ML20151K019
| ML20151K019 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/25/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20151J994 | List: |
| References | |
| 50-461-97-11, NUDOCS 9708050306 | |
| Download: ML20151K019 (38) | |
See also: IR 05000461/1997011
Text
. _ _
- . _ - _ - . . - . . _ . . . _ . - ~ . - . . . . . . _ _
.
. U.S. NUCLEAR REGULATORY COMMISSION
REGION 111
.
! Docket Nos: 50-461
License Nos: NPF-62
Report No: 50-461/97011 (DRP)
I
Licensee: Illinois Power Company i
l
i
Facility: Clinton Power Station
Location: Route 54 West
Clinton, IL 61727
Dates: April 7 - May 23,1997
l
Inspectors: F.D. Brown, Acting Senior Resident
K.K. Stoedter, Resident inspector
R.A. Langstaff, Resident inspector
D.M. Chyu, Electrical Systems inspector
M. Parker, Senior Resident, Palisades
S. Ray, Senior Resident, Prairie Island
Approved by: Christopher G. Miller, Acting Chief, Branch 4
Division of Reactor Projects
l
'
l
\ .,
t
9708050306 970725
.
PDR ADOCK 05000461
( G PDR
i
v(
~-
.
EXECUTIVE SUMMARY
'
Clinton Power Station
NRC Inspection Report 50-461/97011 (DRP) '
This inspection included aspects of licensee operations, engineering, maintenance, and
plant support. The report covers a 6-week period of supplemented resident inspection.
Ooerations
The NRC closely monitored the implementation of the current procedure adherence
and adequacy policy. Generalimprovement over previous performance was noted.
Prompt changes were made to procedures which could not be implemented as
written. (Section 01)
Operator turnovers usually covered the appropriate information. The inspectors
)
observed an on-duty operating crew demonstrate a questioning attitude and
prudently avoid an unnecessary TS LCO entry. However, the inspectors identified
several examples of opportunity for improved performance. (Section 01.1)
!
The inspectors identified that a non-licensed operator and a maintenance mechanic
were in the process of violating procedural steps during a surveillance on the
control room ventilation system. A potentially weak independent verification was
also identified by the inspectors. One violation was identified. (Section 01.2) l
The inspectors identified that the system drawing for the safety related diesel
generator ventilation system was incorrect and that breakers in safety MCCs were
mislabeled. This condition had existed since start-up, but had not been identified or
corrected by the licensee. (Section 02.1)
The inspectors identified that valves in the air start systems for all three Emergency
Diesel Generators (EDGs), and a valve in the fuel oil system for the Division lli EDG,
were not locked open as required by the licensee's locked valve program. One
violation was identified. (Section 02.3) l
Maintenance
The failure to adequately document and communicate the status of job conditions
resulted in maintenance induced damage to a containment isolation valve. One
violation was identified. (Section M1.3)
Operations and maintenance failed to establish and verify that plant protective logic
was in the appropriate condition which resulted in an inadvertent engineered safety
features actuation of the standby gas treatment system during performance of a
surveillance. One violation was identified. (Section M1.4)
2
-. - . . .- .. - -._.-_ _ - - - --- _ - ~ - - . -- - .
.
.
l
l
.
A controls and instrumentation techbician lifted leads not covered by the procedure
-
and a runback of the "A" reactor recirculation flow control valve resulted. One
violation was identified. (Section M1. 5)
The licensee performed tests to determine the revision (identification) number for
three breakers before performing "as-found" functional tests. This preconditioning
resulted in potentially invalid test data. One violation was identified.
(Section M2.1)
- i
The inspectors noted apparent material condition problems with PosiSeal butterfly I
valves in service water systems, synch check relays in safety related breakers, and
lubricants in motor operated valves. The licensee focused on repairing the specific
problems, not on identifying repetitive or potential common mode failure
mechanisms, or on preventing reoccurrences. The inspectors were also concerned
that material condition problems identified on maintenance work requests received
limited review for generic implications. (Section M2.4)
The inspectors identified that the licensee procedure for controlling material which
could clog emergency core cooling system strainers in a post lost of coolant
accident environment was inadequate. After a slow initial response to this issue,
the licensee initiated actions to resolve the concem. The issue of degraded . ,
containment coatings had not been resolved at the end of the period. One violation l
,
1
was identified. (Section M2.5)
Enaineerina
1
The inspectors identified that the licensee failed to analyze or evaluate the potential
loads on safety related piping induced by temporary scaffolding during a seismic
! event. One violation was identified. (Section E1.1) ;
The licensee identified a potentially generic concern associated with the seismic
qualification of circuit breaker cabinets when breakers are removed. The inspectors
considered the identification of this issue to have been indicative of a proactive l
safety consciousness. The implementation of a procedure to address this issue
was inadequate. The inspectors identified concerns with the licensee's stated
approach to assessing cabinet operability. (Section E1.2)
Plant Succort
- i
The inspectors observed an individual reaching into a contamination area without ~
protective clothing. One violation was identified. (Section R1.2)
i
.
! '
- 3
a
i
l
__ - . -
. - - - _ ..
.
Reoort Details
Summarv of Plant Status
The plant remained shutdown throughout this inspection period.
l. Ooerations
01 Conduct of Operations !
The inspectors noted that the sensitivity to procedural adequacy and adherence within the
Operations Department had, with few exceptions, improved from previous inspection
periods. Only two examples of clear non-compliance with working procedures were
identified; one of these occurred early in the inspection period, and the other was in the
Maintenance area. These examples are discussed in more detail in Sections 01.2 and
M1.5. Procedures were used as written or were changed prior to continuing with work
during all other direct inspector observations. Approximately 200 procedure changes were
processed during this inspection period. Despite these improvements, the inspectors made
several observations that indicated continued opportunities for improvement in the general
conduct of operations.
01.1 Conduct of Ooerations in the Control Room
a. Inspection Scooe (71707)
The inspectors observed Main Control Room (MCR) turnovers to verify that all
i necessary information conceming plant system status was discussed and ;
understood. The inspectors also performed routine observation of the general
l
conduct of operations within the MCR using inspection Procedure 71707. '
b. Observations and Findinas
!
I
The information provided in tumovers was generally adequate to ensure that
oncoming crews were aware of plant status and planned activities.
Good Performance involvino Shutdown Coolino
On April 8,1997, the inspectors entered the MCR and observed the on-duty crew
discussing a procedure change. A reactor operator (RO) informed the inspectors
! that a Residual Heat Pemoval (RHR) "A" heat exchanger inlet valve 1SXO82A, had
Valve Operability," was written for performance of this valve stroking with Division
l SX out of service. Existiag plant conditions did not support removing Division l
SX from service, so a temporary procedure change was being processed to stroke
, the valve independent of a full divisional outage. Two alternatives existed. The
i
,
first alternative involved securing shutdown cooling, and entering a Technical
Specification (TS) Limitinc Sondition for Operation (LCO). The shift understood that
<
,
4
d
0
- - -- - - . - - . . _ - . _~_ - - . - - -- . _ - . . . . . - - - . - .
.
.
a member of plant management had directed that this alternative be used. The
- second altemative involved more demanding work for the operators in that a ,
j
manual valve in a contamination area would have to be closed and then reopened, '
but this alternative would not require that shutdown cooling be secured. The crew
subsequently revised Procedure CPS 9069.02 to require the more labor intensive
alternative, avoiding the otherwise unnecessary TS LCO entry. The inspectors j
considered the crew's decision to change the operating procedure in a way which
avoided an unnecessary TS LCO entry to be indicative of positive performance in
operations.
Ooerator Unfamiliarity with Annunciator Status
During a MCR panel walkdown on April 7,1997 the inspectors noticed that the -
annunciators for the inboard and outboard reactor core isolation cooling system
(RCIC) turbine exhaust vacuum breakers were lit. When the inspectors inquired as
to why these specific annunciators were lit, one RO stated that he was unsure. A
i
second RO indicated that the status of RCIC was not important since the system
was out of service due to the plant operating in Mode 4. Neither RO attempted to
determine why the annunciators were lit. Two days later, the inspectors posed the
same question (reason for the RCIC annunciators)'to ancther RO. !n this instance,
,
'
the RO stated that he could not immediately recall the reason why the annunciators
were lit; however, he quickly reached for the annunciator response procedure and l
j
l
informed the inspectors that the annunciators were lit due to a Group 7 isolation on j
low steam pressure.
Although the RCIC system was not operable while in Mode 4, the inspectors were
i
concerned by the operators' unfamiliarity with annunciator status and causes for
changes in system configuration. Licensee management told the inspectors that
l
they planned to increase annunciator awareness as part of the improvements in
l control room professionalism. !
l
Weak Communications Durina Surveillance l
On April 28,1997, the inspectors observed a portion of surveillance Procedure CPS
9070.01, " Control Room HVAC Filter Package Operability Test Run," Revision 25.
This surveillance required a 10-hour system run with system data to be recorded
every two hours. The procedure stated that five of the parameters were to be
recorded from local instruments in the field, and the sixth, system flow, was to be ;
recorded from control room instrumentation. The sheet on which the data was j
recorded was separate from the procedure, and did not identify where the data was '
to be obtained. The inspectors observed that data from the field was recorded in j
the record copy of the surveillance data sheet based on information conveyed over
the phone. The inspectors were concerned that each of the five individual values ;
was not provided to the operator, rather, the operator was told the data was "the I
same as the readings two hours ago." The inspectors felt that this communication
,
technique could result in misrecording one of the five values from the field or the
failure of the control room operator to verify that the sixth value had not changed.
!
l The inspectors independently obtained the local and control room instrument values t
4
i 5
1
i
i
d
l
1
-- .- - . . -. _, .-
i
l
and verified that they were consistent with the recorded data. The on-duty licensee ;
- staff informed the inspectors that this was a routine surveillance with data that did l
not typically change during the test run, and that the observed communication
techniques were within management's expectations. The Operations Manager
subsequently informed the inspectors that this was an example of an opportunity to I
improve communication techniques. l
Trackina Surveillance Dalga
On May 7,1997, operations personnel declared the high pressure core spray l
(HPCS) system inoperable due to exceeding the allowable surveillance frequency,
including the TS extension of 25%. Although operations monitored the surveillance
expiration dates of numerous systems including HPCS, the scheduling of the HPCS
surveillance was overlooked during turnovers and was not scheduled for
.
I
performance. Operations personnel recognized the need to perform the HPCS
l
surveillance test approximately ono hour before the system needed to be declared
l
inoperable. Since the surveillance test took several hours to perform, operations
l
personnel appropriately declared HPCS inoperable and ensured that actions with a
potential to drain the reactor vessel had been suspended in accordance with l
'
technical specifications,
c. Conclusion
Operator tumovers usually covered the appropriate information. The inspectors
observed an on-duty operating crew demonstrate a questioning attitude and
prudently avoid an unnecessary TS LCO entry. However, the inspectors identified l
several examples of opportunity for improved performance.
01.2 Weaknesses in Performance of a Surveillance
E\
a. Insoection Scooe (61726/71707)
The inspectors observed the performance of surveillance CPS 9170.02, " Control
Room HVAC Chilled Water Valve Operability Test," Revision 26, performed on
April 8,1997.
b. Observations and Findinas
On April 1,1997, the licensee's revised procedural adherence policy, which
required procedure steps to be performed in the order written unless otherwise
specified, became effective. During the performance of Procedure CPS 9170.02,
the inspectors observed a non-licensed operator (NLO) give a maintenance
mechanic permission to perform procedural steps out of sequence. The surveillance
procedure required that a flange be installed on line OVC120E, per step 8.1.6, in
order to complete in-service testing on the control room ventilation (VC) chilled
,
water shutdown service water makeup check valve. Upon test completion, the
l
mechanic inquired if the installed flange could be removed. The NLO briefly
reviewed the procedure and gave the mechanic permission to remove the flange.
I 6
_ _ _ _ __ _ __ . __ _
\ o
i
As the mechanic began loosening the flange connection, the inspectors recognized
!
!- that the next procedure step instructed the closure of the auto makeup inlet
isolation valve. The procedure step did not reference the removal of the flange.
The inspectors called the mechanic's attention to this fact, and the mechanic
.
stopped the flange removal. The pipe behind the flange was pressurized with low
energy chilled water at the time of the inspectors' observation.
The failure to perform procedure steps in the order stated by the procedure was
considered a violation (50-461/97011-01) of TS 5.4.1.
Step 8.1.12 directed that valve OVC016A be closed and independently verified.
The inspectors observed that the independent verifier was in close proximity to the
procedure performer and possibly watched the step' performance. The inspectors
then asked the independent verifier if the independent verification method used met
the time and distance expectations delineated in Procedure CPS 1401.01, " Conduct
of Operations," Revision 22. The independent verifier stated that his presence at
the job site was acceptable as long as he was not directing the actions of the
individual perforrning the surveillance. Procedure CPS 1401.01, stated that '
independent verification was " intended" to have both time and distance between
the act and the verification. The inspectors discussed the apparent inconsistency
between the operator's understanding of the requirements and Procedure CPS
1401.01's stated " intent." Operations Department rnanagers informed the
inspectors that the observed performance did not completely satisfy plant
management's expectations, but did satisfy the plant's procedural requirements.
The inspectors will continue to assess the effectiveness of the plant's independent
verification procedures and practices under inspector Follow-up System item eel
50-461/96015-01 a.
The inspectors also observed the independent verification of Step 8.1.22 which
ensured that instrument vent valve OPC-VC550AV was closed. Upon finding the
instrument, the independent verifier noticed that the vent valve was not labeled
with an equipment identification number (EIN). The procedure performer explained
that since the instrument was labeled, and the instrument had only one vent, he
was confident that the correct valve was manipulated. The independent verifier
was not comfortable signing the procedure step and contacted the control room for
further guidance. It was later determined that the performer manipulated the
correct valve. The inspectors considered the independent verifier's actions to be
appropriate.
c. Conclusions
The inspectors identified that a N1.0 and a maintenance mechanic were in the
process of violating procedural steps during a surveillance on the Control Room
ventilation system. A potentially weak independent verification was eko identified
by the inspectors. One violation was identified.
i
I
. . _ . . _ _ _ . . _ - _ _ _ _ _ _ _ _ _ _ _ . . . . . _ _ _ _ _ _ _ _ . . . _ . _ _ _ _ _ . -
-
l
l
c
.02 Operational Status of Facilities and Equipment
-
!
02.1 Enaineered Safety Feature (ESF) System Walkdowns (71707) l
a. Insoection Scone -
t
The inspectors used inspection Procedure 71707 to walkdown portions of the low
l
pressure core spray system (LPCS), the diesel generator room ventilation system ,
(VD) and the Division ll safety related switchgear. Although not an ESF system, ,
the inspectors also walked down portions of the component cooling water (CC)
system.
b. Observations and Findinas
i
On April 14,1997, while performing a routine walkdown of safety related and ESF
switchgear, the inspectors noted that the 480 VAC breaker at Motor Control Center '
(MCC) 181, cubicle 9D, was in the open, deenergized, position. This breaker was
labeled as."D.G. Roorr 1B Vent Sys. Damper 1VD12YB." The inspectors asked the
Line Assistant Shift Supervisor (LASS) why the breaker was deenergized. The .
LASS reviewed the mechanical system drawing for the system, M05-1103, " Diesel *'
Gen. Room Ventilation (VD)," Revision L, and concluded that 1VD12YB was a '
motor operated valve (MOV) which appeared to be required for system balancing.
The LASS could not immediately determine why the damper breaker was open.
'
The licensee subsequently determined that Field Engineering Change Notice (FECN)
14531 had removed power from Dampers 1VD12YA,1VD12YB, and 1VD12YC
during post-construction system testing. The MCC label for 1VD12YC had been
,
l l
corrected to read " spare," but the MCC labels for 1VD12YA and 1VD12YB had not '
been updated. The licensee initiated a condition report (CR) and hung caution tags
on the breakers labeled as 1VD12YA and 1VD12YB to indicate that they were
" spares."
The inspectors walked down the VD systems and determined that dampers
1VD12YA, B, and C were installed, and were provided with self contained hydraulic i
actuators. Based upon the licensee's determination that no power was supplied to
these actuators, they were essentially manual valves, contrary to the system '
drawing.
The inspectors reviewed drawing M05-1103 to determine whether it contained
other errors. No other discrepancies were noted.
The inspectors discussed the VD system observations with the cognizant system
l engineer. The system engineer informed the inspectors that an operator had
- identified the mislabeling of the 480 VAC beakers for 1VD12YA and B in
j January 1997, but that the breaker labels had not yet been corrected when the
inspectors noted the problem. The M05-1103 discrepancies had not previously
been identified or documented.
1
J
$
i 8
I
$
i
5
.
,
- - . _ _ - . - . - . -. . .. --- -- ._.- -_- - . - - . - - - - -.
l
l
l
The inspectors considered the incomplete implementation of FECN 14531 and the 1
'
discrepancies of M05-1103 to be examples of a problem with design control.
However, this problem was of minor significance and is being treated as a
Non-Cited Violation (50-461/97011-02) consistent with Section IV of the NB;
Enforcement Poliev. The inspectors were concemed that system walkdowns by
operators and system engineers were weak, since a non-energized breaker in a
safety related MCC had not been investigated and dispositioned during nine years 3
4
of plant operation. Similar concerns are identified in Section M2.3 of this report.
c. Conclusions
As the result of a system walkdown, the inspectors identified that the system
drawing for the safety related VD system was incorrect and that breakers in safety
!
MCCs were mislabeled. These conditions had existed since start-up, but had not
been corrected by the licensee. The conditions did not affect system operability.
No concerns were identified during the LPCS or CC walkdowns.
02.2 Inconsistencies Found Within Eauioment Control Proaram *
^
a. Insoection Scone (71707)
l
During the course of plant tours, the inspectors verified the position of various
components and that danger and caution tags were placed on the proper
equipment. "
b. Observations and Findinas
l
During a make-up water pumphouse (MWPH) walkdown, the inspectors noted that
the EIN on danger tag 57 for tagout 96-1049 did not match the nameplate on the
' breaker cubicle. Specifically, the danger tag stated the EIN as OWM12PA (power
supply for the makeup demineralize pump) while the breaker cubicle ncmeplate
stated " spare."
The licensee told the inspectors that the EIN for the breaker within the cubicle was
previously OWM12PA. However, the breaker was abandoned as part of a upgrade
to the MWPH, and the cubicle nameplate was changed without updating the tagout
information.
I
inspection Report 50-461/96009 discussed deficiencies in the safety tagging
)
program, including the absence of a feedback mechanism to correct ta0ging .
inconsistencies. The safety tagging supervisor explained to the inspectors that
l
feedback to correct changes in the plant due to modifications was provided prior to
i
releasing the modification for operations. However, feedback to correct tagging {
! !
deficiencies which occurred during the installation of a modification, or due to the ;
,
abandonment of equipment, did not normally occur and was not required by the l
] licensee's safety tagging or modification programs. The inspectors were concerned
,
'
.
<
_ - _ . . _ . _ _ . _ _ . . _ . -
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
1
o
by the practice of not updating tagouts during modifications since post modification
~ testing could require energization of mislabeled components prior to the
modification's release for operation. This could reduce the effectiveness of the
personnel safety provided by the tagout. The licensee acknowledged this issue
during discussion with the inspectors.
c. Conclusions
The inspectors identified that the licensee's safety tagging program allowed
inconsistencies between equipment EINs and the EIN listed on safety tags to exist
during the performance of modifications. The inspectors considered this a
weakness since the level of personnel safety during post modification testing could
be affected by the inconsistent nomenclature. ~
02.3 Imolementation of Locked Valve Proaram on Emeraency Diesel GeneratorJEDG)
Sucoort Systems
a. Insoection Scooe
The inspectors performed routine walkdowns of the EDGs and their support
systems and compared the observations to the licensee's program requirements,
b. Observations and Findinas
Procedure CPS 1401.01, " Conduct of Operations," Revision 26, Section 8.5.2,
required that components, the unauthorized manipulation of which could
compromise plant safety or availability, be chained, lockwired, or otherwise suitably
locked. The inspectors observed that six valves in the air start system for the
Division i EDG, and six valves in the air start system for the Division ll EDG were
not locked open. Four valves in the air start system for Division 111 were not locked
open. The valves involved were 1DG150 through 1DG165. One valve, the supply
emergency cutoff valve in the Division 111 fuel oil system, was also not locked open.
The inspectors questioned plant staff as to why the air start and fuel oil valves
were not locked open since the closure of one or more of these valves would
appear to compromise the availability of the EDGs. Plant staff acknowledged that
the valves should have been locked open, and were in the process of locking the
valves open at the end of the inspection period. Plant staff did not know why the
valves had not previously been locked or tagged. The failure to lock open the
Division lli EDG fuel oil supply cutoff Valve and valves 1DG150 through 1DG165 as
required by Procedure CPS 1401.01 was a violation (50-461/97011-03) of TS 5.4.1.
c. Conclusions
The inspectors identified that valves in the air start systems for all three EDGs, and
a valve in the fuel oil system for the Division 111 EDG, were not locked open as
required by the licensee's locked valve program. One violation was identified.
10
_ - . _ ___ . . - . .. .__ ___ _ ._ . _ . _ . . _ . _
.
.
i 07 Quality Assurance in Operations
-
07.1
Review of Emeroency Resoonse/Emeroency Ooeratino Procedures (EOPs) Audit
a. Insoection Scoce (71707)
The inspectors reviewed Audit Report 038-97-03, " Emergency
Response / Emergency Operating Procedures," issued April 29,1997.
b. Observations and Findinos
-
The inspectors confirmed, through discussions with the lead auditor, that no walk
throughs of EOPs had been conducted during performance of Audit Report Q38-97-
03. The lead auditor stated that procedure walk throughs were more of a
performance review rather than a compliance review. Due to recent chan<;es in
philosophy, Nuclear Assessment management had determined that audits should
focus more on compliance and that surveillances would focus more on
performance. However, the lead auditor was not aware of whether surveillances
had reviewed EOPs from a performance standpoint. Based on discussions with the
surveillance supervisor, the inspectors determined that no surveillance had covered
EOP walk throughs in the previous year. The inspectors considered procedure walk
throughs an important assessment tool for: 1) assessing the adequacy of
procedure validation and verification (V&V),2) scnfirming that changes in the field
since V&V have not adversely affected performance of the procedure, and 3)
assessing operator training and knowledge.
c. Conclusions
.
An audit of EOPs lacked depth in that procedures were not verified in the field. Not
I performing procedure walkthroughs of a sample of EOPs, either through audits or
surveillances, was considered a weakness.
II. Maintenance
M1 Conduct of Maintenance
- a. insoection Scone (61726/62703)
The inspectors observed or reviewed portions of the following surveillance and
maintenance work requests (MWRs) and other maintenance activities.
-MWR D76266/ CPS 8433.01 Generic Procedure for 125 VDC Battery
j Maintenance
-MWR D71146 Packing Replacement for Reactor Water
.
i
Cleanup Valve 1G33F053
f
8
11
I
_
. ._ _ ___ _ . . _ . . _ . _ _ _ . _ _ _ _ . _ _ . _ . _ . . . _ _ _ _ _ _ _ _ . . . _ . . _ _ _ _ . . _ . _ . _ ..
.
.
-MWR D76456 Rotor Work on RCIC Turbine Exhaust
, Vacuum Breaker
L
l
-PCIFWM135 Feedwater Flow Line A Flow Transmitter
-
Loop Calibration
-CPS 9053.07 RHR B/C Pumps and RHR B/C Water Leg
,
i
Pump Operability
-CPS 9170.02 Control Room HVAC Chilled Water Valve
Operability Test
-CPS 9382.02 125 VDC Battery ICV and Battery
Charger Checks
l -CPS 9532.61 CRVICS Fuel Building Exhaust Radiation
l
t- 1 RIX-PR006A (B,C,D) Channel Functional
l Test
-CPS 9069.02 Div i SX Valve Operability
!
-CPS 9070.01 Control Room HVAC Filter Package
Operability Test Run
-CPS 8410.07 Reactor Recirculation 6900 Volt Vacuum
Circuit Breaker Maintenance
b. Observations and Findinas
l
The inspectors found the work performed under these activities to be generally
acceptable, with procedures present and in use. Comments for specific work
activities are discussed in further detail below. Due to the operator performance
issues identified during the performance of Procedure CPS 9170.02, all relevant ;
comments were included in Section 01.2. !
,
i
l M1.2 Performance of 125VDC Batterv Maintenance
i
!
a. Insoection Scoos (62703) l
The inspectors observed portions of the maintenance performed on the Division 11
125VDC battery under MWR D76266.
b. Observations and Findinas
l
While torquing the battery terminals of a Division il battery, the torque wrench
! s.ipped and came into contact with a neighboring battery post, causing a short
i oischarge. Although the torque wrench had been taped to provide electrical
j
insulation prior to use, the electrician had not taped the area around the torque
- 12 !
I
!
i
!
. . . - - . _ - - -
l
.
wrench dial. No personnel were injured and only minor damage to the battery post
,
occurred.
l
The system engineer performed an as-found inspection and noted no battery ,
abnormalities. However, to ensure that the battery internals were not dam'aged, '
the system engineer requested that specific gravity and cell voltage checks be
performed on both cells in their discharged condition.
The inspectors later learned that the electricians had decided not to perform the
requested cell voltage and specific gravity checks since these actions were not
supported by an approved procedure. Electrical Maintenance (EM) personnel did 1
not communicate their inability to perform the requested checks to the system
1
engineer. The cell voltage and specific gravity readings for all cells were obtained
i
after the cells were recharged and prior to returning the battery to service. No
l
deficiencies were identified with cell voltage or specific gravity. l
The inspectors reviewed the condition report (CR) associated with this event and
questioned the description of the immediate actions taken. Specifically, the
immediate corrective actions stated " stopped work, directed that a set of gravities
be taken on Cells 4 and 5, had NSED evaluate damage." These actions were
signed as complete although, as explained above, the pre-recharge " set of
gravities" requested by the system engineer were not obtained.
Procedure CPS 1016.01, " Condition Reports," Revision 29, Step 8.1.4.2a, states
l
" document immediate actions and ensure actions are carried out and/or initiated 1
.
as necessary and initial /date when complete in space provided on CPS No.
l
1016.01F001." The inspectors considered EM supervision's signoff that the initial
corrective actions were complete when alternate actions were performed to be a
i
violation of Procedure CPS 1016.01. However, this violation is of minor
significance and is being treated as a Non-Cited Violation (50-461/97011-04)
consistent with Section IV of the NRC Enforcement Poliev. See Section M7.1 for
additional discussion of this issue.
c. Conclusions
Poor insulation of a torque wrench resulted in shorting between two 125VDC
safety related batteries. No significant damage occurred to the batteries. EM
,
personnel failed to obtain revision to a corrective action document when the
!
specified actions could not be completed.
M1.3 Damaoe to MOV Motor Overload Heaters Due to inadeouate Tumover
a. Insoection Scoce (62703)
The inspectors reviewed the circumstances surrounding damage to the reactor core
isolation cooling (RCIC) exhaust vacuum breaker outboard isolation valve
(1E51F077) during VOTESm testing.
13
l
l
l
l
l
_ . _ _ _ . _ _ _ . _ _ _ . . _ _ _ _ _ _ _ _ . _ _ . _ . . _ _ . _ . _ _ _ _ _ _ . _ _ -
l
I
l ..
On April 23,1997, night shift EM personnel suspended VOTES testing of Valve
1E51F077 to correct problems with a limit switch. While testing was suspended.
l~ operations personnel noticed that the associated MOV test prep switch (TPS) was
l not in its usual position, and asked the EM personnel whether it could be retumed
!
l
to " normal." The EM and operations personnel concluded that the TPS no longer
needed to be iri "u. pass" since testing of the MOV was suspended. Following this
discussion, operations personnel retumed the TPS to the normal position.
l On April 24, the day shift ems completed work on the limit switch and resumed
preparations for VOTES testing. While the day shift ems verified the position of
many tags prior to resuming work, verification of all previously performed steps
was not required. The night shift ems had not communicated the repositioning of
l the MOV TPS during tumover with the day shift EM group leader and had not
included this information within the MWR continuation sheets. _ The MOV TPS was
not repositioned prior to performing the VOTES test. This resulted in EM and
engineering personnel performing the test without thermal overload or torque
switch protection (torque switch protection was bypassed due to test set-up). The
MOV motor and breaker sustained damage when the valve was subjected to a
l locked rotor condition.
b. Observations and Findinas
l
The licensee wrote condition report CR 1-97-04-187 describing the event and held
I a critique (EM 97-010). Specific observations conceming the critique are discussed
!
in Section M7.3.
!
Procedure CPS 1501.02, " Conduct of Maintenance," Revision 18, Step 8.1.4.6,-
!
which the inspectors reviewed, stated "if work is performed during more than one
,
shift provide information to succeeding shift personnel to assure work is completed i
in a safe an effective manner." The inspectors considered the failure to provide
information on the status of the MOV TPS to be a violation (50-461/97011-05) of l
l
c. Conclusions
The failure to adequately document and turnover the status of job conditions
resulted in maintenance induced damage to a containment isolation valve. A
violation of procedure was identified.
M1.4 initiation of Standbv Gas Treatment (VG) System Durina Surveillance Activity
l a. Insoection Scone (61726)
l l
The inspectors reviewed the circumstances surrounding an inadvertent initiation of
the VG system during a channel functional test of process radiation monitor
PR006A.
l
'
l
,
14
i
- - ._. _ __. _ - _ _ , . - ., -- , ._ - _ - _ . _ .
. . . . . . . . .
.
b.
Observations and Findino_ s
~
\
The inadvertent actuation of the VG system occurred r ng a trip signal
due to inse ti
to Process Radiation Monitor PR006A while monitor PR006D w as inadvertently in a
tripped condition. Monitor PR006D was placed ,
in trip , when
on March 6 1997
' local trip switch. Operations clearedut did tagout
e
not
place the local trip switch back to the normal position due to inadequat
, ,
e tagout
restoration guidance. Specifically, the caution tagout restoration
e as
erred
position r
to the removal of the caution tag without giving guidance e position of the
to th
local trip
remained switch.
in trip. Because
Procedure CPS of this error, the local trip
or PR006D
switch for monit
Step 8.6.3, required that the proper restoration r ag position be identi
,
,
removal. The failure to include the restoration position wc on for the local trip s i
monitor PR006D was a violation (50-461/97011-06) of TS 5.41 ..
During the critique for the inadvertent VG system actuation lice
,
one procedure noncompliance. Step 8.1.8 of Procedure nsee
CPS staff identified
9532 61 "CRVICS
. ,
Revision 38, directed the controlsan toand onal Test," instrumentat
the components for each division were in the untripped conditi ensure
indicated approximately 0 volts.rmed The
ng that the C&l
Step 8.1.8
DMMtechnician th
and ground as zero volts when it was -
actually 120 vo
s error, the
C&1 technician did not identify that monitor PR006D ped condition.
was in the trip
The licensee determined that the physical constraints s voltage
associated with thi
revising the test process so that accurate ue
e y to be
voltage re
in accordance with Procedure CPS 9532.61obtained. The failu
e
was licensee identifi d and corrective
Violation (50-461/97011-07) consistent with Sect
..
-
e
c. Conclusions
The failure of Operations and Maintenance toy establish at plant
and verif th
protective logic was in the appropriate condition resulted in an inadve t
r ent ESF VG
cited violation were identified. system actuation during one non-
performance of a surv
M1.5
a.
Lifted Lead Results in Reactor Recirculation a ve Runback (RR) Flow Con
Insoection Scone (617261
The inspectors reviewed the details surrounding a runback of the "A" RR
control valve during performance of a preventivefinw maintenance (PM) acti
.
\ 15
-
.- . - - . _ . - . ~ . - - - - . . - - - - . - . - . - . . - - - - - - - - - ~ _ - ~ .
!
!
!
.
?
b. Observations and Findinos
On May 14,1997 C&l personnel performed PM task PCIFWM135, calibration of the
feedwater flow measurement instrument loop. The PM data sheet instructed the
C&l technician to obtain correct contact indication between terminals 13 and 14 on
trip unit 1C34-K618A by measuring the voltage between these two terminals. Due
i
to plant conditions, correct contact indication could not be obtained using the
j
above method because the indication was masked by position of the contacts :
between Terminals 9 and 10 (Terminals 9,10,13, and 14 are in parallel). To
obtain an accurate contact indication, the technician lifted lead between Terminals
13 and 14. Because wiring from Terminal 14 supplied power to trip units further
downstream, power was lost to other trip units as the lead was lifted. ' This
produced an unexpected runback of the "A" RR flow control valve (the "B" valve
was locked out prior to the evont). The RR flow control valves are a reactivity
control when the unit is operating.
Operations personnelinitiated a CR and held a critique following this event. The
technician involved in the event stated that he did not consult any prints prior to
lifting the lead because he assumed that his actions would have no effect on the
plant. Lifting of leads was not authorized within the work package. C&l
supervision noted that the technician's actions were not covered within the system ;
impact matrix for the task. The inspectors reviewed the work package and
i
determined that two additionalleads were lifted without an appropriate system
impact matrix.
Procedure CPS 1501.02, " Conduct of Maintenance," Revision 18, Step 4.8, stated
"if the work requires lif ting leads or otherwise interrupting electrical circuit
continuity... complete a system impact matrix and attach it to the work document."
The inspectors considered the failure to complete a system impact matrix to
!
' evaluate the consequences of actions not previously evaluated in accordance witli
Procedure CPS 1501.02 to be a violation (50-461/97011-08) of TS 5.4.1. The
inspectors were concerned by this occurrence because it involved a plant employee
who knowingly performed steps not covered by the work package in use, or by an
approved procedure, a performance issue for which plant management had initiated
substantial corrective actions.
c. Conclusions
A C&l technician lifted leads not covered by the procedure and a runback of the
i
' "A" reactor recirculation flow control valve resulted. One procedural violation was
identified.
i
i
.'
i 16
i
l
!
'
, - - - - - - , - , _ _ . . - - - - - _ - - , - . .
.
. -
-, . - . - - _ - . - . - - . - - . - _ . . . - . - . ~ . - . . ~ . . - . _ - . . - - . - . . . . .
L
.
.
M2 Maintenance and Material Condition of Facilities and Equipment
M2.1 B_r.gaker Testina
a. Insoection Scone (61726)
,
The inspectors reviewed:
i
l e Job No. PEMAP1012, "8410.04 Testing for 1DC14E4A/15"
e Job No. PEMAP1054, "8410.04 Testing for 1 AP41E2C"
,
e Job No. PEMAP1057, "8410.04 Testing for 1 AP73E13C"
t e CR 1-96-12-124, " Questionable Breaker Not Removed From System"
l e CPS 8410.04, " Molded Case Circuit Breaker Functional Testing and i
L Maintenance," Revision 9
e CPS 8410.05, " Type HE Molded Case Circuit Breaker Revision Level Test,"
Revision 4
L e Licensee responses to information Notices 89-21 and 96-24
! e Calculation Numbers 19-M-3, Revision 1,19AN-4, and 19-AQ-3 -
~
b. Observations and Findinos
On February 27,1989, the NRC issued information Notice (IN) 89-21, " Changes in
Performance Characteristics of Molded-Case Circuit Breakers." This IN discussed
instances in which vendors made revisions to the performance characteristics of
molded-case circuit breakers (MCCBs) without making corresponding revisions to :
the breaker's part number. In addressing this issue, the licensee re-classified MCCB l
part numbers as 1976/ Revision 3,1986/ Revision 3,1985/ Revision 4,
{
! 1989/ Revision 4, or 1990/ Revision 5 based on individual breaker performance
! characteristics. The licensee then performed reviews to determine whether the
newly classified breakers remained properly coordinated. The mviews determined
that all installed safety related breakers were acceptable. The licensee was still
reviewing the acceptability of the 120V distribution panels. In addition, the
l licensee determined that safety related MCCs could contain breakers having all
l MCCB revisions while non-safety related MCCs could only contain MCCBs having
! i
,
certain revisions.
i
,
f
i
l The licensee periodically performed Procedure CPS 8410.04 to verify the operability i
of installed MCCBs. This procedure applies a designated current to each tested
breaker to ascertain the proper breaker response. In addition, the licensee developed
Procedure CPS 8410.05 to test MCCBs in the plant's store room to verify or
identify these breakers' part number revisions prior to their use in the plant. The ,
inspectors determined that Step 8.1 of Procedure CPS 8410.05 required exercising l
(manually opening and closing) a tested breaker 5 times to. ensure free operation.
Therefore, the performance of Procedure CPS 8410.05 on an installed breaker prior
to performance of Procedure CPS 8410.04 would constitute breaker
, preconditioning in that test data obtained after manual cycling of the breaker would
j no longer represent the breakers'in service performance. The inspectors reviewed
!
i
l 17 l
r
, . , .y ,-
1 _
-, _ _ _ _ . . _ _ _ , , _ . . .-.,..__e,,, . -
. . . .. . - - - _ . - _ - - _ - . .
.
.
'
Procedure CPS 8410.04 and did not identify any preconditioning concerns. The
' licensee stated that Procedure CPS 8410.05 was not intended to be performed on
installed MCCBs.
On December 11,1996, Procedure CPS 8410.05 was partially performed on '
installed breaker 1 AP41E2C, which protects containment penetration 1C11-F003.
The licensee subsequently completed Procedure CPS 8410.04 with satisfactory
results, in response to the inspectors' questions, the licensee identified that on
October 9 and December 30,1996, installed Breakers 1 AP73E13C and
1DC14E4A/15, respectively, were also tested by Procedure CPS 8410.05 prior to
performance of Procedure CPS 8410.04.
!
l
10 CFR Part 50, Appendix B, Criterion V, " Procedures / required in part, that
l activities affecting quality be prescribed by procedures appropriate to the
circumstances. The licensee's procedures for testing Breakers 1 AP41E2C,
t
1 AP73E13C, and 1DC14E4A/15 were not appropriate in that they did not ensure
that as-found data was obtained for comparison with the as-found acceptance
,
' criteria required by 10 CFR Part 50, Appendix B, Criterion XI. These procedures
which were not appropriate to the circumstances were a violation (VIO 50-
461/97011-09) of 10 CFR Part 50, Appendix B, Criterion V.
c. Conclusions
The licensee performed tests to determine the revision number for three breakers
before performing "as-found" functional tests. This precenditioning resulted in
potentially invalid test data. A violation of 10 CFR Part 50, Appendix B, Criterion V
was identified.
M2.2 installation of Temocrary Modifications
'
a. Insoection Scooe (62707)
The inspectors were concerned that some temporary modifications (TMs) were
installed incorrectly with the supply line connected to load terminals and load
connected to line terminals. The ins:nctors redewed the following work packages:
MWR D73749 for TM 97-010, "Aternate Power to 120V distribution panelin
1 AP75E to keep VR/VQ Running," installed on January 26,1997
e
MWR D72424 for TM 96101, " Temporary Power for 1FCO23 During Division 2
Bus Outage," installed on December 30,1996, and removed on January 2,
,
'
1997.
e MWR D62937, for TM 97-014, " Temporary Power to Orarations Radio Base
I Station A, Receiver Cable 3 and 1JB674," installed on f . arch 3,1997
,
,
i
18
I
MWR D73885 for TM 97-004, " Install Temporary Modification to Maintain
- Power to 1 AP87E," installed on January 17,1997, and removed on
January 20,1997.
. e
MWR D72416 for installing TM to maintain power to 125 VDC MCC 1D during
4160 Bus 1B1 outage, installed on December 27,1996, and removed on
January 6,1997.
MWR D60155 for installing and removing TM to cross-tie non-divisional battery
charger to Division 2 DC bus, installed on December 9,1996, and removed on
December 19,1996.
b. Observations and Findinas '
Step 9 in MWR D62937, stated, " Lift and remove the line side leads from the top
of Breaker 10AL. Using cond 7ctors/ cable of Min 4 AWG, jumper from the load side
of Breaker 10AR to the line side of Breaker 10AL." The licensee connected two
breakers in series to provide breaker protection. The inspectors did not identify any
personnel safety concern with this breaker configuration.
MWRs D72416 and D60155 required installation of cross-ties from the non-
divisional MCC 1F to divisional MCC 1D and 18, respectively, during a bus outage
in accordance with Procedtire CPS 3503.01, " Battery and DC Distribution." Step
8.2.7.3.8 in Procedure CPS 3503.01 required connection of two conductors to the
load side of the spare breaker on MCC 1F. By conventional configuration, the top
of the breaker was designated as the line terminal and the bottom of the breaker as
the load terminal. However, for the spare breaker, the line side was connected to
the bottom of the breaker. The procedure did not clarify that the load side was at
the top of the breaker. Therefore,it would appear that the conductors were
terminated to the line terminals.
Step 8.2.7.2.9 in Procedure CPS 3503.01 required connection of a Class 1E
disconnect switch to the spare breaker at MCC 1F. However, the procedure did
not clarify that the connection should be made to the load terminals which were
located at the top of the breaker. The licensee initiated Comment Control Forms
(CCFs) to clarify that the spare breaker had its line conductors terminated at the
bottom terminals. In addition, the connection of the conductors or the disconnect
switch was to be made to the load terminals located at the top of the spare breaker
for MCC 1F.
In both installations, the conductors and the disconnect switch were connected to
the load terminals located at the top of the spare breaker. This field configuration
was in accordance with Drawing No. E03-1DC17E. The inspectors also reviewed
the drawings for the line and load connections of UPS breakers for MCC 1 A,18,
and 1D. The line terminals were designated at the bottom of the breakers. The
licensee reviewed the vendors manuals and concluded that the in-plant
configurations were consistent with the vendor and design drawings.
19
_ _ _ __ _ _ _ _ . _ . . _ _ . . _ _ _ _ _ . _ _ _ _ __ _ _ _ _ - _ . .
'
l*
1.
c. Conclusions
-
The inspectors did not identify any installation problems associated with the
instructions provided in the above work packages. However, there were minor
procedural deficiencies in Procedure CPS 3503.01 for which the licenseo initiated
l CCFs.
M2.3 Miscellaneous Material Condition Problems
a. Insoection Scoce (71707)
The inspectors toured the facility to assess material condition.
b. Observations and Findinos
The inspectors observed the following undocumented deficiencies on safety-related
equipment:
e
The inspectors noted a number of room and equipment coolers with loose or
broken inspection door handles. None of the problems had been identified with
maintenance request tags. Examples of room coolers with deficient handles
included the reactor core isolation cooling room, "A" RHR heat exchanger room.
"B" shutdown service water room, and several of the safeguards switchgear
rooms. In addition, several non-safety related room coolers had similar
deficiencies.
Although the inspectors did not identify any operability issues with the
deficiencies, they were concerned that certain ventilation lineups might result in
the cooler housing being briefly pressurized, popping open the doors. This could
result in the cooling coils being bypassed during subsequent operation of the
fans. The concern was brought to the attention of the Shift Supervisor. The
inspectors noted that most of the deficient handles on safety-related coolers had
subsequently been identified with maintenance request tags.
The inspectors noted that the Standby Liquid Control common supply line check
valve, Valve 1C41-F006, was missing the cotter pin and lock wire which would
normally hold the manual operating lever in place. Similar valves in other
systems had the cotter pins and wires. Lack of the pin would not affect
operability unless something caused the handle to move from its normal
position. The inspectors informed the LASS of this finding. The LASS
determined that the presence of the pin and lock wire was not checked in the
system valve lineup checklist, was not shown on the piping and instrumentation
drawing, was not included in the locked valve program, and was not required by
TSs. However, the LASS had a maintenance request tag placed on the valve to
initiate action to get the pin and wire installed.
The inspectors later discussed the issue with the system engineer. The
engineer determined that the applicable drawing for the valve (Anchor / Darling
i
l
f
20
.- - - - .-- - - - - - -
.
Valve Company drawing W8121407, revision C) showed that the pin and lock
i*
wire should be installed. The inspectors reviewed surveillance Procedure
9015.02, "r tandby Liquid Control injection Operability," Revision 33, which
manually exercised the valve, using the handle, and noted that it did not
L
! mention the pin or lock wire. The inspectors reviewed maintenance procedure
8120,04, " Maintenance of Anchor / Darling Tilting Disc Check Valves,"
Revision 12, and noted that the procedure provided instructions to install the pin
and lock wire when reassembling the valve after maintenance. However, the
inspectors noted that Procedure 8120.04, Appendix C, " List of Anchor / Darling
i
Tilting Disc Check Valves," did not list 1E41-F006 or 1E41-F007. The system
ersgineer agreed that both_ of those valves should have been incli.ded on the list,
and wrote a comment control form to initiate a revision.
e
The inspectors noted that both constant level oiler bulbs on the A fuel pool
cooling pump were missing their locking bolts. The inspectors were concerned
i that a seismic event or significant pump or piping vibration could cause the
bulbs to fall off. Loss of the oiler bulbs would not have an immediate effect on
operability of the pumps, but would prevent the oiler from automatically
compensating for small oil losses. The inspectors informed the LASS of the
j- - concern. The oilers were subsequently corrected.
! c. Conclusions
l
l The inspectors noted minor material condition issues associated with safety related
l
room coolers, a safety related check valve, and oilers on a fuel pool cooling pump.
i
All of these problems should have been readily apparent to plant management,
operators, and system engineers performing tours and system walk downs.
M2.4 Material Condition Deficiency identification and Trackina l
a. Insoection Scooe (62703)
The inspectors performed routine assessments of equipment histories, maintenance
records, and current maintenance requests to identify repetitive failures, indications
of possible common mode failure machanisms, or other adverse performance trends
which might be indicative of ineffective or inadequate maintenance,
b. Observations and Findinas
!
The inspectors observed several material condition issues during this inspection
period which did not appear to be rece!ving adequate attention. While the material
conditions had been identified for repair, the inspectors found that in some cases
prompt operability determinations or evaluations for possible common mode
failures, repetitive failures in components with different unique identifiers (EINs), or
other adverse trends were not being performed. No examples of inoperable
4 aquipment for which appropriate actions were not taken were identified, but the
i
inspectors were concemed by the potential programmatic implications of this issue. :
i
21
i
l'
' - , -. - _ - ---, --- . - - - - -- ,
_ _ _ _ _ _ _ _ . _ . _ . _ _ _ . - _ _.__._.__ _ - -._._ _ _ _ _
l \
. ;
.
"
i ' PosiSeal Butterfiv Valves in Service Water Systems
.
-
During a plant tour on April 30,1997, the inspectors noted that there were
maintenance request tags on valves 1SXO14A and 1SX0148, the service water
(WS) to SX isolation valves. The tags noted that there was leakage from the SX to
WS systems when the valves were closed. The inspectors were concemed by the
potential effect of flow diversion on SX operability, and investigated the issue.
Both valves were PosiSeal butterfly valves.
i
i
MWR D73235 had been issued on December 19,1996, because the licensee noted
l- that the WS system remained pressurized when the WS pumps were secured and
the 1SXO14A and B valves were closed. The valves are automatic isolation
designed to close whenever the associated SX pump start, thus isolating the non- ~
safety related WS piping from the safety related SX piping. Excessive leakage
through the valves could degrade the availability of SX cooling water to safety- i
related loads. The inspectors noted that the MR was evaluated by the Shift
Supervisor as having no significant effect on operability and was given a priority of
4 with " repair with unit on line" indicated. The inspectors discussed the condition
of the valves with the system engineer in an attempt to evaluate whether the
operability decision and priority were appropriate. ,
!
The system engineer stated that the amount of leakage was small, and that the
isolated WS system had been maintained depressurized by continuously draining )
through a 3/4-inch drain line. The system engineer said that at about the same !
,
l
time the back leakage was discovered, significant back leakage was identified
through 1SXO14C on Division 111 SX, and the valve had been replaced. The
inspectors asked whether the leakage through any of the three valves had been
,
'
l
quantified, whether the leakage had been formally analyzed for effects on SX 4
system operability, and whether a CR had been issued. The answer to all the
questions was "no." j
The next day the system engineer informed the inspectors that he had thought
about the issue further and decided to recommend that both valves be replaced.
On May 5, ?197, CR 1-97-05-050 was issued documenting the concems, a
conditional s cerability determination, and the need for further evaluation of the
leakage. The conditional operability determination was baseo an the fact that the
unit was shutdown and that the temperature of the ultimate heat sink was 45
degrees below the design maximum.
On May 8,1997, licensee engineering, outage planning, and other personnel met to
.
discuss the plans for resolving the issues with the valves. Engineering personnel I
. stated that the valves should be replaced because once PosiSeal butterfly valves
started leaking, degradation could accelerate. Information was presented regarding
the condition of Valve 1SXO14C which had been replaced, previous replacement of
the Valves 1SXO14A and B, and problems experienced with similar valves which
isolated SX from the fuel pool cooling system. The decision was made to replace
both valves.
! 22
!
- - .
,
- _ - - - - - - - - _. . - - . - -
.
.
- The inspectors performed a cursory review of the history of PosiSeal butterfly
- valves in service water applications at Clinton Power Station. The inspectors
l
determined that Valves 1SX014A, B, and C had been replaced in 1991 and 1992
due to excessive leakage, and that similar valves had failed to provide adequate
isolation between the SX and component cooling water systems earlier in the
current outage (Inspection Report 50-461/96015, Section M2.1). 1
The inspectors concluded that PosiSeal butterfly valves had a history of in service
! 1
failure at Clinton, were known to degrade rapidly once seat leakage developed, and
l
were capable of rendering the SX system inoperable due to inter-system leakage.
The inspectors also determined that the licensee had not evaluated whether the
-
maintenance, testing, and planned replacement programs for these valves provided
reasonable assurance of SX system operability during future operating cycles.
Synch Check Relav Failure in Safety Related Breaker
On April 11,1997, the inspectors performed a routine review of MCR logs. During
this review, the insp*ctors noted that 4160 voit breaker 1 AP09EC feeding the
"1B1" safety related bus from the Emergency Reserve Auxiliary Transformer
(ERAT), had failed to close during an attempted bus transfer. This failure had
occurred approximately ten hours earlier. A MWR had been initiated to trouble
shoot and repair the breaker. A CR was not generated until the inspectors asked
whether one was appropriate.
l
The CR which was subsequently written for the breaker failure provided the
I
additionalinformation that the breaker failure had been caused by a faulty synch
i
!
check relay. The CR classified the degraded material condition as a Maintenance
Rule functional failure. The inspectors verified that the synch check relay was not
required for automatic transfer of the bus, but noted that TS surveillance SR- 3.8.1.S required periodic manual operation of the breaker with successful transfer
j of bus 181 as acceptance criteria.
l
she inspectors performed a cursory review of the history of synch check relays at
the Clinton Power Station. The inspectors determined that the failure of synch
check relays had previously been documented in Inspection Report 50-461/96009,
Section M1.2, and that during the course of that inspection period, plant staff had
told the inspectors that synch check relays had a history of failures.
The inspectors were concerned that a safety related breaker failed to meet its TS
surveillance acceptance criteria, as demonstrated by an in service failure to close,
and that this failure was attributed to a component with a known failure history,
but no CR was written until the inspectors intervened, and no investigation of root
cause for prevention of failure repetition was initiated by the licensee.
1.ubricant Dearadation in a Safety Related Motor Ooerated Valve (MOV)
While reviewing MWR D76456 for the RCIC exhaust vacuum breaker outboard
- isolation valve, a safety related valve, the inspectors noted that a MWR
.
23
i
!
!
!
i
!
- ._ -- ..- - .- - -.- _ _ _ - . . - - .- -.-
,
.
! .
l.
continuation sheet entry had been made which identified degraded lubricant on the
l
'
switch deficiencies. The inspectors noted that this lubricant degradation had not
been identified on any tracking document, so neither the condition or its causes
could be analyzed or trended.
l
The inspectors reviewed the PM tasks for the above valve and determined that the
last PM on the MOV had been performed in 1992. The inspectors determined that
the vonder recommended replacement of the MOV lubricant on an 18 month
frequency, or as appropriate based upon service experience. The inspectors found
that the exhaust vacuum breaker outboard isolation valve had originally been on a
18-month PM frequency, but that the PM frequency had been changed to
54 months after 1992. The inspectors verified that the recommended lubricant had
been used in the current and preceding PMs.
l
The inspectors were concerned that the cause and consequences of this degraded
.
lubricant in a safety related valve was not being evaluated. The inspectors
!
discussed the condition of the MOV lubricant with a maintenance individual who
stated that all MOVs exhibited similar lubricant degradation, and that it "was
^
nothing to be concerned about." The inspectors were concerned that the
information on degraded lubricants was not being adequately tracked, trended, or
analyzed.
Historv of Licensee Assessment of Material Condition Problems
The inspectors reviewed the licensee's history of identifying and assessing material
condition problems relative to repetitive or generic failure mechanisms. The CR
1-89-05-084 had identified inconsistencies between how MWRs and CRs were
used to assess material condition deficiencies. The Notice of Violation attached to
inspection Report 50-461/92016 identified that a material condition deficiency
resolved on a MWR had not been adequately assessed for generic impact on other
components inspection Report 50-461/96009 documented that repetitive failures
of Feedwater System containment isolation check valves had nm been adequately
addressed to prevent reoccurrence. A Severity Level ill violation was issued for the
failure to correct check valve leakage. An apparent violation for inadequate
corrective actions related to maintenance of safety related breakers was identified
in inspection Report 50-461/97003 (EA 97-132). Many of the referenced problems
with breaker maintenance had been identified and addressed in a non-integrated
manner using MWRs.
Indications of Effectiveness
The inspectors reviewed the licensee's Material Condition Management Program
l
" Trend Report" for January 1997. This report documented that trending of
vibration data was being performed and that some repetitive component failures
were being documented and dispositioned. The inspectors' review of CRs initiated
during the inspection period supported the observation that repetitive failures of a
component within a three month period were being documented on CRs.
f
I
24
i
i
I
I
!
l
,- e _-,
.
Proarammatic Concern l
,
The inspectors noted that the licensee's corrective action program did not require
that material condition deficiencies identified on MWRs be reviewed for generic
application or repetitiveness (with the exception that CRs were required to be l
written when MWRs indicated inat a system or component failed twice within a
i
three month period). Degraded material conditions identified on MWRs were also
l
not subject to root cause analysis to prevent reoccurrence. The inspectors were
concerned that the failure to perform adequate assessment of material condition
problems identified on MWRs could lead to future equipment reliability or operability
problems.
Status of issues at the Conclusion of the Period
The inspectors requested that the licensee evaluate whether the failure of PosiSeal
butterfly valves in service water systems, breaker failure due to faulty synch check
relays, and MOV lubricant degradation were generic or repetitive material condition
.
l
problems, and to provide the maintenance history and trending data which
supported the conclusions. The inspectors consider the effectiveness of the
licensee's process for identifying and preventing recurring material condition
problems which were adverse to safety to be an unresolved item (50-461/97011-
10) pending review of the licensee's maintenance history and trending data and the
licensee's corrective actions for degraded safety related breakers (Inspection
Report 50-461/97003).
c. Conclusions
The inspectors noted material condition problems with PosiSeal butterfly valves in
service water systems, synch check relays in safety related breakers, and lubricants
in MOVs. The licensee's response to these issues appeared to be focused on
repairing the specific problems, not on assessing potential repetitive or potential
common mode failure mechanisms, or on preventing recurrcnces. The inspectors
were also concerned that material condition problems identified on MWRs received
limited review for generic implications. An unresolved item was opened pending
review of more detailed material history and trending data and the licensee's
response to a pending enforcement action.
M2.5 Control of Transient Materialin Containment
a. Insoection Scoca (71707)
The inspectors performed reviews of generic correspondence on Emergency Core
Cooling System (ECCS) suction strainer clogging and performed walkdowns of
containment to identify whether the licensee's housekeeping and transient material
programs were adequate and properly implemented.
I
i
i
25
. _ _ _ _ _ . _ _ _ . . _ _ _ _ _ _ . _ . _ _ _ . _ _ _ . _ . _ _ . _ _ _ _ _ . _ _ ..
.
b. Observations and Findinos :
While performing walkdowns of the containment, the inspectors identified several
items of potential concern. These included:
Pealing and degraded coatings on the containment walls
,
' The use of double backed tape and magnets to hold signs and placards in place
within containment
l
The extensive use of caution tape and foam insulation as an occupational safety
and health precaution for permanently installed interferences within containment
,
The extensive use of radiological tape and glued or self-adhesive labels on
systems and structures in containment
The use of paper (fibrous) caution and maintenance request tags in containment
The poor housekeeping control over old wires, tape, and general debris in some
portions of containment.
The inspectors reviewed Procedure CPS 1019.05, " Control of Transient
Equipment / Materials," Revision 3, and found that it did not address many of the
items discussed above. The inspectors also found that while the procedure
specified limits for transient materials in containment, there was no specified
implementation process to ensure that the cumulative amount of transient material
from all sources would be below the licensee identified threshold for proper ECCS
strainer operation in a post loss of coolant accident (LOCA) environment.
l The inspectors discussed the above issues with the Licensing and Engineering
!
staffs. The inspectors requested information on the environmental qualification of
- the coatings and rihesives used in containment, and the documented mialysis that
the presence of large amounts of flexible and semi-rigid materialin containment did
not represent an undue potential challenge to the ECCS strainers. The licensee's
initial response referenced strainer design type considerations rather than the
implementation of ongoing controls. At this time, the inspectors reviewed an
Engineering Evaluation associated with CR 1-9610-033, " Foreign Material in
Suppression Pool Area of Drywell," and found that the CR also focused on design
considerations for ECCS strainers rather than on-going operability considerations.
The inspectors identified their concerns to licensee management who, after
,
i
discussion with the inspectors and independent walkdowns of containment,
acknowledged that Procedure CPS 1019.05 was inadequate for the control of
material which could cause clogging of ECCS strainers under post LOCA conditions.
- This conclusion was documented in CR 1-97-05-178. The following CRs regarding
ECCS strainer clogging were also written subsequent to the inspectors involvement
- with this is. 3vw; 1-97-05-014,1-97-05-184, and 1-97-05-232.
!
.
.26
-
_ __ . _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ . _ - . . _ . _ _._ _._._..-
~
l
- 10 CFR Part 50, Appendix B, Criterion V, " Procedures," requires, in part, that
- - activities affecting quality be prescribed by procedures of a type appropriate to the
circumstances. CPS 1019.05, Revision 3, Section 8.8, was not appropriate to the
i
- circumstances in that it failed to identify or provide for adequate control for material
which could clog ECCS strainers in a post LOCA environment, a violation (50-
461/97011-11) of 10 CFR Part 50, Appendix B, Criterion V.
I
The licensee informed the inspectors that they had initiated procurement of
environmentally qualified (EO) adhesives and labels for use in containment at the i
i
end of the inspection period. The licensee also initiated revision of Procedure CPS
,
1019.05 to ensure that it adequately identified and controlled material which could
'
cause ECCS strainer clogging. The licensee had not provided the inspectors an
assessment of the impact of degraded containment coatings, or a corrective action
plan, at the end of the inspection period. ,
'
c. Conclusion ,
,
The inspectors identified that the licensee procedure for controlling material which
could clog ECCS strainers in a post LOCA environment was inadequate. After a
slow initial response to this issue, the licensee initiated actions to resolve the
concem. The issue of degraded containment coatings had not been resolved at the
end of the period. One violation of NRC requirements was identified.
M3 Maintenance Procedures and Documentation
M3.1 Documentation Contained Within Maintenance Packaaes
a. insoection Scope (62707)
The inspectors reviewed Job No. PEMAP1054, "8410.04 Testing for 1 AP41E2C," i
MWR D63102, " Install New Control Switches for Bridge," MWR D70531, " Red Pen
,
!
Sticks at 100%," D71601, " Transmitter is Sending a Low Flow Signal to DCS
Computer," and CR 1-96-12-124, " Questionable Breaker Not Removed From
l System."
b. Observations and Findinas
On December 11,1996, the technicians tested MCCB 1 AP41E2C using Job
,
l No. PEMAP1054. The individuals could not find the stamp which contained
i
information concerning the breaker revision; therefore, they used Procedure CPS
8410.05, " Type HE Molded Case Circuit Breaker Revision Level Test," Revision 4,
to determine the breaker revision. When the breaker appeared not to reset within
five seconds, the technicians marked the surveillance as failed and turned over to
the next shift personnel for disposition. The engineering personnel of the next shift
l
i
found the stamp and the breaker revision on the face of the breaker. Therefore,
Procedure CPS 8410.05 was not re-performed. Procedure CPS 8410.04 was then
,
performed satisfactorily. Detailed resolution and evaluation of this breaker's failure
i
h
1
27
i
'
_. _ . _ _ _ _. _ _ _ _ ._. _ _ _ . _ _ __ . _ _ . _ _
1
l
l
' to reset within five seconds were documented in the MWR In addition, CR 1-96-
'* 12-124 was initiated on December 13,1996 to document this discrepancy end
resolution.
A note between Steps 8.10 and 8.11 in Procedure CPS 8410.05 stated, "Within -
5 seconds of breaker trip, manually reset breaker by opening then attempt to close
breaker to verify trip was due to instantaneous trip unit. If breaker will not latch
closed, trip was influenced by the thermal trip unit and can not be considered a
valid instantaneous trip." Step 8.11 stated, "If breaker trips, reset breaker and
close if possible within = 5 second after trip." When the technicians observed that
I
the breaker did not reset within 5 seconds on December 11, this condition showed
-
that the trip was due to a thermal and not an instantaneous trip. Therefore, the
breaker trip was not a valid instantaneous trip. The inspectors reviewed the
i
completed Job No. PEMAP1054 and did not find the documentation acsociated
l
with Procedure CPS 8410.05. The licensee stated that the reasons not to include
documentation associatt 4h Procedure CPS 8410.05 were:
- Procedure CPS 8410.05 was not a required test because the date and revision
of the breaker were subsequently identified.
l *
'
The failure of the breaker to reset within 5 seconds was not a valid failure but
showed that further testing was necessary to determine the instantaneous trip i
set point.
The licensee committed to change the procedure to clarify that breaker revision was
determined by a valid instantaneous trip.
!
The inspectors agreed that the documentation of Procodure CPS 8410.05 of
December 11,1996, did not need to be included in the maintenance package.
However, a violation of 10 CFR Part 50, Appendix B, Criterion V was identified
during review of testing associated with MCCB 1 AP41E2C (Section M2.1).
c. Conclusion
The inspectors did not identify any violations during a review of Job No.
PEMAP1054,
M3.2 Environmental Qualification (EQ) Documentation of Material
a. insoection Scone
The inspectors reviewed Procedure CPS 8492.01, " Cable Termination,"
Revision 21. The review included checklists associated with this procedure, and
Nuclear Station Engineering Department Maintenance Standards for Raychem
- material.
)
.
- 28
l
l
. -- - -
- - - . . - - - . - - --- - - - - . . . - . . ~ . - . . - - - . - .
I
.
L
!
O
~
b. Observations and Findinas
i- ,
The inspectors reviewed each section of Procedure CPS 8492.01 to verify the type
and qualification of materials specified for Class 1E components. Procedure CPS
8492.01 required the use of Raychem kits for Class 1E cable insulation or i
termination and the use of either Raychem kits or Okonite tape for non-1E
applications. The Raychem materials specified in the procedure were EQ for 40
years except for Raychem NPKX and NPKP kits. These two kits were not included
in the Nuclear Station Engineering Department Maintenance Standards manual. The
licensee determined that these two kits were also EQ, but were not included in the
,
manual. The licensee committed to initiate a CR and revise the manual.
L
l c. Conclusion -
!
The inspectors concluded that for all Class 1E applications, the licensee appeared to
use EQ qualified materials in accordance with CPS 8492.01.
M3.3 Review of Maintenance Work Packaoe for the Reactor Water Cleanuo System
a. Insoection Scone (62703)
l The inspectors reviewed maintenance work request (MWR) D71146 for the reactor
l
'
water cleanup discharge inboard isolation valve for conformance with the
requirements of CPS 1501.02, " Conduct of Maintenance."
,
b. Observations and Findinas
Operations personnel wrote MWR D71146 to replace the packing on valve
1G33F053. While reviewing the work package, the inspectors identified that both
EM and quality verification (OV) had signed MWR Job Step 8 for replacing parts on
the valve's motor operator per Procedure CPS 8451.05. The inspectors reviewed
the work package and determined that the only part replaced was the limit switch
i
cover gasket.
! The inspectors reviewed Procedure CPS 8451.05, " Corrective Maintenance for
l Limitorque SMB-000 and SMB-00 Actuators," and determined that the procedure
i
did not specifically address the replacement of the limit switch cover gasket.
! However, Procedure CPS 8451.50, " Motor Operated Valve Testing with VOTES,"
!
which maintenance used to test the valve after the packing was replaced (Job
Step 12), contained a specific step for replacing the limit switch cover gasket if
necessary.
l
QV personnel explained to the inspectors that the replacement of the limit switch
cover gasket could be performed using either procedure because some activities
were covered within more than one procedure. Further discussions with QV -
supervision determined that signing multiple job steps when the activity performed
l was covered by more than one procedure was not isolated.
I
i
!
29
- . - - - -. -. . - - - _ . _ , _-. -
i
!
l
l
! *
~
!
Since EM and OV personnel did not perform work using Procedure CPS 8451.05 as
- directed by Job Step 8, Procedure CPS 1501.02, " Conduct of Maintenance,"
required that Job Step 8 be noted as "not applicable." Procedure CPS 1501.02
also required that a note be placed in the back of the MWR stating the reason the
job step was not performed. The failure to comply with Procedure CPS 1501.02 '
constituted a violation of minor significance and is being treated as a Non-Cited
Violation (50 461/97011-12) consistent with Section IV of the NRC Enforcement
Policy. See Section M7.1 for additional discussion of this issue.
c. Conclusions
Both maintenance and QV personnel signed that work was completed using
Procedure CPS 8451.05 when it was actually completed using Procedure CPS
8451.50.
M7 Quality Assurance in Maintenance Activities !
M7.1 Sensitivity to Quality Record Sion-offs
Sections M1.2 and M3.2 of this report document instances where Quality Record
sign-offs were completed for actions slightly different than actually performed.
While each case was individually minor, the generalissue is of regulatory
significance. The inspectors discussed, with plant management, the need to ensure
that Maintenance and Nuclear Assessment personnel were appropriately sensitive
conceming the accuracy of their sign-offs. Plant Management acknowledged the
importance of such sensitivity.
1
M7.2 OV Sion-off Missed
a. insoection Scoce
On September 17,1996, a step requiring notification of Quality Verification (QV)
personnel was added in Procedure CPS 8492.01 C001, " Cable Termination
Checklist," by Procedure Advance Change (PAC) 0496-96. The inspectors were
concerned that necessary QV activities were not specified in Procedure CPS
8492.01, " Cable Termination" and its associated checklist CPS 8492.01 C001.
The inspectors reviewed revisions of Procedures CPS 8492.01, CPS 8492.01C001
and Nuclear Assessment Procedure (NAP) 110.02, " Quality Verification Planning."
b. Observation and Findinos
Step 2.1.3 in Procedure CPS 8492.01, Revision 20, required the use of the cable
termination checklist (Procedure CPS 8492.01C001, Revision 9), when
maintenance was performed on safety and quality related systems. The checklist
contained eight OV signature blocks for various steps in the procedure.
!
On August 26,1996, Procedures CPS 8492.01, Revision 21 and CPS
8492.01C001, Revision 21 (Revisions 10 through 20 were not used) were issued.
30
t
l
. . .. . --- _ - ~ _ . - _ . - . - _ - - -- - . - - - . . - -
!
i
Step 5.4 in Procedure CPS 8492.01 required notification of QV personnel before
-
the performance of this procedure on any Class 1E system or component when OV
1*
was called out on the Authorizing Work Document. In addition, this notification
!
l
was to be treated as a QV witness allowing for verification deemed appropriate for
the scope of work being performed. This practice was consistent with NAP
110.02. Step 8.1.2.1 of the procedure also required use.of the checklist for all
l work performed by this procedure. However, Revision 21 of the checklist did not
l contain a QV signoff for personnel to denote QV inspection. Therefore, the
! licensee issued PAC 0496-96 to add signoffs for notifications of QV before
! performing this procedure on Class 1E systems or components.
' Although the signoff for OV personnel was not in Procedure CPS 8492.01 C001,
Revision 21, from August 26 to September 17,1996, the inspectors had
reasonable assurance that necessary QV activities were performed on Class 1E
systems or components because Step 5.4 in CPS 8492.01, Revision 21, was stillin
effect. In addition, any QV requirements would be denoted in work packages as
deemed necessary.
c. Conclusions
The inspectors concluded that from August 26 to September 17,1996, QV
l
activities were performed on Class 1E systems even though sign-offs for OV
l inspections were not in Procedure CPS 8492.01C001 checklist.
M7.3 Review of Maintenance Critiaues
l a. Insoection Scooe (40500)
The inspectors reviewed Critiques PS97-009 and EM 97-010 against the
requirements of Procedure CPS 1016.05, " Conduct and Documentation of
Critiques."
b. Observations and Findinas:
Critioue PS97-009
On April 9,1997, the inspectors observed maintenance work on the "C" RHR
pump. The mechanics had started to remove a drain plug from the seal cooler for
the pump and noted that service water to the seal cooler was still pressurized. The
l
mechanics reinstalled the drain plug, stopped work, and notified their supervision of
the problem. The licensee initiated CR 1-97-04-072 to document the problem, and
that a tagout error had occurred. The inspectors attended the critique, held April 9,
1997, and reviewed the critique report, Critique PS97-009, issued April 30,1997.
During the critique, the licensee determined that the tagout performed for the work
failed to consider the work being performed on the service water side of the seal
cooler, and that the mechanics failed ensure that the tagout was adequate as
, required by Procedure CPS 1014.01, " Safety Tagging." These conclusions were
,
,
31
!
. . . - . . . - - -..-.-- ~._ - - .- - - . _ _ - _- ..- .--.~-
l
- j
-
-
appropriately documented in the critique report. The inspectors determined that the
. licensee's conclusion regarding the primary cause of the error was appropriate.
The failure to adequately prepare or implement the tagout for the RHR C seal
cooler, as required by Procedure CPS 1014.01, was considered a violation of minor
significance and is being treated as a Non-Cited Violation (50-461/97011-13)
consistent with Section IV of the NRC Enforcement Policv.
The inspectors noted that relevant facts established during the critique were not
documented in the critique report. Specifically, having multiple tasks on a single
work document contributed to the failure to identify work on the service water side
i
of the seal cooler when the tagout was developed. The failure to document this
could have led to missed opportunities for desirable corrective actions.
Critioue EM 97-010
Critique EM 97-010 reviewed the circumstances of the MOV damage discussed in
Section M1.3.
~
The inspectors noted that the critique report stated that no apparent procedure
noncompliance or non-conservative operations had occurred during the event. The
inspectors discussed this determination with several individuals who attended the
critique. The inspectors found that the determination of no noncompliance and no
non-conservative operations focused heavily on the procedure in use at the time of
the event. Individuals at the critique placed little emphasis on determining if
requirements delineated in administrative procedures such as " Conduct of
Maintenance" should have prevented the event. As discussed in Section M1.3, the
inspectors identified one noncompliance related to " Conduct of Maintenance." The
inspectors were concerned that this narrow focus reflected inadequate sensitivity
to, and familiarity with, administrative maintenance requirements.
c. Conclusions
The inspectors reviewed two Maintenance critiques and noted opportunities for
improvement in each.
l
111. Enaineerina
E1 Conduct of Engineering
E1.1 Attachment of Scaffoldina to Safetv-Related Pioina Not Analyzed
a. Insoection Scooe (37551)
L
The inspectors observed scaffolding attached to safety-related equipment. The
inspectors reviewed the scaffolding attachment for adequacy of analysis and
.
j
32
'
._. _
.
'
adequacy of the scaffolding procedure, Procedure CPS 8901.10, "Scaf fold
- Erection /Use/ Dismantling," Revision O.
b. Observations and Findinas
During a tour of the RHR "B" pump room, April 28,1997, the inspectors observed
that scaffolding was attached to the minimum flow line for the RHR "B" pump and
one of the pipe supports for the line. The inspectors reviewed Procedure CPS
8901.10 and determined that the procedure permitted the observed scaffolding
attachment. Specifically, Step 8.3.19.6 and Appendix G of Procedure CPS
8901.10 stated that it was acceptable to attach scaffolding to pipes of 4 inches
diameter and greater. However,in response to questions by the inspectors,
engineering personnel stated that no evaluation had been performed which
demonstrated that the attachment of the scaffolding would not cause undue stress
upon safety-related piping during a seismic event. Design engineering initiated CR
1-97-05-035 to document that no evaluation had been performed and to document
the inadequacy of Procedure CPS 8901.10 and Procedure CPS 1019.05, " Control
of Transient Equipment / Materials," Revision 3. In addition, the licensee inspected
other scaffolding in the plant and identified additional examples of scaffolding
attached to safety-related equipment. 10 CFR Part 50, Appendix B, Criterion V,
" Procedures," requires in part that activities affecting quality be prescribed by
procedures appropriate to the circumstances. The failure of the procedure to
require and evaluation of the additional stress upon the RHR "B" pump minimum
flow line piping is a violation (50-461/97011-14) of 10 CFR Part 50, Appendix B,
Criterion V.
c. Conclusions:
The inspectors identified that the licensee failed to analyze or evaluate the loads on
safety related piping induced by temporary scaffolding. One violation of 10 CFR
Part 50, Appendix B, Criterion V, was identified.
E1.2 Seismic Qualification of Circuit Breaker Cabinets
a. insoection Scoce (37551)
The inspectors reviewed the circumstances associated with implementation of a
procedure for controlling the seismic configuration of safety related circuit breaker
cabinets.
b. Observations and Findinas
The licensee identified that the seismic qualification of safety related breaker
cabinets had been based upon having breakers in each bay of the cabinet. Breakers
l
!
were typically removed from their bays for performance of preventive maintenance
or repair. The licensee identified that the removal of the breaker's weight from the
cabinet affected the critical characteristics of the cabinet during a potential seismic
33
l
e
.
l
l*
event, and that this had the potential to place the cabinet's other safety related
- breakers in an unanalyzed condition.
4
The licensee reviewed the original seismic qualification process and performed some l
additional analysis to establish criteria for conditions in which the removal of
breakers from their bays would not affect the operability of the other breakers in l
the cabinet. The identified criteria was compiled into Procedure CPS 1014.11,
l
'
"6900/4160/480V Switchgear/ Circuit Breaker Operability Program," Revision 0, j
issued May 2,1997. '
!
On May 5,1997, the licensee recognized that the 480V 1 A unit substation had l
been in non-compliance with the requirements of Procedure CPS 1014.11 since the
!
procedure was issued. In addition, a combination of breaker removals performed
~
I
prior to May 2 and on May 5,1997, placed the Division 14160V switchgear into a
condition of non-compliance with Procedure CPS 1014.11. Both electrical cabinets
were promptly declared inoperable, and CRs were written to document the
inadequate implementation planning associated with the issuance of Procedure CPS
1014.11. Corrective actions included the commitment to walk down field i
conditions prior to implementation of new procedures and implementation of a !
method to track the status of individual breakers within the safety related
switchgear. The failure to ensure that the 480V 1 A unit substation and the 4160V l
Division 1 switchgear were in compliance with Procedure CPS 1014.11 was l
licensee identified and corrective actions were considered appropriate, therefore it is
being treated as a Non-Cited Violation (50-461/97011-15) consistent with
Section Vll.B.1 of the NRC Enforcement Policv.
The inspectors concluded that the licensee exhibited a good safety focus in
identifying the breaker , abinet seismic qualification issue. However, the inspectors ;
were concerned that the licensee appeared to be using probabilistic risk assessment '
in determining operability criteria. Such an approach would be inconsistent with the
definition of operability contained in TS, and discussed in Generic Letter 91-18.
The inspectors were also concerned with the past operability of safety related
switchgear. These concerns were forwarded to the Office of Nuclear Reactor
Regulation for review, and are considered an inspection follow-up item
(50-461/97011-16) pending a NRC review of the licensee's analysis of electrical
cabinet seismic qualifications and the suitability of the operability control program
established in Procedure CPS 1014.11.
c. Conclusions
The licensee identified a potentially generic concern associated with the seismic
qualification of circuit breaker cabinets when breakers are removed. The inspectors
concluded that the licensee exhibited a good safety focus by identification of this
issue. The implementation of a procedure to address this issue was inadequate,
l and a procedure violation resulted. The inspectors identified concerns with the
licensee's stated approach to assessing cabinet operability, and a follow-up item
was opened pending NRC review of this issue.
34
i
I
_ _ _ . _ _ . . _ _ _ _ _ _. _ ._ ._ _ . _ _ _ .. . _ _ . . _ . . _ . - _ _ ..
.
e
..
.
IV. Plant Sucoort
R1 Radiological Protection and Chemistry (RP&C) Controls
R1.1 Minor Weakness.in Usina Small Article Monitor (SAM-9) Identified '
a. Insoection Scoce (83750)
The inspectors observed several personnel use the SAM-9 to release personal items
from the radiological controlled area (RCA).
b. Observations and Findinos
!
The inspectors observed a member of the licensee's staff exit the turbine building !
and then stop to converse with another staff member who was waiting in line to '
use the SAM-9. The inspectors left the area after monitoring several small articles
and continued to exit the RCA by processing through the personnel contamination
monitors (PCMs). Prior to the inspectors successfully processing through the PCM,
the two individuals discussed above exited the SAM-9 area and entered the PCMs.
Because of the short time which had elapsed, the inspectors were confident that
the individual who was not in line to use the SAM-9 had failed to monitor his
personal items.
The inspectors immediately notified a radiation protection (RP) technician who
confronted the individual prior to exiting the RCA. The individual stated that he had !
forgotten to use the SAM-9 prior to entering the PCM area. The individual then
returned to the SAM-9 area and processed his item through the monitor. No >
!
contamination was found. The RP technician reminded the individual of the
purpose of the SAM-9 and reinforced the need for attention to detail. No violations
occurred since the individual was reminded to use the SAM-9 prior to him exiting
the RCA.
c. Conclusions
!
,
One example of licensee personnel not immediately processing personal items
!
through the SAM-9 was identified.
R1.2 Contamination Controls Not fully lmolemented
a. Insoection Scone
The inspectors observed an individual reach into a contaminated area without
protective clothing. The inspectors assessed the individual's actions and reviewed
applicable procedure requirements.
i
- 35
l
!
i
'
__ _
_ _
.
. . _ . - . _ _ __ _ . _ _ _ _ _ _ _ . . _ . . _ _- _ ____ _ _ . _ . ___ . _ . . _ . .
e
~
t
b. Observations and Findinos
d
On May 8,1997, the inspectors observed an individual, inside containment, leaning
into a posted contaminated area and reaching out to tum a metal valve label inside
the contaminated area. Although the individual handled the label, the individual
-
was not wearing gloves nor any other protective clothing. The licensee had defined
l
the activities being performed by the individual as being under a "C" radiological '
classification. The licensee subsequently held a fact finding meeting, documented ;
on CR 1-97-05-100, which confirmed the inspectors observations. ~
Section 6.0 of Procedure CPS 1024.02, " Radiological Work Control," Revision 4,
specified that personnel performing radiological work were not permitted to deviate :
from established radiological control requirements without specific written or verbal
guidance from responsible radiation protection personnel. Radiation Worker ,
Information Sheet (RWIS) 5.6, " Minor Radiological Risk Work Rules for Mechanical
Maintenance," dated January 14,1997 specified radiological control requirements
activities with a "C" radiological classification. Instruction 7 of RWIS 5.6 specified
l
that protective clothing be worn for entry into Contamination Areas. The failure to
wear protective clothing in a contaminated area was contrary to RWIS 5.6 and CPS :
1024.02, and is considered a violation (50-461/97011-17) of Technical
Specification (TS) 5.4.1. ,
i
c. Conclusions
The inspectors observed that radiological controls were not properly implemented
when an individual reached into a contamination area without protective clothing.
One violation of procedures was identified. 5
l
l
l
1
V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the
conclusion of the inspection on May 23,1997. The licensee acknowledged the findings
presented.
The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
l
i
!
'
i
) l
i
'
36
\
, .. . _
o
"
t
\s INSPECTION PROCEDURES USED
!' IP 37551: On-site Engineering
IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and Preventing
Problems -
IP 61726: Surveillances
IP 61703: Maintenance Observation
IP 62707: Maintenance Observation
IP 71707: Plant Operations
l lP 71750: Plant Support
! IP 83750: Occupational Exposure
IP 92700: Onsite Follow up of Written Reports of Nonroutine Events at Power Reactor
Facilities
IP 92902: Followup - Engineering
IP 92903: Followup - Maintenance
IP 93702: Prompt Onsite Response to Events at Operating Power Reactors
ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
50-461/97011-01 VIO failure to perform steps as written
50-461/97011-02 NCV inaccurate VD system drawings
50-461/97011-03 VIO failure to lock open EDG support system valves
50-461/97011-04 NCV quality record sensitivity
50-461/97011-05 VIO inadequate shift turnover i
!
50-461/97011-06 VIO no restoration on caution tag
50-461/97011-07 NCV incorrect performance of t,urveillance actions
50-461/97011-08 VIO failure to complete an impact matrix
50-461/97011-09 VIO breaker preconditioning
50-461/97011-10 URI identifying material condition issues
50-461/97011-11 VIO control of loose material in containment
50-461/97011-12 NCV quality record sensitivity
50-461/97011-13 NCV inadequate tagout
50-461/97011-14 VIO scaffolding loads on safety related piping l
50-461/97011-15 NCV seismic qualification of switchgear 1
50-461/97011-16 IFl assessment of electrical cabinet operability
50-461/97011-17 VIO contamination controls
Closed
50-461/97011-02 NCV inaccurate VD system drawings
50-461/97011-04 NCV quality record sensitivity
50-461/97011-07 NCV incorrect performance of surveillance actions
50-461/97011-12 NCV quality record sensitivity
l 50-461/97011-13 NCV inadequate tagout
l 50-461/97011-15 NCV seismic qualification of switchgear
37
.. - . . . ~ .
- - - , . .- . - - . - -.
f
,
PERSONS CONTACTED
o
Licensee -
W. Connell, Vice President
W. Romberg, Assistant Vice President
P. Yocum, Manager - Clinton Power Station
D. Thompson, Manager - Nuclear Station Engineering Department
R. Phares, Assistant to the Vice President
.
%
t
e
!
l i
l l
I
!
i
I l
0
38
!
l
l
-. ..