IR 05000461/1985001
| ML20137Q615 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/22/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137Q607 | List: |
| References | |
| 50-461-85-01, 50-461-85-1, NUDOCS 8512050322 | |
| Download: ML20137Q615 (45) | |
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U. S. NUCLEAR REGULATORY COMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE I
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50-461/85001
Inspection Report
Illinois Power Company
Name of Licensee
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Clinton Power Station
Name of Facility
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March 1, 1984 -'Au3ust 31, 1985
Assessment >eriod
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8512050322 851122
ADOCK 05000461
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I.
INTRODUCTION'
.The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect.available observations and data on
a periodic basis and to evaluate licensee performance based upon this
information~
SALP.is supplemental to normal regulatory processes used to
ensure compliance to NRC rules and regulations.
SALP is intended to be
.
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant construction and operation.
A NRC SALP Board, composed.of staff members listed below, met on
October 16, 1985, to review the collection of performance observations
and data to assess the licensee's performance in accordance with the
guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee
Performance." A summary of the guidance and evaluation criteria is
provided in Section-II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Clinton Power Station for the period March 1, 1984 through
August 31, 1985.
SALP Board for Clinton Power Station:
C. Norelius, Director, Division of Reactor Projects, (Acting SALP Board
Chairman)
R. Warnick, Chief, Reactor Projects Branch 1, Division of Reactor Projects
H. Livermore, Senior Resident Inspector, Vogtle (former Senior Resident
Inspector,Clinton)
P. Hiland, Resident Inspector, Clinton
F. Jablonski, Clinton Project Inspector, Division of Reactor Projects
C. Paperiello, Director, Division of Reactor Safety
J. Streeter, Technical Assistant, Division of Reactor Safety
J. Harrison, Chief, Engineering Branch, Division of Reactor Safety
C. Williams, Chief, Plant Systems Section, Division of Reactor Safety
R. Love, Reactor Inspector, Plant Systems.Section, Division of Reactor
Safety
S..DuPont, Reactor Inspector, Test Programs Section
W. Shafer, Chief, Emergency Preparedness and' Radiological Protection
Branch, Division of Radiation Safety and Safeguards,.(DRSS).
M. Schumacher, Chief, Radiological Effluents and Chemistry Sectior., DRSS
J. Creed, Chief, Safeguards Section, DRSS
G.' Pirtle, Physical Security Inspector, Safeguards Section
W. Butler, Chief, Licensing Branch 2, NRR-
B. Siegel, Project Manager, NRR
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D. Humenansky, Technical Assistant to Commissioner Zech, OCM
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II.
CRITERIA
The licensee's performance is assessed in selected functional areas
depending on whether the facility is in a construction, preoperational,
or operating phase.
Each functional area normally represents areas
significant to nuclear safety and the environment, and are normal
programmatic areas.
Some functional areas may not be assessed because
of.little or no licensee activities or lack of meaningful observations.
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Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each
functional area.
1.
Management involvement in assuring quality
2.
Approach to resolution of technical issues from a safety standpoint
3.
Responsiveness to NRC initiatives
4.
Enforcement history
5.
Reporting and analysis of events
6.
Staffing (including management)
7.
Training effectiveness and qualification.
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board's assessment, each functional area evaluated is
classified into one of three performance categories.
The definition of
these performance categories is:
Category 1:
Reduced NRC attention may be appropriate.
Licensee
management attention and involvement are aggressive and oriented
,
toward nuclear safety.
Licensee resources are ample and effectively
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used so that a high level of performance with respect to operational
safety or construction is being achieved.
Category 2:
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and management
is concerned with nuclear safety.
Licensee resources are adequate and
are reasonably effective such that satisfactory performance with respect
to operational safety'or construction is being achieved.
Category 3:
Both NRC and licensee attention should be increased.
Licensee management attention and involvement is acceptable and considers
nuclear safety, but weaknesses are evident.
Licensee resources appear to
be strained or not effectively used so that minimally satisfactory
performance with respect to operational safety or construction is being
achieved.
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Trend: The SALP. Board has also categorized the performance trend in
each functional' area rated over the' course of the SALP assessment period.
'The categorization describes the general or prevailing tendency (the
performance gradient) during the SALP period.
The performance trends
are defined as follows:
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Improved:
Licensee performance has generally; improved over the course
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lof the SALP assessment period.
uSame:
Licensee performance has remained essentially constant over
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-the course.of the SALP assessment period.
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Declined:
Licensee performance.has generally declined over the course
of the SALP assessment period.
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III. SlM4ARY 0F RESULTS
Licensee' performance.was analyzed-in fourteen functional areas and
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determined =to be acceptable.
Performance showed an overall improving
trend. The licensee has shown aggressive management attention and a
high level of-performance in the functional areas.of Containment and
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Other Safety-Related Structures,LPiping Systems and Supports, and
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Licensing Activities.
Additional management attention is warranted in
the functional areas of Radiological Controls, Preoperational Testing,
and Security.in preparation.to receive a license for loading fuel.
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Continued management' attention should also be given to the followup of
- allegatio'ns.
Increased management attention to all areas of performance
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-has been apparent ~during the latter part of the assessment period.
Licensee management has been responsive to NRC findings and concerns;
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however,' increased attention to. details is warranted in initial responses
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to violations, Bulletins, 50.55(e) reports and other submittals to the
Region.
Rating Last
Rating This
Functional Area
Period
Period
Trend
A.
Soils and
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Foundations
NR
None
B.-
Containment and Other
-Safety-Related
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Structures.
1
Improved
C.
-Piping Systems
and Supports
1
Improved
D.
-Safety-Related
Components-
2
Same
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E.
Support Systems
2
Improved
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F.
Electrical. Power Supply-
and-Distribution
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2
Same
G.
Instrumentation'and
Control Systems
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'Same
H.
Quality Programs and~
Administrative Controls
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2-
Same
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- Affecting Quality
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Preoperational Testing
'2
Same
.J.
Radiological Controls
-2
Same:
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-Security
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Improved.
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Operational Readiness
NR
None
' M.
Licensing Activities
1
Improved
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N.
Overinspection
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Same
- NR - Not rated because of-limited work and inspection activity.
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IV.. PERFORMANCE ANALYSIS'
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A.
Soils and Foundations
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1.
Analysis.
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Examination cf this functional. area consisted of portions of
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one inspection by region-based inspectors, two inspections by
resident-inspectors, and a portion of the NRC Construction
Appraisal Team (CAT) inspection.
Areas examined in::1uded (1)
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soil stabilization activities on the plant sit (-
proper and at
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the Clinton Lake Dam, and (2) a review of earthwork logs for
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safety-related Class B structural fill.
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Little or no safety-related soils work was in progress during
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-the assessment period and inspection effort in this functional
area was limited to reviewing quality records documenting earth
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. fill and geotechnical construction. The NRC inspector's review
was incomplete-in this area because the licensee did not have
information-at hand to clarify several general questions.
The
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questionable'_ areas involved QA records to verify that lift
thicknesses,-densities, material qualities and inspection
frequencies, did in fact, meet specifications and procedures.
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The licensee indicated that adequate clarity could be provided
and the data would be assembled for review. The item was left
open for further review.
During the CAT inspection this same
matter was still open.
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One violation was identified by the CAT inspection in regards
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to the adequacy of soils records:
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Severity-Level IV - failure to implement _ adequate corrective
action for' nonconforming soils: test records.
(50-461/85030).
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This violation was significant because the licensee had
identified the problem nine months prior to the CAT inspection
but had failed to provide a timely resolution ~to the problem.
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Management attention was. directed.toward stabilization of plant
environs.'. Work.in progress both onsite and at the Clinton Lake
a
Das was evidence'of a continuing commitment to prevent' soil
erosion.
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No allegations were reviewed in this functional area.
2.'
Conclusion
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- Licensee performance
- is rated Category 2 in th'is functional
. area.
Licensee performance was not rated in.the previous
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assessment period.
No trend was'_ identified.
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3.
Board Recommendations
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NRC should perform a followup inspection to assure foundation
adequacy and licensee compliance in the geotechnical area.
B.
Containment and Other Safety-Related Structures
1.
Analysis
Examination of this functional area consisted of ten inspections
by region-based inspectcrs, portions of four inspections by
resident inspectors, and a portion of the NRC CAT inspection.
Areas examined included:
(1) structural steel field verification
and overinspection activities; (2) a field walkdown to compare
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as built conditions with design and records for the fabrication
and erection of structural steel in the Auxiliary Building and
Containment; (3) observation of completed work and selected
records for containment penetrations; (4) licensee actions
related to previous inspection findings and 10 CFR 50.55(e)
items; (5) in process welding, bolting, containment penetration
sealing, and verification of weld filler metal controls;
(6) welding and nondestructive testing activities associated
with structural steel fabrication, erection, and modification;
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(7) fuel storage pool and refueling cavity liner fabrication;
(8) containment liner and containment penetration installation;
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(9) drywell wall and penetration installations; (10) reinforced
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concrete construction and structural steel installation; and
(11) allegations brought to the attention of the NRC.
One violation was identified during the assessment period in
this functional area:
Severity Level IV - failure to implement adequate corrective
action for inadequate cadweld operator test frequency
(50-461/85030).
This violation was considered significant because of the lack
of timely corrective action by the licensee but not significant
in regards to the total cadweld operator testing program.
There
was no problem ~ identified with the tensile strength requirements
of the cadwelds themselves.
Other NRC inspections in this area
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did not result in any violations.
During the assessment period the adequacy of control over
drilling and coring activities was assessed to assure that
pertinent information regarding damaged reinforcing steel was
properly documented and dispositioned by the licensee and design
engineers to ensure adequate structural integrity.
No problems
were identified.
During the assessment period, portions of three inspections
were devoted to the Overinspection Program of items in this
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functional area. The inspection performed early in the
assessment period of several thousand welds reported that in
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-many. cases reinspections were overly conservative and site
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inspectors were identifying. weld attributes as unacceptable
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which, in fact, were acceptable.
Another NRC inspection
reported in this. functional area that requirements were being
met. - Late in the assessment period the NRC learned that
approximately one_ third _of the accessible category 1 structural
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steel beams were not.in the Overinspection Program. The NRC
questioned this exclusion and was pursuing resolution of this
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issue at the end of the assessment period. The NRC has expended
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considerable time on overinspection activities in this
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functional area.
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During the assessment period, three allegations perta ning to
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this functional area were reviewed.
The three allegations
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primarily related to:
(1) control elevation markers being off
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tros the true location; (2) concrete expansion anchors were
incorrectly installed; and (3) overinspections in the area of
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structural steel were of questionable quality. A re-survey of
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the elevations in question established that the control markers
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were within. practical surveying tolerances.
Incorrect
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installation of expansion anchors was substantiated; however
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a.10 CFR 50.55(e) report had been issued for this deficiency
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and acceptable corrective action was taken by the licenste and
verified by the NRC. The specific example of questionable
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overinspection of structural steel cited by the alleger was
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substantiated; however, upon the NRC inspector's review of a
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random sample of the overinspection effort, no trend of
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inadequate inspections could be found.
The allegation was
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confirmed but appeared to be an isolated case.
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For this functional area, the' inspectors determined that
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management involvement and control was such that decisions
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consistently were made at a level ensuring adequate management
review.. Reviews were; timely, thorough, and technically sound.
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Records were complete, well maintained, and available.- The
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licensee's approach to resolution of technical issues from a
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safety standpoint routinely exhibited conservatism.
Enforcement
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history was good, that is. there were no major violations and
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only one nonrepetitive minor violation.
The' previous SALP report noted two open problems:
(1) failure
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to report a problem via the:50.55(e). system, and (2) failure to
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perform prompt corrective action in regards to a containment.
liner weld.
Subsequent action by the licensee indicates that
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the site reporting system worked properly, that careful exami-
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nation of the weld discontinuity indicated chewing gun was
placed on-the weld after pair. ting and inspection, and was,
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therefore, not an attempt to mask the weld.- Corrective action
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by the licensee was intensive and satisfactory.
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_2.
Conclusion
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Licensee performance is rated Category 1 in this area. The
licensee was rated. Category 2 during the previous assessment-
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period.
Licensee performance improved during the assessment
period.
3.
Board Recommendations
None.
C.
Piping Systems and Supports
1.
Analysis
Examination of this functional area consisted of thirteen
inspections by region-based inspectors, portions of eight
inspections by resident inspectors, and a portion of the NRC
CAT inspectior.. Areas examined included (1) piping and support
. installations and field verification /overinspection activities;
(2) revicw of discrepancies and engineering dispositions
performed regarding large bore piping, small bore piping, and
pipe support overinspection deficiencies; (3) preservice
inspection of pressure retaining components; (4) review of
selected piping weld repair records; (5) reactor coolant system
and connecting system hydrostatic testing activities; (6)
independent verification inspection of construction activities
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and materials using the NRC NDE van and contractor technicians
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under NRC direction; (7) licensee actions related to previous
inspection findings including 10 CFR 50.55(e) and 10 CFR 21
items and IE Bulletins; (8) material storage; (9) energy
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absorbing material'in pipe whip restraints; (10) installation
of concrete expansion anchors and diesel generator exhaust
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silencer supports; and (11) allegations brought to the
attention of the NRC.
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Three violations were identified as a result of NRC inspections
as follows:
a.
Severity Level V - failure to follow procedures for
documenting an unacceptable condition during installation
of a pipe support.
(50-461/84028)
b.
Severity Level V - failure to identify excessive porosity
in a piping weld.
(50-461/84035)
c.
Severity Level IV - Licensee's program was not adequately
implemented in that there was a failure to model and
analyze two ASME Class I snubbers in accordance with
safety analysis report commitments.
(50-461/85030)
The licensee's initial response to the first violation was not
complete and required additional information in order to provide
an adequate basis for closure. The licensee, in each case,
conducted extensive reviews in response to the notice of
violation to determine the cause and properly correct the
deficiency.
No violation was repetitive from the previous
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assessment period and none appeared to have programmatic
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' Jmplicat.fons. Violation c. above was denied by the licensee
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aften.the%ssessment period ended.
NRC review of this matter
ha Vnot been completed.
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', Giu'ri5g t'he assessment period, thirty-three allegations pertaining
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to this functional area were reviewed.
The 33 allegations
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primarily related to:
(1) quality of piping and pipe support
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drawings,,weltis, and installations; (2) deficiencies in storage
and maintenance; (3) quality of vendor audits; (4) quality of
inspections by QC; (5) qualification of personnel; (6) adequacy
of as-built piping data; and (7) intimidation of welders and
inspectors.
Twenty-three of the allegations were not substantiated;
ten allegations were substantiated resulting in two violations
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' described in paragraph H.1.d and e.
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The signif,icance of the remaining substantiated allegations was
minimal 6ecause in several instances the licensee was aware of
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the problems and had taken appropriate corrective action, and
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in othevrinstances the person making the allegation was not
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1, aware o) the exist 3nce of specifications or procedures that
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controlled the activities in question.
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mIndependent mei urements made using the NRC Region I mobile NDE
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e n did not disclose any significant deficiencies. One minor
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violation (item b., excessive porosity) discussed above resulted
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in prompt action by the licensee to determine and correct the
root cause of the deficiency.
Results of the independent
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measurements clearly indicate an improvement in performance by
the, licensee in this functional area over the previous SALP
asiessment period.
An'ltem identified at another site that related to the use
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of potentially-defective energy absorbing materials in pipe
whip restraints was aggressively reviewed by the licensee and
dete~rmined not to be a problem at Clinton Power Station.
The
review and< testing program initiated by the licensee was very
responsive'to the NRC initiative, clearly demonstrated
management's desire to assure quality, and provided a sound
technical basis for resolution of the item.
For the areas examined, the inspectors determined that management
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control systems consistently showed evidence of prior planning
and, assignment of priorities.
Activities were controlled through
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the ape of well stated, disseminated, and understandable procedures.
Thed ic 6see's actions in response to NRC initiatives in almost
a1Y4ses indicated they understood the issues and their reviews
were timely, thorough, and technically sound. The approaches
used to evaluate verification /overinspection program discrepancies
demor%trated clear understanding of the issues, and were viable,
conservati'Je, technically sound, and thorough.
Records were
generally complete, well maintained, and available.
Records also
showed that the preservice inspection equipment and material
certifications were current and complete, and the personnel
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performing verification /overinspection program inspection,
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systems hydrostatic testing, and nondestructive examinations
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were trained and certified.
Audits and surveillances were
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- generally complete, timely, and thorough.
The violations
identified were minor, not repetitive, nor indicative of
. programmatic breakdown.
2.
Conclusion
Licensee performance is rated Category 1 in this area. The
licensee was rated Category 2 during the last assessment period.
Licensee performanca has been improving over the course of the
SALP assessment pe.iod.
3.
Board Recommendations
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',,, None.
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D.
Safety-Related Components
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1.
Analysis
Examination of this functional area consisted of two inspections
by region-based inspectors, portions of three inspections by
resident inspectors, and a portion of the NRC CAT inspection.
Areas examined were limited in scope and included:
(1) review
of previously identified items; (2) in process observation of
reactor pressure vessel (RPV) stud installation; (3) RPV
internals installation;.(4) installation and test of spent fuel
storage racks; (5) in process review of welding control for RPV
internals installation; (6) mechanical equipment installation
including emergency diesel generators, diesel generator fuel oil
day tanks, and standby liquid control pumps; (7) welding and NDE
records for reactor vessel internals modification and
installation; (8) visual inspection'and review of NDE records
for six vendor supplied tanks; (9) ~ routine tours of the
construction site to assess the adequacy of housekeeping,
storage, and maintenance conditions of materials and equipment,
and potential fort fire hazards; and (10) completed work and
selected quality: records related to material certification,
installation, and cleanliness of components installed in the
reactor recirculation system.
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One violation was identified during the assessment period, as
follows:
Severity Level' IV - failure to assure thdt vendor supplied
. tanks, heat exchangers, and radiographs conformed to
(50-461/85030)-
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This violation ha<l significance becaUse vendor procured tanks
and heat exchangers were accepted and installed with deficient
welds, and_some of the vendor radiographs.for the containment
liner and dry well wall area did not have the required weld and
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ifilm quality. This potentially generic problem has been
-brought to the attention of the NRC Vendor Program Branch and
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an Information Notice relating to the welds problems has been
-issued to licensees.
'In. general, housekeeping throughout the power block and site
storage areas has been adequate.
The licensee has been
responsive to NRC concerns during the assessment period when
- areas of the plant or a specific system were noted to be in a
degraded condition.
The licensee has established cleanliness
zones in the plant and has maintained adequate fire protection
during the assessment period.
The storage of material and the
maintenance'of plant equipment was satisfactory.
Additional
cornents-on plant housekeeping can be found in section L of
this report.
As noted in the previous SALP report, temporary "in' vessel"
' fuel. racks had numerous weld discontinuities, and nonconformance
reports associated with the racks had been incorrectly
.dispositioned. Actions to correct the problems included
. amending the Final Safety-Analysis Report to include the quality
- requirements and welding code applicability, redispositioning
the nonconformance reports, and repairing the weld defects.
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Inspection activities in this area were limited because con-
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struction was essentially completed.
For the areas examined,
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the inspector determined that the management control systems
imet regulatory requirements.
Records were complete, well
- maintained', and available.
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zNo allegations were reviewed-in.this functional area.
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'2.
Conclusion -
Licensee performance is rated Category 2 in this area.
This
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is the same rating as given in the previous assessment period.
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Licensee performance has remained essentially constant _over the
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course of-the SALP: assessment period.
3.
~ Board Recommendations
None.
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. E.
Support Systems
1.
Analysis
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Examination of:this-functional' area consisted of two inspections
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by region-based-inspectors.
Areas examined included:
(1)
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followup and review of licenseeL actions.regarding heating,
ventilation and air conditioning-(HVAC);.(2) review ~of a
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L10 CFR'50.55(e) report; (3) review of the implementation of.the
revised QA program since lifting Stop Work Orders 014,'015, and
020;
(4) procedures and instructions;~(5) welder qualification
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records; (6) inspector certification records; (7) indoctrination
and training of personnel; (8) identification and control of
materials and components; (9) selected nonconformance reports
and installation documentation; and (10) an as-built
verification of selected portions of the HVAC system.
No violations or deviations were identified.
For the areas e'xamined the inspector determined that activities
related to HVAC installation and inspection were controlled
through the use of well stated and defined procedures.
Observations of work indicate that personnel have an adequate
understanding of work practices and that procedures were
adhered to.
Records were found to be generally complete,
well maintained, and available.
The records also indicate
the personnel performing welding and QA/QC surveillances and
inspections were being properly trained and that they were
certified.
No allegations were reviewed in this functional area.
2.
Conclusion
Licensee performance is rated Category 2 in this area.
This is
the same rating as given in the previous assessment period.
Licensee performance has generally improved over the course of
the SALP assessment period.
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3.
Board Recommendations
None.
F.
Electrical Power Supply and Distribution
1.
Analysis
Examination of this functional area consisted of eight
inspections by region-based inspectors, portions of six resident
inspections, and a portion of the NRC CAT inspection. Areas
examined included:
(1) review of previous inspection findings;
(2) observations of raceway and equipment installations;
(3) observations of electrical cable installation and
terminations; (4) equipment storage and maintenance activities;
~
(5) training and qualification of personnel; (6) hanger
reinspection, field verification and overinspection activities;
and (7) followup on allegations brought to the attention of the
NRC.
Five violations were identified as follows:
a.
Severity Level IV - failure to provide adequate
dispositions on nonconformance reports.(four examples)
(50-461/85013).
.
~.
.
- -
.
-.
.
- - -
. _ _.- _ _
m
' b.
Severity Level IV - failure to effectively implement
'certain inspection activities (three examples)
.
(50-461/85030).
,
.
c.
. failure to verify the availability and
F
~ acceptability of vendor documentation (approximately 50
examples) (50-461/85041).
m.
d.
Severity Level V - failure to provide adequate procedures
and. failure to follow procedures (50-461/85042).
e.
Severity Level V - failure to provide adequate procedures
to implement the requirements of upper tier procedures
(50-461/85042).
i
The'first violation identified four NCRs that were dispositioned
" written in error" when in fact they were valid deficiencies.
,
-
The second violation identified the failure to assure that
safety-related raceway was installed in accordance with FSAR
.
commitments for electrical separation; the failure to assure
that only qualified materials are installed under that
Maintenance Work-Request Program; and the failure to assure that
.
required insulating materials had been installed on safety-
i
related SkV power cable terminations.
The third violation
. identified approximately 50 lastances where the completed
.
Documentation Checklist had been. removed from one receiving
i
report package, changes made, and inserted in another receiving
report package.The fourth violation identified that procedures
did-not address the.use of Potential Interaction Reports to
document _ multiple interactions requiring different dispositions
-
,
and-Interaction Reports =dispositioned use-as-is were closed
without reference to applicable calculations. The fifth
,
violation ~ identified the failure of QC_ inspectors to record the
presence of a QC accept stamp on subdivided materials.
Licensee
actions to correct these violations will be. reviewed during
subsequent inspections prior to fuel load. The violations were
.not repetitive of' violations identified during the previous
assessment period.
.As noted in the two previous SALP. reports, numerous problems
,
were identified with QA, QC, drawings,-installation of hardware,
and associated records. As a result of these problems, the
_ i
licensee-initiated a 100% reinspection program of cable tray
hangers installed prior to' June 28, 1982, (old work) and.an
j
,0verinspection Program described in; Paragraph N, of all-
r
-electrical and instrument and' control work activities. The-
'hangerLreinspection program involved ~approximately 5100 hangers
-
and is scheduled for completion'in 1985. -Inspections in this
.-area. indicated that the reinspection / rework program did -identify
- and resolve ~ hardware' deficiencies. The NRC will continue to
'
?' follow this program. LThe licensee has requested NRC concurrence
in terminating the Overinspection Program.
NRC is in the-
,
_ process of reviewing the data provided to substantiate the
i-
re_ quest for termination.
None of.the nonconformances. identified
t
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.
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.
.
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.
,
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'
'by overinspection in this functional area was safety-significant.
In addition to the reinspection /overinspection programs, the
licensee has implemented positive corrective actions in the
i
areasfofTaudits and documentation review by removing these
-
responsibilities from Baldwin Associates (except audits required
by the ASME program) and-placed these responsibilities under the
control of the licensee's QA program.
I
During this assessment period,'54 allegations pertaining to this
,
,
~ functional area were reviewed.
These 54 allegations primarily
'
.related to:
(1) material certification and traceability; (2)
'
'
electrical raceway support welding; (3) qualification, training,
and certification of personnel;'(4) discrimination, intimidation,
'
harassment, and blackballing of personnel; (5) violations of
1 procedures or changes to them;-(6) control and use of drawings
,
and documents; (7) push for production; and (8) disagreement
'with dispositions to nonconformance reports.
Nineteen
-
'
allegations were not substantiated. Thirty-five of the 54
_ allegations were substantiated, resulting in one violation as
'
described.in paragraph e. above.
Thirty-four substantiated
allegations did not result in violations.for one of the
- _
'following reasons; the' licensee was aware.of the problem but
-
had not completed corrective action; the alleger was not.
'
'
knowledgeable of procedures or specifications which satisfied
the concern; or the concern did not violate a requirement.
.
Corrective actions initiated by licensee management during
this period appear to have been effective. The inspectors
i
!:
determined that management generally provided timely resolutions
that~were acceptable. The licensee was responsive to NRC
. concerns and took appropriate corrective actions to resolve
specific and generic issues from a technical and safety
j=
standpoint.
2.
Conclusion
.
Licensee performance is rated. Category 2 in this area. This is
the same rating as the previous assessment period.
Licensee
- -
'
'
-performance has remained essentially constant over the course
.of the SALP assessment' period.
!:
- 3.'
-Board Recommendations-
None.
i:
!.,
G.
. Instrumentation and Control' Systems
!
'
[
1.
Analysis-
.
- -
~
_ Examination in thisLfunctional area consisted of significant-
l
l portions lof seven ' region-based inspections,- a'nd a portion of
'the NRCLCAT:1nspection.~1 Areas examined included: -(1) review of.
previous-inspection findings;-(2) observation of raceway and
t
I
(
q
.
, _
,
.
-_
a.
. _,
.
-
2.
.
.
...
,....
_
_
.
-
.
equipment installation; (3) observation of electrical cable
installation and terminations; (4) equipment storage and
maintenance activities; (5) observation of instrument sensing
line installation; (6) hanger reinspection, field verification,
and overinspection activities; (7) training and qualification
of personnel; and (8) followup on allegations brought to the
attention of the NRC.
This functional area was also involved in the licensee's
reinspection program of old work, field verification, and
overinspection.
Details of these programs were discussed in
Paragraph F.
None of the nonconformances identified by
overinspection in this functional area was safety significant.
Two violations were identified during the assessment period as
follows:
a.
Severity Level IV - failure to ensure that instrumentation
piping and fittings were protected from entry of foreign
material.
(50-461/84043)
b.
Severity Level V - failure to ensure that vendor documen-
tation was complete and acceptable.
(50-461/84043)
The first violation was indicative of recurring housekeeping
problems. As indicated in Paragraph L, housekeeping was
identified as a problem throughout'the plant.
Senior licensee
<
management was responsive and made good effort in correcting the
problem by establishing more restrictive cleanliness zones and
increased surveillances.
The licensee's response to the second
violation was not complete and required additional information
in order to provide an adequate basis for closure; however, this
failure of the vendor to sign and date documents appeared to be
an isolated case.
During this assessment period, 12 allegations pertaining to
this functional area were reviewed.
The allegations were in
regard to:
(1) qualifications ~of engineers; (2) lack of
permission to prepare Nonconformance Reports (NCRs) and Field
Change Requests-(FCRs); (3) " vaulting" travelers without
permanent hangers-being installed; (4) bend radius / ovality of
instrument' piping not inspected; (5) " sugaring" of stainless
'
steel. instrument tubing; (6) identical. tubing material
requisition ~ numbers;'(7) improper closure of NCRs;-
~
(8) termination of a field engineer; (9) use of "unstatused"
drawings and other drawing'contr'ols; (10) push for production;
(11) control nf. changes to procedures and other documents; and
(12) discrimination.
Seven allegations were not substantiated.
Four substantiated allegations did not result in violations for
one or more of the following reasons:
the alleger'was not
knowledgeable of'the procedure which satisfied the concern; the
licensee was aware of.the problem but had not completed
17-
__
_
corrective action; or tests showed that design loading was not
affected.
One allegation, discrimination, remained open pending
completion of the Department of Labor's review.
For the areas examined, the inspector determined that licensee
management's understanding of the issues was generally apparent.
Resolutions to problems were generally timely and corrective
actions effective.
It was also observed that, in general,
the licensee was responsive to inspector concerns and took
appropriate corrective action to resolve specific and generic
issues from a technical and safety standpoint.
2.
Conclusion
Licensee performance is rated Category 2 in this area. This
is the same rating as given in the previous assessment period.
Licensee performance has remained essentially constant over the
course of the SALP. assessment period.
3.
Board Recommendations
None.
H.
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
Examination of this functional area consisted of six inspections
by region-based inspectors, portions of ten inspections by
resident inspectors, and a portion of the NRC CAT inspection.
Areas examined included:
(1) operational QA program; (2) QA/QC
. administration; (3) QA for preoperational testing; (4) procurement;
(5) safety committee; (6) previously identified items; (7)
, review of licensee action on.IE Bulletins and Circulars; (8)
material traceability and control;-(9) control of design and
design change documents; (10)'and corrective action measures.
Significant deficiencies in the licensee's QA Program were
found by NRC inspectors in February 1981.
Cited problems were
identified with seismic Category 1 large bore pipe supports and
restraints design, fabrication, installation, and inspection.
The. licensee took action.to correct the deficiencies.
More
serious QA problems were discovered in December 1981.-
Allegations were made by electrical contractor employees to the
NRC.- In January 1982, all safety related electrical work was
ordered stopped by the licensee.~ Shortly thereafter work was
- ordered stopped by the licensee in the areas of heating,
-ventilating, and air conditioning; instrumentation; and
structural steel.
Representatives from the NRC met with senior
licen:;ee management personnel in. January 1982 to discuss the
j'
stop work orders and the licensee's recovery plan.
Additional
l
meetings between NRC and the' licensee have taken place since
l_
then on a recurring basis.' All work resumed by December 1983
L
after each affected area was reviewed and verified ready by.the
i
!
L
.
18..
!
.-
,
,
_
,-
.--
.
_
.
%
'
L
NRC..The meetings between-NRC and licensee management resulted
in the licensee's commitment to perform an overinspection of
!
completed work as further described in Paragraph N.
Five violations were identified during the assessment period in
,
j.
this functional area, as follows:
.
I
a.
Severity Level V - failure to followup on outstanding
document transmittals to verify receipt of current revision
of construction documents.
(50-461/84017)
I
b.
Severity Level V - failure to properly implement document
control procedures in the filing and updating of one copy
of the BA Project Procedures Manual, and in the posting of
design change documents in specifications.
(50-461/85030)
c.
Severity Level IV - bolting materials for mounting certain
plant equipt.ent were not as required by applicable drawings
and specifications.
(50-461/85030)
d.
Severity Level IV - failure to identify procedural
violations during quality review of documentation.
(50-461/84030)
e.
-Severity Level IV - failure to comply with the procedure
for documenting nonconformance reports.
(50-461/85026)
The first two violations showed generally good management
involvement in the resolution of the problem; corrective actions
were prompt.
The third violation concerned traceability and
control of fasteners and mounting bolts.
In general, it was
found that the traceability and control of material at the site
was satisfactory. LThe licensee has stated that their " Vibration
Monitoring" program would trend the performance of equipment
which exhibited the fastener deficiencies.
Review of this-item
was still open at the end of the assessment period.
The fourth
violation has significance because there were potentially
generic problems with the_ contractor's QA' organization final
review of documentation to assure.that work had been
accomplished in accordance with all procedural. requirements.
The-licensee's first; response'to-the violation did not
adequately respond to the stated problem; the second response
"
was satisfactory. The licensee determined that the incident was
. isolated to a single individual and event.
The fifth violation
was significant because' nonconforming hardware conditions were-
being resolved and corrected in~a way that circumvented the
established nonconformance-system. The extent of this problem
was being evaluated'by.the. licensee at the'end of the assessment
period.
During the assessment period, as discussed throughout this
report, several responses to NRC notices of violation required
additional information'and/or clarification in order to'
establish ~ acceptability of the response.
One IE Bulletin-
r
-
.
_
,
response was found not to address all required information.
Numerous Safety Evaluation Report confirmation of implementation
items, identified by the licensee as ready for NRC inspection
and closure, were not closeable on the basis of the information
provided by the licensee.
These items indicate a need for added
attention to detail on the part of individuals performing the
work and the need for increased management attention in this
area.
QA/QC staffing for both the licensee and the licensee's
construction contractor, Baldwin Associates, has remained at a
level throughout the assessment period that was sufficient to
support ongoing construction, inspection, and quality recovery
programs.
Of particular merit was the licensee's QA surveillance program.
The surveillance program has been instrumental in providing a
continuous overview of day to day activities, in identifying
problem areas in their early stages, and in effecting prompt
corrective action to identified problems.
The QA program for preoperational testing was reviewed and
determined to be acceptable.
.There was evidence of prior planning usually with defined
procedures for control of activities.
Decision making was
usually at a level that ensured adequate management review.
Records were generally complete, well maintained, and available.
Corrective action was timely and effective in most cases.
No allegations were reviewed in this functional area.
-2.
Conclusion
Licensee performance is rated Category 2 in this area.
This is
the same rating as given in the previous assessment period.
Licensee performance has remained essentially constant over the
course of the~SALP assessment period.
- 3.
Board Recommendations
None.
I.
Preoperational Testing
1.
Analysis
Examination of this functional area consisted of five intensive
region-based inspections and a portion of eight inspections by
resident inspectors.. Areas examined included:
(1) indepth
reviews of preoperational test procedures; (2) reviews of
administrative controls; (3) observation of maintenance and
preoperational test ~ activities; (4) observation of Nuclear
~ Steam Supply System. integrated flush; and (5). test witnessing.
~
,
-
=
. y
^
.
,
.
Due to the small number of preoperational tests initiated, only
,
limited preoperational testing activities were witnessed during
,
the assessment period.
No violations or other significant
-findings were ide'ntified.
However, subsequent to the SALP
. period two inspections were conducted and both identified
violations:
(1) failure to control preoperational test sequence
and (2) inadequate preoperational procedure (Standby. Liquid
Control System)..Both of these findings appear to be
administrative weaknesses.
For those activities observed, personnel appeared to be well
trained and knowledgeable, with sufficient numbers of test and
support personnel available to accomplish important tasks.
Procedures were~followed and records of testing activities were
. properly prepared.
Complex evolutions were adequately
controlled with well established interfaces. Management was
constantly involved throughout the assessment period.
The inspectors identified the need for. program improvements to
assure responsibilities were clearly understood during the
testing phase.
These needed program improvements were:
-
a.
Test Program - clarification to distinguish construction
activities from operational' activities. The licensee made
improvements by clarifying commitments to applicable
Regulatory Guides and Standards.
b.
Test Program Administration - clarification of administra-
tive controls in document control, preventive maintenance,
and equipment protection to fully comply with Regulatory
Guide 1.68.
The licensee made improvements by committing
to all. Regulatory Guide 1.68 requirements in the FSAR.
The above concerns:were corrected by the licensee during this
assessment period. Other areas of the licensee's testing
program met Regulatory Guides and Standards including controls
' for design changes and modifications, and control-of jumpers
and lifted leads during testing.
Additional' effort is underway
to develop a design change and modification program for
operations. The licensee also has demonstrated. aggressive
management attention by identifying and promptly correcting
program weaknesses such.as resolving previo'us inspection-
findings. Improvements have been noted in resolving previous
inspection items in a timely manner.
No allegations'were' reviewed in this functional-area.
2.. ~ Conclusion
-Licensee performance is rated Category 2 in-this area. -This-is
,
the same rating'as given in the previous assessment period.
Licensee performance-was considered to be proceeding _ positively,
'
over:the course of the SALP assessment period; however,
,
I
i
_
J21
'
'
,
.
.
<
I
,. _
,
w
.
-,
,
'
.
,
subsequent'to the assessment period two inspections were
conducted;in this area and both resulted in violations.
Consequently, the trend is considered to be the same and there
'
is concern about the licensee's ability to perform a quality
test program when preoperational activities increase.
3.
Board Recommendations
-The Board recommends that.due to the significant amount of
preoperational testing remaining to be performed and approved,
the licensee should dedicate sufficient resources and
management attention to ensure that the testing program is
effectively implemented.
The Board notes that inspection
findings identified just' after the end of the assessment period
. indicated some administrative weaknesses which are deserving of
licensee management attention to prevent recurrence.
J.
Radiological Controls
1.
Analysis
Five preoperational inspections were conducted during the
assessment period by regional specialists. One inspection
conducted three weeks after the assessment period is also
reflected in.this appraisal.
The inspections covered
(1) radiation protection, (2) radiological environmental
monitoring (REMP), (3) chemistry / radiochemistry, and
(4) radwaste. No violations were identified.
Licensee management support for the radiation protection program
appears good. This has been demonstrated by the licensee's
responsiveness to identified problem areas such as:
the ALARA
identification and resolution program; weaknesses in the
radioactive material receipt program; and the need to strengthen
the experience level of the radiation protection staff. These
matters are being satisfactorily resolved by the licensee.
'
Staffing of the professional and technician health physics
positions is almost complete.
The staff appears to be
qualified,'well organized, adequately trained, and stable.
The
i
most noteworthy weakness in the staff is the lack of Boiling
Water Reactor (BWR) experience; however, the Radiation
Protection Manager (RPM) and the Health Physics (HP) Supervisor.
.
have considerable BWR experience.
The technicians and
professional staff continue to.~ receive experience at other
operating plants.
The staff has several persons with technical
expertise in radiological engineering.
The health physics
training program, which ' includes abundant on-the-job, training,
appears good.
Chemistry group staffing consisted of one supervisor and
-nineteen supporting personnel which'is at the authorized level.
The group is currently augmented by three technical consultants,
'
two training' consultants, and'nine or ten contract technicians.
[
L
-
'
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.
.
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-
.
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...
.
.
- -. -
-
-
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,
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l
The staff is academically qualified with most of the fourteen
'
Rad-Chem-technicians'(RCTs) having bachelors degrees or nuclear
j
navy experience.
Experience in chemistry is satisfactory, but
i
nuclear power plant radiochemistry experience is limited.
.
training has slipped appreciably about three months from targets
,
- .~
anticipated in the spring of 1985, owing partially to delays in
p
installation of laboratory ventilation equipment which is a
.
prerequisite to open source radiochemistry work.
The RCTs are
!
currently receiving Phase III training on the Post Accident
i
Sampling System. All but one, a newly hired RCT, have completed
Phase I and Phase II training.
Formal and hands-on training in
'
~
.
radiochemistry and gamma spectroscopy is now scheduled for
[
completion. in 0ctober 1985, for at least half of the RCTs.
- '
The delay in installation of ventilation equipment has reduced
'
the opportunity for the RCTs to complete their qualifications
l
'
and become fluent in radiochemical analyses through on-the-job
i
work.
Further slippage will jeopardize laboratory readiness
,
for the licensee's projected January 1986, fuel load. The
j
delay will also require more than normal management oversight
i
of laboratory activities during early plant operation.
In
i
recognition of this problem, the licensee has agreed to retain
j
a qualified radiochemistry consultant to advise and assist the
l
Supervisor-Chemistry in_ oversight of the laboratory for a period
of at least six months after fuel load.
l
The Supervisor-Chemistry recently completed vendor chemistry
,
and radiochemistry courses and one month of observation training
i
at Farley Nuclear Generating Station, and two months of " hands-on"
training at LaSalle Nuclear Generating Station.
The third month
,
,
J
of hands-on training at LaSalle, originally anticipated, will
{
be obtained at Clinton while working with the retained consultant.
,
{
The health physics staff has performed well in identifying
potential radiological problems in all areas of the plant;
however, after initially strengthening their controls over
,
contractor radiographer activities, their assessment of a recent
l
radiological incident was weak. The licensee continues to
i
correct self and inspector identified problems and programmatic
weaknesses. The RPM and Power Plant Manager have been
)
}
responsive to the inspector's suggestion of instructing the
plant staff supervisors in the need for emphasizing to the
workers the importance of employee adherence to radiological
'
procedures ~and controls.
The procedure review program is
continuing and procedures have been strengthened.
,
'_
Laboratory and radiation protection facilities and space appear
adequate to perform all necessary work functions. Ventilation
i
in the laboratory is expected to be completed in the' fall of:
j
1985. At present, the licensee has the capability of performing
limited nonradioactive chemical analyses. Most laboratory
!
equipment was undergoing' testing and calibrations.
Technicians
were becoming familiar with operating the equipment.
A limited
QA/QC program for operating chemical instruments appeared-
1
23
.
r
,
,
,.
-
---
,, - -.
.--
,.
..,.
. _....,., - -,_
.
.-
.,. - _ _ - - _. -.
-
-
-
,
adequate, but a QC program for chemical analyses had been
implemented only to a limited extent. Nonradiological chemical
procedure development was almost complete.
Counting instruments, except for.a proportional alpha-beta
counter on order, are in place and operational.
Calibration
sources and solutions are ordered and the licensee expects to
prepare standards and complete calit, rations in October 1985.
Currently only a limited number of RCTs are knowledgeable on
the gamma spectrometer and liquid scintillation counting
systems.
Considerable work remains to be done to qualify
other RCTs.in'their operation, to complete procedures, and to
fully implement QC programs to verify capability of instruments
and analysts. These activities will have to be essentially
competed prior to fuel load.
The Radiological Environmental Monitoring Program (REMP),
initiated in 1980, is well established.
Sample collection and
-analysis are being performed by a qualified and experienced
'
contractor.
Data recovery and reporting have been satisfactory
and no trends or significant anomalies have been observed.
Expansion to full implementation was scheduled for 1985, with
the addition of baseline iodine sampling.
Difficulty in
locating milk animals within 5 miles of the plant has forced
the licensee to plan to sample grass and leafy vegetation in
place of milk.
It'is expected that the licensee will have
fully met'REMP program commitments by fuel load.
.
The remaining major plant' systems scheduled for completion by
fuel load are the liquid and gaseous radwaste system
preoperational tests and preoperational tests and calibration of
,
the process and area radiation monitors.
These tests are
currently scheduled to be completed and the systems turned over
to the plant staff during December 1985. Although not yet
-
!
installed, a vendor supplied radwaste system is scheduled to be
operational by fuel load.
The licensee has submitted a Process
i
Control Program ~(PCP) covering operation of the vendor supplied
solid radwaste processing system to NRR for approval.
i
No allegations were reviewed in this' functional area.
2.
Conclusion
Licensee performance is rated Category 2 in this area.
This is
the same rating as given in the previous assessment period.
.
Limited experience in operating plant radiochemistry will place
great importance on procedure development and training in this
area.
..
-
,
3.
Board Recommendation
Inspection frequency.and intensity should be increased, as
appropriate to assure that the licensee is prepared for fuel
load.
Continued senior licensee management attention is
warranted to support fuel load.
K.
Security
1.
Analysis
Examination of this functional area consisted of five safeguards
inspections which addressed (1) security measures for receipt
and protection of new fuel, and (2) actions and progress for'
implementation of the security program required for operations.
Initial inspections concentrated on the adequacy of the
licensee's planning and scheduling for program completion.
The licensee's security requirements become effective upon
issuance of an operating license; therefore, no violations have
been cited during this assessment period.
Inspection findings
have been identified and must be resolved prior to license
issuance.
The licensee's planning and scheduling program was found to be
generally acceptable.
An integrated security system implemen-
tation schedule had been developed and most major program
elements were included.
Additional program elements identified
by the NRC have been included in the schedule.
Although some
element schedule completion dates were not met, general
adherence to schedule completion dates has been adequate.
Major security system elements (for example, security computer
system and alarm systems) completion dates have been closely
,
monitored by senior onsite managers, up to the Vice President
level. The licensee's senior management appears to have a keen
j
awareness of the security program's impact on eventual plant
operations. The August / September 1985 Inspection Report noted
that the proposed complete security implementation date of
November 18, 1985, allows minimum time to resolve implementation
'
problems prior to the licensee's projected fuel load.
The licensee's major security documents (security plan,
contingency plan, and training and qualification plan) had been
initially approved by the NRC; however, one onsite inspection
identified the need for significant changes to the security
plan.
The licensee revised the security plan to address the
,
identified concerns. The plan revision still requires NRC
l
approval.
Procedural guidance has been prepared by the
licensee's security staff and the procedures appear adequate.
l
i
_
_
-
..
-. - -
,
-.
.
The 11censee'.s proposed staffing le. vel. appears adequate to
fulfill basic security plan. commitments provided numerous
-
compensatory measures are not required upon program
implementation. The senior contract security supervisor and
the plant protection' supervisor assumed their duties
December 1984 and March 1985, respectively.
Both managers
have extensive nuclear security experience.
To date, the
licensee's' progress in planning, scheduling, coordination,
and resource management appears adequate.
The licensee appears very effective in identifying and resolving
technical problems pertaining _to the security. program. A
security system implementation work group has been established
to monitor implementation of the security program.. The work
-
group has expertise involving several disciplines; they meet on
a weekly basis.
Coordination appears very effective and
technically correct resolutions to identified problems are
evident.
The' licensee has been very responsive to NRC concerns pertaining
to-the security program.
The licensee effectively monitors the
status of inspection findings and aggressively takes action to
resolve them.
Several findings pertaining to barriers,
emergency power, intrusion alarm systems and closed circuit
television systems still require resolution.
To date, support of some nonsecurity departments in fulfilling
tasked objectives for the-security program has generally been
minimally effective.
During a June 1985 inspection it was
noted that the Personnel Screening Program for unescorted access
to vital areas warranted senior management oversight and
support.
Prior to June 1985, this major portion of the security
program had received very limited attention. An August 1985
inspection.noted progress toward implementation of the personnel
screering program.
However, this program continues to warrant'
senior management attention and if not adequately implemented,
could impact on the security programs capability to' support fuel
load.
~ ~
~
- Security protection and accountability procedures for special
nuclear material were inspected during August / September 1985
and determir.ed to be' adequate.
In summary, the licensee's security staff has been effective in
planning for implementation of the-security program ~and in
. identifying problem areas pertaining:to the program.
Proposed
,
security staffing seems adequate and NRC concerns and findings
.are effectively monitored and addressed.. Departmental support
.
for.the: security program is effective, except for the Personnel
' Screening Program. : Security protection is adequate for special
nuclear material received and stored onsite.. Major milestones,
1such as total integration of the security. system, extend into -
the'next appraisal period.
,
'26
.
.
-
} f
,
No allegations were reviewed in this functional area.
2.
Conclusion
Licensee performance is rated Category 2 in this area. This
functional area had not been previously assessed.
Licensee
performance has ganerally improved over the course of the SALP
assessment period.
3.
Board Recommendations
Licensee attention should be increased to assure that the
security system is ready for fuel load.
L.
Operational Readiness
1.
Analysis
Examination of this functional area consisted of four
region based inspections and portions of ten inspections by
resident inspectors.
Areas examined included:
(1) programs for
operations, tests, and experiments; (2) programs for maintenance,
design changes, and measuring and test equipment; (3) plant
staffing; (4) operating staff training; (5) administrative
procedures review; (6) maintenance procedures review;
(7) comparison of as-built plant to Final Safety Analysis
Report description; (8) housekeeping; (9) control room behavior;
(10) battery operation and maintenance; and (11) review of
previously identified items.
No violations or deviations
were identified.
Early in the assessment period, plant operations personnel were
neglecting'in plant familiarization (system walkdown) training
in order to support other priority work.
Licensee supervision
addressed this matter in a timely fashion, adjusting manpower
and' priorities in order to provide sufficient time for plant
operators to continue this important activity.
Inspection of programs for operating staff training identified
no significant deficiencies in the programs reviewed.
The
licensee's plant specific simulator was recently installed and
is.being used for reactor operator training.
Plant specific
training information (system descriptions) which was supplied
to the NRC for operator licensing examination purposes and
which was available to licensed operator trainees was not up to
date.
Licensee actions to update the system descriptions have
-
not been timely. -The lack of up to date information resulted
in more time being utilized by the NRC in the development and
grading of'the examinations.
Seventeen-of twenty two' reactor
operator / senior reactor operator license candidates successfully
completed the NRC administered license examinations which
represents an examination pass. rate above the industry average.
i
,
This indicates that the lack of up to date information did
not significantly effect the knowledge of operator license
candidates.
Additional operator license exams are scheduled
prior to fuel load. Management attention is necessary to
'
assure the timely implementation of re qualification training
programs to maintain the proficiency of cold licensed operators
and senior operators.
Several of the administrative procedures reviewed contained
numerous minor discrepancies, deviatiens from committed
standards, and were not easy to use.
The ANSI standard and
technical specification requirements for independent technical
review of procedures were not reflected in administrative
procedures; the technical adequacy of maintenance and operating
procedures reviewed reflected this.
Procedures for control of
safety-related documents were fragmented, did not provide a
strong interface between organizational units, and were
improperly classified in the licensee's procedure control
system. As a result of these and other similar findings, the
licensee instituted changes to their QA program requiring an
independent technical review of safety related procedures by
highly qualified staff and contractor personnel.
A systematic
self audit was used to rectify document control procedure
problems and a 100% review of the classification of documents
in the Operating Manual Status Report was also undertaken.
Licensee actions in this regard were progressing satisfactorily
at the conclusion of the assessment period. Weaknesses included
the technical adequacy and completeness of the operating
procedures as discussed above.
System walkdowns by resident inspectors to verify as-builts
revealed several strengths, including:
component accessibility
for maintenance, engineered provisions for maintaining personnel
radiation exposures ALARA, valve tagging, and the program for
control of locked valves.
An inspection in the area of design changes and modifications
identified that the licensee's operations program for design
changes and modification control had not been completed.
Licensee personnel expected to have the program completed and
implemented by the start of openations.
There has been
substantial effort on the licensee's part to meet that goal.
An inspection in the area of operations' tests and experiments
showed that all the necessary elements for control of tests and
experiments could be accounted for but the program was
cumbersome.
For example, it used nine procedures to describe
the activities of the Nuclear Review and Audit Group (NRAG),
Facility Review Group (FRG), technical staff, licensing, and
six plant departments.
Additional management attention is
warranted to ensure that the program is manageable.
..
.
.
.
~
Plant housekeeping and control room behavior were assessed
as adequate considering the state of construction of the
-
. facility.
Because of the number of personnel working onsite,
(approximately 7300 at the end of the assessment period) daily
attention to housekeeping was required to assure the requisite
level of cleanliness was maintained, and to preclude degradation
~_
of sensitive plant equipment and components. Management attention
to this area has been apparent.
Housekeeping continued to improve
throughout the assessment period, in part as a result of extensive
surveillance activities performed by the quality organization and
by plant operations supervision.
Additional action will be
necessary to place all areas of the plant in a state of operational
readiness. Control room behavior could not be adequately assessed
because of the construction status of the plant.
NRAG activities commenced in'the latter half of the assessment
' period, well in advance'of the required implementation date.
NRAG has been instrumental in focusing the attention of the FRG
on plant operational safety.
Although not specifically
inspected durint the' assessment period, resident inspector
Leonitoring of MtAG activities indicates that NRAG has been
.
inquisitive, aggressive, involved, and technically oriented
toward assuring plant operational safety.
Management approach to the resolution of issues from a safety
standpoint and understanding of the issues is generally
apparent. Management's response to NRC initiatives has been
generally timely, sound, and thorough.
Management involvement and control in assuring quality is
evidenced by adequate planning, assignment of priorities,
and awareness of the status of these items.
The level of
understanding of the issues is generally apparent. Acceptable
-resolutions are generally proposed.
Significant additional actions are required by the licensee and
additional inspection activity should be focused by the NRC in
order to assure the operating staff is. ready to support fuel
load'and initial operation.
No allegations were reviewed in this functional area.
2.
' Conclusion
Licensee performance is rated Category 2 in this area. This
functional' area had not been previously assessed. There was no
data base on which to establish'a trend.
' 3.
Board Recommendations
I
'
None.
-
l
M.
Licensing Activities
1.
Analysis
The licensee's performance evaluation in the area of
licensing activities was based primarily on three attributes:
a) management involvement in assuring safety; (b) approach to
resolution of technical issues from a safety standpoint; and
(c) responsiveness to NRC initiatives.
Training was the only
other attribute specifically addressed and was judged to apply
to only a small fraction of licensing actions.
a.
Management Involvement and Control in Assuring Quality
The licensee's management participated actively in many
licensing activities.
In particular, licensee's management
was actively involved in the following:
Resolution of the three remaining licensing
contentions that resulted in the signing of Joint
Stipulation agreements between the licensee, the NRC,
the Illinois Attorney General, and the Prairie
Alliance.
Negotiations to determine the scope of the
independent design review (IDR), and commitments
related to followup actions once the IDR final
report was issued.
Pursuing the resolution of hydrogen control issues
through the hydrogen control owners group and
containment pool dynamics encroachment issues.
Preparations for the Seismic Qualification, and Pump
and Valve Operability Review Teams.
The licensee's management involvement has been very
effective and instrumental in the resolution of all of
these issues in a timely manner to support fuel load except
for the Pump and Valve Operability Review Team audit which
was completed August 29, 1985.
This has been the only
issue where the Licensing Project Manager (LPM) has
observed a significant management breakdown.
However, the
problems were recognized by licensee management during the
audit and a corrective action plan committed to and
initiated.
During this assessment period, several management changet
occurred.
A new Director of Nuclear Licensing and, very
recently, a new Plant Manager were named, lhe new Nuclear
Licensing Director has aggressively pursued the resolution
of the remaining licensing issues and any new issues
requiring licensing action that have either been identified
by the licensee or the NRC staff.
On a few occasions,
~
the licensee's management has been too aggressive by trying
to resolve issues before they were fully prepared or before
all the relevant information was available.
The licensee's management has an awareness of the licensing
issues by virtue of experience in industry, technical
expertise, and active participation in Owners Groups. The
licensee's management has also consistently exercised firm
control over its contractors' activities and maintained
good communication between the contractor, their own staff,
the_NRR staff, and the NRR staff' contractors.
The licensee has a manager at the vice president level
stationed at the site who is in charge of the nuclear
program management, quality assurance, station management,
and nuclear station engineering. The nuclear licensing
,
department is incorporated within the organization
reporting to this vice president.
As a result, related to
licensing activities, there has been consistent evidence
of prior planning and assignment of priorities, well stated
and understandable policies, and well considered frequent
management involvement and review. Moreover, corrective
actions have generally been taken promptly to address staff
concerns, and scheduler commitments have usually been
adhered to.
b.
Approach to Resolution of Technical Issues From a
Safety Standpoint
The licensee's management and staff have demonstrated a
good understanding of the technical issues based on
evaluations obtained from the NRC technical reviewers.
The
onsite location of the licensee's engineering and licensing
departments provides assurance that most engineering work
related to complex technical issues, either done in-house
or performed under its direction by contractors, is
adequately addressed.
The licensee's staff has performed particularly well in
the resolution of issues associated with the hearing
contentions related to emergency preparedness, detailed
control room design (SPDS, DCRDR, and R.G.1.97) and quality
assurance issues.
Environmental qualification and
resolution of NUREG 0737 items are two additional areas
where the licensee has performed well.
Although the licensee has provided the information needed
to adequately resolve licensing issues in'a timely manner,
the initial submittals in some instances have not been as
complete as expected, requiring followup information and
clarifications to be provided.
The need to request
additional information does not necessarily reflect a
lack of knowledge of the issue, but rather a lack of-
complete documentation.
<
,
f
The licensee should be able to improve the quality of its
initial submittal so that the need for followup information
can be minimized. The licensee has developed a tracking
system for resolution of licensing issues called Closure of
Licensing Issues Program (CLIP).
In conjunction with
inputs from the NRC staff, this report is updated on a
weekly basis.
The CLIP report includes all SER outstanding
.and confirmatory issues, proposed license conditions, and
TMI NUREG 0737 issues.
In addition, any other major issues
requiring resolution (i.e., design and FSAR changes that
require revisions to the staff's safety evaluations) are
also included.
The CLIP report includes all the licensing
actions currently requiring technical resolution and
identifies the actions required for closure both by the
licensee and the NRC.
This report has been very helpful in
'
tracking and resolving the remaining licensing issues.
t
There are currently six SER outstanding issues and seven
SER confirmatory items remaining to be resolved prior to
issuance of a low power license.
This is a relatively
small number of open SER issues for this stage of
licensing.
c.
Responsiveness to NRC Initiatives
Open and effective communication exists between the NRC
and the licensee's licensing staffs.
Effective dialogue
between both staffs usually promotes prompt and technically
sound responses to NRC initiatives.
The licensee usually
meets all established commitment dates or provides written
or verbal responses explaining the circumstances associated
with any delays and, in most instances, establishes new
firm dates. ' Conference calls with the staff are promptly
established and include appropriate engineering, plant,
and/or contractor personnel.
The establishment of a
technical licensing contact in Washington by the licensee
for the duration of the licensing' stage has been effective
in resolving technical issues and expediting the exchange
of information in an accurate and concise manner.
This
should prove to be even more effective during the months
just prior to issuance of the low power and full power
licenses.
The licensee's staff has' demonstrated a good working
knowledge of applicable regulations, guides, standards,
and generic issues pertaining to their plant. This was
evidenced by the licensee's positive attitude and
responsiveness to the NRC staff in addressing unresolved
SER issues. The licensee's staff has always been prepared
to meet with the NRC staff in a short' time frame to obtain
'the necessary understanding of NRC information needs and
has been successful, by preparedness and aggressiveness,
in expediting most SER issue resolutions in a timely
<
manner.
o
,
,.
_
_
)
During meetings, the licensee has demonstrated a thorough
understanding of the technical issues and has effectively
utilized the services of its architect engineer, the
nuclear steam system supplier and other contractors as
needed, to make each meeting productive.
d.
Staffing (Including Management)
The licensee has during this assessment period, hired
personnel with nuclear experience to fill the Director of
,
Licensing and the Plant Manager positions.
The NRC staff
has a reviewed the licensee's plant organization, staff
levels and qualifications and found them acceptable.
To satisfy the requirements of Generic Letter 84-16, the
licensee has established a supervisory operating plant
program under which selected supervisory personnel either
have been or will be assigned to another utility's plant
for at least six months to obtain operational experience.
<
This experience combined with the number of operators that
passed the SR0 and RO examinations indicates that no shift
advisors may be required. The security organization
. positions and responsibilities are well defined.
The
security staff'is considered to be adequate to implement
the facility physical protection program.
No allegations were reviewed in'this functional area.
2.
Conclusion
An overall performance ~ rating of Category 1 has been assigned
for the functional area of Licensing Activities.
This is an
improvement over the licensee's Category 2 rating in the
previous SALP rating period. The licensee's performance has
improved during the rating period.
3.
Board Recommendations
None.
,
N.
Overinspection Program
Management meetings between NRC and the licensee held in 1982,
resulted in the licensee's commitment to inspect a portion of
work completed prior to July 1982, and subsequent recovery plans
to verify the adequacy of the plant's physical construction.
The licensee originally committed to inspect approximately 20%
of structural steel; mechanical equipment; electricalLraceway
and supports; heating, ventilating, and air conditioning; large
'
and small bore piping and supports; and instrumentation.
Verification inspections began in August 1982, but were stopped
by the licensee in October 1982, because the NRC determined that
,
.,y
-
+
-
wq--
-.
.
..
.
.
--
. - - - - ~ -
-.
.
.
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J
the _ licensee had not properly planned the activities or trained
,
the inspectors.
Stone.and' Webster personnel became involved
with verification activities at that time.
The licensee
'
submitted an Overinspection Program Plan to the NRC in November
1982. The plan described a series of inspections including
normal first line quality control inspections by Baldwin
Associates; verification inspections by Baldwin Associates
Quality Assurance; and overinspections by licensee Quality
.
'
Assurance.
The Overinspection Program Plan was a statistically
based random sample inspection based on Military Standard
(MIL-STO)-105D, " Sampling Procedures and Tables for Inspection
-
l-
by Attributes". The plan was verified by the licensee, Stone
'
and Webster, and NRC to produce 95% assurance that at least 95%
.
of the items in a-lot were not defective.
The Overinspection
,
Program (verification inspections) resumed inspection activities
e
in September 1983.
i
i
1.
Analysis
Examination of the licensee's Overinspection Program involved
portions of seven inspections by region-based, resident, and
j
CAT inspectors.
Areas examined included:
(1) safety related
structures; (2) piping systems and supports; (3) heating,
l
ventilating, and air conditioning (HVAC); (4) welding;
j
(5) electrical and instrument control systems; and (6)
!
programmatic aspects of audit and surveillance; and (7)
j
Overinspection Program termination requests.
l
Inspection findings related to the nonprogrammatic aspects of
-
overinspection activities were discussed in previous sections
of this report.
Program implementation was found to be adequate
,
with oily minor deficiencies being identified by the licensee's
p
-QA surveillance group.
The licensee has determined that none of
the several thousand' discrepant attributes identified during
.
overinspection:has-any significance to; safety. ~Four requests
l
for termination of overinspection were received from the
licensee during the assessment period.
Review by the NRC of
overinspection data and engineering evaluations regarding the
licensee's request for termination of overinspection identified
numerous inadequacies.
The licensee vigorously responded to the
identified problems and undertook extensive corrective actions
'
on their own to assure the technical adequacy of future
L
submittals. To date, overinspection of' safety-related large
L
bore piping and mechanical supports'has been officially
!:
terminated. The licensee submitted additional requests to
l'
terminate overinspection of electrical hangers, HVAC duct and
j
duct supports, and electrical cables, terminations, cable tray,
's
and conduit.
The licensee, at their own risk, suspended
overinspection'of those commodities pending_ review by NRC of
requested additional' technical data.
The scope of structural
steel overinspection was questioned by the NRC and was under
review by the licensee and the NRC at the conclusion of the
assessment period. Overall, the overinspection data submitted
by the licensee indicates that work done after 1982 has improved,
p
!-
L
I
.
...
.
_ _ _.,.
.
_, -. _,. _ _ _ _, _ _ _ _ _ _ _ _ - - -
and that the discrepancies identified were not significant to
safety.
As noted in the previous SALP report, certain contractor
QC inspectors were not properly qualified or certified to perform
inspections. The licensee's corrective action included reinspec-
tion of the inspectors' work as part of the Overinspection Program.
Due to termination of overinspection in several areas the licensee's
corrective actions were incomplete.
This matter was reviewed
with the licensee and will be reinspected by NRC upon completion
of licensee actions to assure the adequacy of the inspector's
work.
2.
Conclusion
Licensee performance is rated Category 2 in this area.
This
functional area was not previously assessed.
Licensee
performance has generally remained constant over the course of
the SALP assessment period.
3.
Board Recommendations
None.
i
,
h
,
u
-
~ V. -
SUPPORTING DATA AND SUMARIES
A.
Licensee Activities
Construction of the Clinton Nuclear Generating Station was
approximately 96% complete at the close of this assessment period.
The licensee completed several actions and reached many milestones
during the assessment period. The actions were related to the com-
pletion.of construction, including acceptance and preoperational
testing, system turnovers to operations, operator training, comple-
tion of licensing activities, and receipt of fuel.
Selected
activities and milestones are listed below.
1.
Major Construction Milestones
April 1984
Suppression pool initially filled
June 1984
completed
January 1985
Reactor integrated flush
completed
February 1985
Reactor cold hydro test completed
March 1985
Diesel Generator Division II
synchronized
May 1985
ECCS pumps 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> run completed
July 1985
Reactor hot operations test
completed
August 1985
Diesel Generators, all divisions,
operated
August 1985
Nuclear fuel shipments arrive
2.
Major System Turnovers
July 1984
. Engineered Safety Systems
August 1984
Radwaste
November 1984
Reactor Plant Component
Cooling Water
January 1985
April 1985
Reactor Recirculation and
Water Cleanup
June 1985
Containment and Drywell
Ventilation
June 1985
Control Rod Drive
July 1985
Craft Security Portal and
Systems
3.
Major Reviews and Audits
>
September 1984
Joint Utility Management Audit-
of QA
January 1985
Independent Design Review by
'
Bechtel
'
February 1985
"N" Certification by ASME team
March 1985
Equipment Qualification by NRR
May 1985
Near Term Operating License
'
visit by INPO
r.
t
c
,
June 1985-
Construction Appraisal Team (CAT)
,
by NRC
July 1985
Case Load Forecast Panel by NRC
July 1985'
Training Accreditation Visit
by INPO
August 1985
Reasonableness of Cost Audit by
Illinois Commerce Commission
August 1985
_ Seismic Qualification Review Team
(SQRT) and Pump and Valve
Operability Review Team (PVORT)
,
Audits by NRR
4.
Training and Preparations for Operation
General Employee Training
Radiation Worker Training
' Background Security Screening
Fitness for Duty Program
Removal of Temporary Structures from Protected Area
Integrated Emergency Drills
Reactor Operators Examined by NRC: (17 of 22 Passed)
Maintenance Contract Let to Stone & Webster
5.
Important Licensing Interactions
Joint Stipulation signed by Ifcensee, Illinois Attorney
General, Prairie Alliance, and NRC; all licensing contentions
withdrawn.
Atomic Safety and Licensing Board (ASLB) terminated.
Extension of Construction Permit to October 1, 1986.
Illinois Certificate of Registration received for Low Level
Radioactive Waste.
Amendment No. 2 to Construction Permit; environmental issues.
' Radioactive Waste Agreement between licensee and U.S.
Ecology Inc.
Annex to the State of Illinois Plan for Radiological Accidents
. approved by State of Illinois.
Special Nuclear Material License granted to Itcensee by
NRC.
Supplementary Safety Evaluation No. 4' issued.
6.
. Petition To Intervene
,
.
, Petitions to intervene were filed in 1980 by the Prairie
-Alliance and the' State of Illinois Attorney General.
An Atomic
Safety and Licensing Board was established in 1981 and admitted
,
_ _.
-
\\
r
12 contentions including quality assurance.
The number of
i
contentions was ultimately reduced by negotiations to three,
.
including quality assurance. Quality assurance issues were the
i_
subject of extensive discussions and exchanges of information
'
among the licensee, the State, and NRC.
The licensee submitted
i
s
a " Summary of Quality Improvement and Confirmatory Actions"
[
(QICA) report which described the programs and plans for action
!
to address the concerns raised by the contention on
l
quality. The programs and plans included a record verification
!
.
L
program, a Final Safety Analysis Report verification program;
t
'
third party audits; special programs including seismic analyses
i
for as-built safety related piping systems walkdown program,
f
seismic interaction analysis program, electrical separation
I
program, and fire protection program; a configuration program;
1
a system turnover and startup testing program; the overinspec-
i.
tion program; and the independent design review.
A meeting was
!
l
. held in December 1984, at NRC's office between NRC and
i
l
representatives of the State of-Illinois Attorney General.
The
purpose'of'the meeting was to discuss NRC inspector activities
'
-
and the methods used or contemplated to inspect the previously
l
!
described licensee quality related plans and programs.
Specific
-
.
matters discussed were the overinspection program, the
Appraisal Team (gn review, the proposed NRC ConstructionCAT) insp
independent desi
!
!
t
Assurance Program.
NRC responded in writing to the Illinois Attorney General in
January 1985 regarding the NRC actions planned or taken to
j
verify the various programs discussed in the licencee's QICA.
-
Based on negotiations and the previously described programs,
,
plans, and meetings, a Joint Stipulation was signed in January
,
l
1985, between the licensee, the State of Illinois Attorney
General, the Prairie Alliance, and the Nuclear Regulatory'
Commission.
The Joint Stipulation allows the Illinois Attorney
.
General to participate in matters relating to those quality
!
!
related issues previously discussed.
As a result, the remaining
i
!
contentions have been withdrawn and Atomic Safety and Licensing
i
Board proceedings terminated.
To date, the Illinois Attorney
General's office has attended meetings and actively participated
!
in matters related to the independent design review,
!
,
!
l
overinspection, and the CAT inspection.
t
l
B.
Inspection Activities
,
}
During the assessment period of March 1, 1984, through August 31,
!
1985, there were 80 NRC inspection reports written pertaining to
[
[
matters at the Clinton Nuclear Generating Station.
NRC's inspection
'
activities were as follows:
56 routine inspections; 10 resident
i
!
inspections; 5'special inspections by Region III; 3 special
,
!
inspections by other NRC teams; and 6 meetings.
All or portions of
-
!
25 inspections were devoted to review of allegations.
The special
i
inspections were in regards to review of concrete expansion anchors,
,
.
,
i
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' NVAC recovery program, NDE activities, review of previous findings,
'
J,'and review of records at the offices of Sargent and Lundy.
- '
Enforcement actions for these NRC inspection activities are
F " included in Table 1.
,
,
-
.
..
_.,
.
' 3
f,-
Three"special inspections were conducted by other NRC teams.
1.
The.first inspection'was conducted by Region I in regards to
indLpendent measurements of piping weldsent quality. The
inspection verified the adequacy of the licensee's welding and
nondestructive examinations (NDE) quality control programs for
safety-related piping weldments fabricated to ASME Code, Section
'
III, Class 1 and 2.
The inspection included radiographic,
penetrant, visual, magnetic particle, and ultrasonic examinations,
and measurements of hardness, thickness, ferrite, and alloy
-
content.
205 weldments were involved in the inspection which
required 376 hours0.00435 days <br />0.104 hours <br />6.216931e-4 weeks <br />1.43068e-4 months <br /> of onsite inspection. One violation was
identifled as?Jescribed in Section IV of this appraisal,
t
,
N
2.
Thesecond4nspectionwasconductedbyNRC'sOfficeofInspection
and Enforcement in regards to the independent design review
'
,
l
/
conducted by the Bechtel Corporation.
The independent design
~
review was a major inspection activity during the assessment
period. The NRC inspection team was made up of NRC Office of
Inspection and Enforcement representatives and consultants.
The inspection was conducted in two phases:
a site tour and
an evaluation at Bechtel's headquarters.
,
',
The objective of tJm inspection was to ensure that the
,
independent design' review was being conducted in accordance
with the approved plan. The team was favorably impressed with
,
Bechtel's effort, especially the quality of engineering
/
expertise being employed, and the obvious management commitment
.to the effort at the highest corporate levels.
However, the
NSC,fr.spection team did conclude that the independent design
.
re W w progr a plan was only moderately implemented in the
u
area of engine.oring disciplines interaction, that is, the team
!
did net observe good communication between discipline review
groups.
No violations were identified.
(50-461/84039)
3.
The third inspection was conducted by the NRC Office of Inspection
~ ' rid Enforcement's Construction Appraisal Team (CAT) and involved
.
~
a
' examinaticas, observations, and reviews of selected hardware
V % d~related Quality Assurance Program activities. The inspection
J
specifically included welding:
nondestructive examination of'
weldments; construction of electrical, instrumentation, mechanical,
and civil structural components and systems; control of design
,. changes and material traceability; and corrective action.
The-
,
inspection did rlot identify any pervasive breakdown in the samples
"
of installed hardware or construction controls for managing the
construction of the'Clinton plant.
The Overinspection Program
was viewed as being effective in identifying deficiencies with
construction.
The, deficiencies noted by the CAT included
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ineffective control of work performed by the plant staff after
'
equipment was released from construction status; inadequate
,
.
control of design documents; and inadequate programs for
"
verification of electrical cable separation.
Six violations
['
were identified and are discussed in Section IV of this
7{d
- appraisal.
'C.-
Investications~andAllegationslteview
'
No. investigations by NRC's Office of Investigation were initiated
.during the assessment. period; however, there are five outstanding
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allegations concerning wrongdoing scheduled for investigation in the
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near future.
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There were 91 511egation files (258 allegations) opened by Ni!C during
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the assessment period, an. increase of 182% from the last assessment
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neriod. -'Approximately 20% of the. allegations were hardware related.
Examples of hardware related allegations include material
certification and traceability, piping and electrical raceway support
.
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welding, and concrete expansion anchor installation.
Examples of the
!
remaining 80% nonhardware related allegations include:
qualification,
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tiaining, and certification' of personnel; discrimination,
!
'
intimidation, harassment, and blackballing of personnel; violations
"
of procedures or changes to them; control of drawings and documents;
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_ push for production; and disagreement with dispositions to
nonconformance reports.
i--
Twenty-five c'omplete or partial regional and resident inspections
F
. were required to c, lose 65 allegation files.(102 allegations). Those
25 inspections resulted in substantiation of 52. allegations. Three
substantiated allegations were in violation of NRC requirements.
,
-These are discussed in Section IV of this appraisal.
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The remaining 49 substantiated allegations'did not result in
violations for one o'r more.of the following reasons:
The concern did not violate.a requirement.
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Licensee had identified the problem and corrective action
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was in progress.
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The alleger was not knowledgeable'of procedures or
-
- specifications which. satisfied-the~ concern.
~The remaining.25 allegation files (85 allegations) were in some
' stage of inspection: activity. by NRC.
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Late in the assessment period.a high number of allegations were
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received by NRC. The concerns mainly came from members of the
'Baldwin Associates' Document Review Group who alleged poor management
%
practices. On-July 2, 1985,'NRCcforwarded 46 allegations from.
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v various. allegation files to the licensee for. review-and disposition.
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' NRC and licensee senior management personnel met? July.11,1985:onsite-
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to discuss the allegations which had been referred to the licensee
for handling.
NRC will review results of the licensee's
investigative efforts.
'
The licensee has voluntarily placed a SAFETEAM onsite in addition to
the Quality Concern Program and quality " hot line" instituted during
the previous assessment period.
The SAFETEAM is chartered to conduct
routine interviews of terminating employees, scheduled interviews of
project staff, and interviews of individuals on a drop in basis.
Through the interview process the SAFETEAM determines if an
interviewee has_any concerns which should be addressed. The SAFETEAM
investigates the concerns, attempts to achieve resolution, and
responds to the' individual with results of the investigation.
These
activities are carried out while maintaining the individual's
confidentiality.
NRC has reviewed results of selected SAFETEAM
investigations; no substantive problems were identified during these
reviews.
Enforcement history in th; area of allegations is extremely good
considering the high number _ of allegations.
Licensee management
attention and involvement in the area of allegations has been
aggressive, especially in the latter part of the assessment per' d.
Licensee resources are adequate and reasonably effective such.r.
.
-
satisfactory performance with respect to construction is being
achieved.
D.
Escalated Enforcement Action, Orders, and Civil Penalties
No escalated enforcement action took place during Clinton's SALP 5
assessment period.
E.
Administrative Actions
There were no confirmatory action letters.. issued by NRC
during the assessment period.
4-
F.
Management Conferences Held During Assessment Period
' February 28, 1984
Meeting at Champaign, Il to' discuss status
of emergency preparedness'(50-461/84006).
May 31, 1984
Meeting at Clinton site with management to
' discuss status of construction and' key
elements of improvement programs
(50-461/84016).
October 16, 1984
Second Corporate Management Meeting
-(50-461/84033).
-October 25,-1984
Meeting at Regional Office with management
to discuss proposed changes to the
Overinspection Program (50-461/84037).
,
.
.
..
-.
.-
April 22, 1985
Meeting at Regional Office to discuss
proposed changes to Overinspection Program;
large and small bore pipe and mechanical
supports (50-461/85024).
July 11, 1985
Meeting at Clinton site with management
to discuss allegations and SAFETEAM
(50-461/85038).
G.
-Review of' Construction Deficiency Reports and Vendor Defect
Reports
1.
NRC was notified by the licensee of 29 construction defie:mies
per the requirements of 10 CFR 50.55(e).
Of the 27 N, e,
thirteen were subsequentla withdrawn or determined to be not
reportable by the licensee.
Corrective actions were initiated
by the licensee for all deficiencies.
Two of the remaining 14
deficiency reports were reviewed and documented as closed in NRC
inspection reports.
Below is a listing of the reportable
construction deficiency reports made during the SALP 5
assessment period:
Number
Description
461/84006-EE
Damage to Conax electrical penetration
i
terminal blocks
461/84007-EE
Preop test procedures reference
incorrect specifications.
461/84016-EE
Workmanship discrepancies with wiring
in HPCS diesel generator panels.
461/84018-EE
300 pieces of 1/2 x 15 x 15 inch A-36
steel plate has low yield and tensile
strength.
,
I
461/84019-EE
Nelson studs on embedment plates.
461/84021-EE
Battery charger conductors pulled
out of lugs.
461/84023-EE
Ruskin interlocking fire dampers
!
not closed.
461/85003-EE
Hollow core masonry units (CMU)'
lack objective evidence that.they
meet three hour rating claimed in
fire protection evaluation report.
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461/85004-EE
' 27 butterfly dampers have defective
-fillet welds; Pacific Air Products.
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Number
Description
461/85005-EE
HVAC contractor did not address
impact of design changes on items
previously inspected.
461/85006-EE
Vendor supplied electrical panels
(Eberline and Power Conversion
Products) have miswired circuits
and utilize incorrect wiring and
terminating techniques.
461/85007-EE
Horizontal piping supports for fire
suppression systems have not been
designed.
461/85008-EE
Effective throat size of flared
bevel arove welds on piping and
electrical supports does not meet
requirements of specifications.
461/85009-EE
Civil structural design changes have
not in all cases been added to
drawings as required by procedures.
The' increase in construction deficiency reports over the 20
reports submitted during the previous SALP period was due in
part to increased licensee activities in the preoperational
testing area, and to the NRC Construction Appraisal Team
Inspection. A review of the nature and details of the items
reported, and the timeliness of reporting indicates that the
licensee maintains a proper reporting threshold and is
responsive to the reporting requirements of 10 CFR 50.55(e).
The quality of written reports and the associated analysis
reflects favorably on licensee management and staff. One
weakness observed by NRC was that final reports almost
exclusively do not reflect completion of all work and associated
corrective actions. This matter has been discussed with
licensee management on several occasions.
2.
NRC was notified by the licensee of ten reportable defects
per the requirements of-10 CFR 21.
Investigations of the
l
matters have been initiated by the' licensee on all items.
l
Below is a list of the vendor defect reports made to NRC during
the SALP 5 assessment period:
Number-
Description
461/84003-PP
Hub Inc.. pipe (3500 ft) not
,
ultrasonically tested.
.
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.
.
.
. -
.
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Number
Description
461/84004-PP
Circuit breaker environmental test
failure of circuit for hydrogen
rec'ombiner.
461/84005-PP
Rosemount transmitter amplifier board
functional problem.
461/84006-PP
Deficiencies in ELMA Power supplies.
461/84007-PP
General Electric improper setting of
Topaz inverter low voltage shutoff.
461/85001-PP
Titus model 272 grilles internal
tension wires used for adjustment of
blades will not remain in place when
blades are closing.
461/85002-PP
Rosemount model 1153B transmitters
have anvironmental leak.
461/85003-PP
General Elenric model CR 2940 control
switches not environmentally qualified.
461/85004-PP
Technology for Energy Corporation (TEC)
model 914-1 acoustic valve flow monitor
module failure of indicator to reset.
461/85005-PP
Basic Engineers sway strut and snubber
failure.
The number of vendor defect reports made during the assessment
period was slightly higher than the number made during the
previous SALP period.
The quality of the licensee's review and
associated analysis of vendor defect reports did not approach
that done for construction deficiency reports.
This matter has
been discussed with licensee management on several occasions
and some improvement h'as been noted.
H.
Noncompliance Data
Facility Name:
Clinton Power Station
Docket:
50-461
Inspection Numbers:
84006 through 84043
85001 through 85042
44;
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-TABLE 1
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SALP 5
"
.
i
Functional Area
Violations and Severity Level
I
II
III
IV
V
'
A.
Soils and-
. Foundations
B.
Containment and Other
Safety Related Structures
.
'
-Supports
C.
Piping. Systems and
Supports
2
D.
Safety Related Components
E.
Support Systems
F.
Electrical Power Supply
and Distribution
2
G.
Instrumentation and
s
-Control Systems
1
H.
Quality Programs and
Administrative Controls-
3
i
.I.
Preoperational Testing
lJ.
Radiological Controls
K.
Security
L. ' Operational Readiness
M.
Licensing Actions
N.
Overinspection
.
TOTALS
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45I
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