transients in the shutdown L service water systemlwas; good. ' However, the initial evaluation of the pressure transient issue:in' 1991 and-1992-. was weak. .. Second,_ information obtained by quality assurance ~ inspectors was not-always-included in final audit reports. While the responsible supervisor was: > aware of_ the concerns, senior management was not and missed _ opportunities to gain; la1better. understanding of-the facility and'.its personnel. '

                    -In accordance with:10 CFR 2.790.of the Commission's regulations, a copy of this:

letter and the. enclosed inspection report will' be placed :in the: NRC- Public a Document. Room. j

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e Q-Illinois Power Company 2 SEP 2 81993 We will gladly discuss any questions you have concerning this inspection. Sinc , chard . agu Chief Reactor Pro ett Section 1C

Enclosures:

Inspection Report No. 50-461/93017(DRP) cc w/ enclosure: l J. Cook, Vice President and Manager, Clinton Power Station i R. Phares, Director, Licensing  : OC/LFDCB Resident Inspectors, Clinton,  ! Dresden, LaSalle, Quad Cities Licensing Project Manager, NRR I J. W. McCaffrey, Chief, Public .; Utilities Division ~i R. Newmann, Office of Public Counsel, State of Illinois Center S. Zabel, Esquire, Schiff, Hardin & '1 Waite K. Berry, Licensing Services Manager, General Electric Company j Chairman, DeWitt County Board  : State Liaison Officer Chairman, Illinois Commerce Commission R. Rosano, NRR

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,1 Q U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-461/93017(DRP) Docket No. 50-461 License No. NPF-62.

     <ticensee:     Illinois Power Company                                              '

500 South 27th Street  : Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: August 10 - September 13, 1993 Inspectors: P. G. Brochman F. L. Brush C. J. Phillips i r ApprovedBy:RichardL.ha%e, Chief fM7 Date-Reactor ProJ(cts Section IC Inspection Summary Inspection from Auaust 10 throuch September 13. 1993. (Recort No. 50-461/93017 (DRP)) Areas Insoected: Routine, unannounced safety inspection by the resident inspectors of licensee actions on plant operations, maintenance, engineering, and plant support. Results: No violations or deviations were identified. 1 O s #N

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Executive Summary  : 1 Plant Operations  !

  • As of the end of the report period, the plant was at 90 percent power and 'I coasting down in preparation for the September 26, 1993 refueling outage. l l

Enoineerino The licensee completed a substantial reevaluation of the fire loading calculation for the plant. One calculation was in error.for the Division 1 III battery room. The licensee implemented compensatory fire watches'and I initiated a modification to install a smoke detector.

  • The licensee completed extensive testing of the Division III shutdown '

service water system (SX) and concluded that the closing speed for several , flow control valves was too fast. The high closure speed was believed to , be the initiator for the hydraulic transients observed on the SX system. The closure speed was decreased. The licensee's initial actions to ' address this issue---2 years ago---were weak. l Plant Support Problems found during quality assurance audits were not being included in i the final audit report. Radiation Protection's control of radiography-was very good. o l 2

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    .-                                                                                   L F                                             DETAILS                                     '

I. Persons Contacted Illinois Power Company (lP)

            *J. Perry, Senior Vice President J. Cook, Vice President and Manager of Clinton Power Station (CPS)

J. Miller, Manager - Nuclear Station Engineering Department (NSED)

            *R. Wyatt, Manager - Quality Assurance                                     .,
            *D. Thompson, Mantger - Training                                             i
            *J. Palchak, Manager - Nuclear Planning and Support                          .
            *F. Spangenberg, III, Nuclear Strategic Change leader                        .
            *R. Phares, Director - Licensing L. Everman, Director - Radiation Protection
            *P. Yocum, Director - Plant Operations
            *W. Clark, Director - Plant Maintenance K. Moore, Director - Plant Technical W. Bousquet, Director - Plant Support Services
            *C. Elsasser, Director - Planning & Scheduling                               !

R. Kerestes, Director - Nuclear Safety and Analysis

            *D. Korneman, Director - Systems and Reliability, NSED
           *J. Langley, Director - Design and Analysis, NSED                             ,
           *K. Graf, Director - Engineering Projects, NSED
           *J. Sipek, Supervisor - Regulatory Interface D. Smith, Supervisor - Security R. Rod, Supervisor - Outage Planning J. Taylor, Supervisor - Nuclear Support Services                           4 The inspectors also contacted and interviewed other licensee and contractor personnel during the course of this inspection.

Denotes those present during the exit interview on September 13, 1993.

2. Action on Previous Insoection Findinos (Closed) Inspection Follow-up Item (461/93009-03(DRP)): What was the cause of pressure transients in the shutdown service water (SX) system?

Based on the concerns identified by the resident inspectors and the failure of the divider plate on a VC chiller, the licensee instrumented the SX system and performed testing to identify any possible pressure transient initiators. The -licensee determined that the flow control valves for the Division III switchgear chiller (VX) and control room chiller (VC) heat exchangers closed too fast. These valves were operated by hydramotor actuators and the rapid closing caused a pressure transient in the SX system. 3

th This was the probable cause of the bent divider plates in the VC chiller and the lifting of the Division III SX relief valve. - The- licensee analyzed the test data and concluded that the system pressure did not . exceed the ASME code' limit for the piping. The licensee intended to adjust the. closure times on the valves to minimize any pressure transients. The inspectors reviewed the- licensee's analysis and corrective actions and have no further concerns in' this matter. However, other aspects of the licensee's performance on this issue are discussed in paragraph 5.b. , No violations or deviations were identified.

3. Plant Operations .

The unit was online the entire report period and was at 90 percent power on September 13, 1993, coasting down in preparation for the . fourth refueling outage. Operational Safety (71707) The inspectors observed control room operation, reviewed applicable logs, and conducted discussions with control room operators. During these discussions and observations, the operators were alert, cognizant of plant-conditions, attentive to changes in those conditions, and took prompt " action when appropriate. The inspectors verified the operability of < selected emergency systems, reviewed tagout records, and verified the proper return to service of affected components. No violations or deviations were identified.

4. Maintenance Observations Of Work Activities The inspectors observed maintenance and surveillance activities of both safety-related and nonsafety-related systems and components listed below. .

These activities were reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes or standards, and in conformance with technical specifications. Document Activity 9080.01 Division I DG Operability Test D33023 Fabrication of Piping for Modification RT033 D33024 Fabrication of Piping for Modification RT034 No violations or deviations were identified.

     ' American Society of Mechanical Engineers, Boiler and Pressure Vessel Code        !

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5. Enoineerina
a. Division III 9attery Room Smoke Detector 'I
                                                                                                        .l In 1992, the licensee initiated an extensive project to recalculate              'j the loadings for 128 plant fire zones.          During this effort, L it-             ;

determined that the original calculations for the : Division III-battery room were non-conservative. The actual fire loading was determined to be 87,000 Btu /ft*, instead 'of 29,000 Btu /ft'. Thel original. calculations had been a basis for a deviation.to Section-1 III.F of 10 CFR Part 50, Appendix R, which required an Dautomatic. l fire detection system be installed in- areas that contain: safe' shutdown or safety-related equipment. As a result of. its 'new .! calculations, the licensee determined that the room required a fire l detector. As corrective' action,. the licensee implemented - compensatory measures and created a modification .to install' a fire - detector in the battery room. The licensee intended to install the I detector by June 1994.

b. Shutdown Service Water (SX) Pressure Transients j In late 1991, the inspectors noted that the SX relief valve  :

(ISX154C) on the Division III switchgear room heat exchanger  ; ap, neared to have lifted. This .information was . given _ to the. , licensee. The licensee evaluated the condition; however, a root , cause for the relief valve lifting was not initiated at= that ' time. ' In 1992, the inspectors again noted that the valve appeared to have'  : lifted. This time the licensee removed the valve and bench tested , it. During' the test, the valve twice lifted slightly below its - , setpoint of 170 psig and once at the normal setpoint. The licensee- ' replaced the valve. The licensee also walked down this portion of - 1 the system and did not observe any damage to piping, hangers, or i embedments. No further actions were taken. A detailed walkdown of- , the SX system had been performed by Sargent & Lundy engineers in -{ early 1991 as part of another issue. No problems were'. observed at-- 1 th + time.  ! In tarly 1993, the inspectors again noticed water weeping from the. ISX154C's discharge tailpipe. Based on the latest' NRC-observations and its own identification of a bent divider plate on the "A"  : control room chiller's (VC) heat exchanger, the licensee undertook l a thorough analysis of the SX system. The licensee instrumented the - j SX system and performed testing to identify any possible pressure d transient initiators. Analysis of the. test data indicated that a i possible cause of the pressure transient was the: chillers' flowi 'l control valves stroking too quickly. The hydramotor actuators fore these valves stroked open slowly, but closed at the origina1' maximum factory speed. The licensee has changed the speed of the-actuators to correct the problem. I

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y P The inspectors expressed concern to engineering management that its - I initial rssponse to this -problem in 1991 and 1992 was _ poor. This  : was based on the inspectors conclusion that the pressure necessary  ; to lift the relief valve,. relative to the nominal system pressure at t that elevation' (120 psig ninus 27 psig equaling 93 psig) was 83 percent' higher. However, the . latest testing, analysis, and corrective actions appeared to be very good. The inspectors have no further concerns on this matter. ' No violations or deviations were identified.

6. Plant Succort i
a. Evaluation of Licensee Self-Assessment Capability (40500)

The inspectors reviewed three quality assurance audit reports and their associated audit check lists. The inspectors noted that problems found during the audits and listed on the audit check lists a were not included in the final audit report. The inspectors expressed concern to quality assurance management that by not including this information in the audit reports, senior. plant management would receive a distorted appraisal of plant and personnel performance. Two examples of this were: In audit Q38-93-15, ' Nuclear Program Procedures", the auditor indicated there was a possible programmatic problem relating to the procedures involved with parts replacement based on~ his observations and that there were 22 condition reports relating to parts problems. This information was not indicated in the-final audit report. In audit Q38-93-11, " Plant Staff Operations and Operations Support", the audit checklist stated that standing night orders were used in lieu of procedures in the radwaste operations center. The checklist cited'several examples of this. This indicated that some procedures were not useable - and were being circumvented routinely. _This information was not reflected in the report nor was a condition report written: for the problem. Subsequent discussions with operations management indicated that they were aware of this problem and were taking action to correct it. Licensee management acknowledged that a better job should have been  ; done in including this-type of information in the report and have taken steps to correct the situation. The inspectors will continue to review the licensee's efforts in this area. - l 6

4, i t , h b. Radiation Protection The inspector observed radiography activities for three welds which I had been fabricated for an upcoming modification. The inspector i attended the pre-job briefing and ALARA review. The briefing was  ! very thorough and addressed the expected hazards, estimated . dose levels, access control, and contingency procedures. The inspectors observed the job site, perimeter control, placarding, . communications, use of monitoring instruments and dosimetry,. and  : safety techniques. Problems with monitoring equipment were promptly l identified and addressed. Overall, the inspector concluded that the licensee had done an excellent job-in preparing for and performing  : the radiography.

c. Temporary Instruction (TI) 2500/028 - Employee Concerns proaram The inspectors reviewed the licensee's employee concerns program as requested by the subject TI. On August 24, 1993, the requested information was sent to RIII. The information is attached to the report. The inspectors did not identify any concerns. .

No violations or deviations were identified.

7. Exit Interview '

The inspectors met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on September 13, 1993. The inspectors summarized the purpose and scope of the inspection and the findings. The inspectors also discussed the likely informational content of the inspection report, with ~ regard to documents or processes reviewed by the-inspectors during the inspection. The licensee did not identify any such documents or processes as proprietary. .,

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Attachment:

Temporary Instruction 2500/028, Appendix A ' G h I 7 ,

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