ML20195D401

Forwards Evaluation of Items Identified by NRC Inspectors During 1980-87 That Required Significant Corrective Actions by Licensee.Addl 10-15 Instances Noted Where Inspectors Found Problems W/Util Methods to Close Out Items

ML20195D401
Person / Time
Site:	Clinton
Issue date:	06/17/1988
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
IEB-85-003, IEB-85-3, NUDOCS 8806230112
Download: ML20195D401 (7)

Text

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. ., , ', yg l JUN f 71988 MEMORANDUM FOR

A. Bert Davis, Regional Administrator i FROM: R. C. Knop, Chief, Reactor Projects Branch 3 SUBJEC.. EVALUATION OF 5IGNIFICANT ISSUES AT CLINTON 1980-1987 [

On June 6,1988, you directed me to perform a review of the Clinton site experience to determine what significant issues were identified by NRC inspectors that resulted in significant corrective actions by the licensee, a Attached is the results of that review.

It should be noted that there were an additional 10 to 15 instances where the inspectors identified significant problems in the methods being used by Illinois Power to close out items identified by their management control systems.

An example: During initial fuel loading, the licensee identified several fuel -

movement errors. During the NRC review, we identified additional details of  !

i why these events were occurring and met with the licensee to get broad corrective action.

l R. C. Knop, Chief

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Reactor Projects Bran a 3 j

Attachment:

As Stated

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CLINTON NUCLEAR POWER PLANT Items which were identified by the NRC for which significant corrective actions were required.

Prepared by Richard C. Knop i

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CLINTON NUCLEAR POWER PLANT

1. During 1980, the Senior Resident Inspector identified that Illinois Power Company personnel were welding attachments to and removing attachments from the Containment liner without QA inspection and documentation to verify compliance to ASME and AWS codes. Correction actions required major reinspection of the containment liner by the licensee, an improvement in QC controls and non-destructive testing of the containment liner.

2. During a team inspection conducted by Region III inspectors, a number of significant deficiencies were found in the area of fabrication, installation, and inspection of Seismic Category 1 supports and restraints for piping and electrical raceways. A Confirmatory Action Letter (CAL) dated February 18, 1981 was issued by Region III documenting the stop work on large bore pip. hangers imposed by IP on February 13, 1981 and the action to be token by Illinois power to resolve problems identified during that inspection. Subsequently a trial installation and inspection program was initiated by Illinois Power on a limited number of large bore hangers.

During an inspection of that trial program, additional problems were identified. Additional necessary corrective actions were identified in a letter to Illinois Power dated May 8, 1981. Based on an inspection conducted in June 1981, the stop work was lifted.

3. During mid 1981, Regional inspectors working on a allegation identified improper QC inspector testing practices that left doubt to the validity of the QC test scores. Based on this finding, the licensee changed a number of QC inspector testing controls and also required testing of all applicable QC inspectors currently working at the site.

4. Due to allegations received in December 1981, an inspection was conducted during the period January 5 to March 3,1982. Significant deficiencies ,

were found in electrical c onstruction activities at the Clinton Power Station. This was evidenced by numerous examples of violations with i

eleven of the 18 criteria for a quality assurance program as set forth in Appendix B to 10 CFR Part 50. As a result of preliminary investigation ,

j findings, Illinois Power Company issued a stop work for specified electrical activities. On January 27, 1982, Regicn III issued a Confirmatory Action Letter (CAL) addressing the stop work order and describing programmatic changes that would be necessary prior to the resumption of such work. Another finding during that inspection related  !

to the intimidation of quality control inspectors by Baldwin Associates management personnel including the discharge of two BA Quality Control inspectors for providing information to the NRC.

A meeting was held on January 27, 1982 to discuss preliminary findings from the inspection. At that time, the applicant was requested to review areas other than electrical to determine if nroblems identified during this inspection were generic to other areas.

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• 2 Subsequently, a civil penalty was issued by the NRC on October 5, 1982 for the amount of $90,000. The licensee acknowledged and paid the violation on October 21, 1982.

5. During early 1982, the Senior Residu.t Inspector identified a problem in the disposition of welding problems on the Reactor Vessel Refueling Bellows. Based on the Inspector's issues, the licensee issued a stop work. Af ter the recovery program was reviewed by the NRC, the licensee reworked the bellows and performed additional NDE of the welds.

6. During the time period of the Clinton 1982 stop work, a regional based inspector identified a number of weak areas in the licensee's administrative systems over and above those involved in the stop work.

The corrective actior,s by the licensee included:

• Improvement in training, qualification and certification programs to ensure that qualified people were working in the IP recovery program.

• An improved trucking system to track completion of critical actions supporting the recovery program.

• Improvements in the QA audit / surveillance systems to verify effectiveness of the recovery program.

• Improvements in the corrective action program to ensure timely corrective actions-both short term and long term.

7. During late 1984, the Senior Resident Inspector identified that a number of nonconformance reports (NCR) were dispositioned with a use-as-is closure using site engineering staff in violation of the requirement to have the engineering organization responsible for the original design

< concur in the dispcsition. The finding required that all previous 4

use-as-is dispositions of NCRs be audited by the licensee to determine acceptability of disposition.

8. During 1985, a DRS inspector identified that the station batteries were not being maintained in accordance with vendor requirements.

Housekeeping in the area and on the batteries was very poor. Dased on this finding the licensee retested the battery, did an enginee*ing  ;

analysis to verify that the material condition of the battery was '

adequate and revised the appropriate procedures. .

9. During 1986, a DRS inspector identified that some preoperational tests were being conducted out of the sequence identified in the preoperational testa. The finding required the licensee to revise their sequence controls to identify those steps that could be done out of sequence and to review all past preoperational tests to ensure that no preoperational tests were compromised by doing steps out of sequence. l l

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10. During early 1985 the Senior Resident Inspector identified problems in the procedures to ensure independent verification of system lineups prior to fuel load. After a number of false starts and three inspections the licensee provided an acceptable program to ensure that documented evidence existed to show independent verification of valve lineups and that the independer.t verification was adequate.

11. During 1985, the Senior Resident inspector identified discrepancies in the Engineering Operating Procedures (EOP) for the Clinton facility.

Regior based inspectors subsequently did an indepth review and identified additional problems. An enforcement conference was held but no escalated enforcement was taken because no unreviewed safety issues were identified.

The findings required a massive rewrite of the E0Ps and verification in aCCordance with regulations including comparing the procedures against the General Electric guidelines.

12. During late 1985 the Resident Inspectors identified that administrative procedures were not being revised and approved in accordance with RG 1.33.

The finding required the licensee to go back and review all procedures, to revise some procedures, review and approve in committee meetings a substantial number of the administrative procedures.

13. During inspections conducted by a DRS inspector, a number of discrepancies were identified where the as built drawings did not match the installed electrical equipment ir a number of panels. The licensee subsequently reviewed 46 electricri panels and found additional discrepancies. These discrepancies do not appear to affect the systems' ability to function properly. At a followup meeting between the licensee and the NRC, the licensee committed to seview an additional 92 panels. The licensee completed the review and associated engineering evaluation for each of l

( the 92 panels. All hardware related discrepancies were corrected prior to 5% power.

14. A Construction Assessment Team (CAT) Inspection was conducted at Clinton during May and June 1985. Approximately 2500 hours0.0289 days <br />0.694 hours <br />0.00413 weeks <br />9.5125e-4 months <br /> of inspection were expended. The Cat Team identified problems in electrical cable separation, unqualified wire used by maintenance and deficient wiring in vendor supplied electrical cabinets. The licensee had to replace some of the wire. Others were accepted after an engineering review,

15. During 1985, a DRS inspector identified that Construction Work Controls in the Containment were lax following a containment Leak Rate Test at Clinton in January 1986. Subsequently a hole was found in the containment liner. After a number of meetings the lictnsee agreed to a retest of the containment by means of a Type A (ILRT) test requiring the containment and valve lineups to be reverified prior to the test.

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16. During 1986, the Resident Inspectors identified that personnel performing activities affecting quality in maintenance were not properly trained or indoctrinated. Based on the inspector's findings the licensee stopped all Safety Related work being done by Stone & Webster (Maintenance Work). The work was allowed to resume after a massive training period and a pilot program which was followed closely by the NRC.

17. In February 1986, a DRS inspector identified weaknesses in the system turnover process in that it did not contain any minimum quality 1 requirements or criteria for accepting and maintaining systems in a condition that would not invalidate the completed preoperational tests.

After several false starts and a significant amount of inspection, the NRC accepted a turnover process in July 1986. Because of the false starts the licensee conducted a number of walkdowns to be able to demonstrate that all components, building and systems were included.

18. In summer 1986, the Senior Resident Inspector identified problems in the Service Water pump house. The cubicles were not properly floodproofed.

A civil penalty was assessed. Corrective action by the licensee included a verification that similar problems did not exist in the deactor Building Complex.

19. In 1986, a review of Bulletin 85-03 by a DRS inspector identified a potential common mode failure due to improper MOV torque switch settings.

Further inspection disclosed improper MOV training, poor procedures, and inadequate maintenance. Based on this inspection, a civil penalty was assessed. The licensee undertook a number of corrective actions including management changes, improved training and revising maintenance procedures.

20. During mid 1986, Region Based inspectors identified a number of problems with regard to maintenance of Motor Operated Valves (MOV) the deficiencies included improper greasing, improper MOVATS testing, improper or missing MOV parts, and inadequate training for maintenance personnel. The licensee corrected the individual problems and started a massive maintenance improvement program which included; new management and supervisors, upgraded procedures and training, trending of important maintenance parameters and additional QA oversight. The NRC reviewed and concurred in the program before allowing the plant to receive a low power license.

21. During 1986, the Senior Resident Inspector identified a discrepancy during a review of a plant modification to the Diesel Generator Air Start j System. The discrepancy identified that a component was changed in the air start system without any objective evidence that the diesel would start and operate under all required conditions. Based on this finding the licensee initiated a critical self assessment which included revising a number of design control procedures and a replacement of the Nuclear Station Engineering Manager.

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22. During 1986 the Resident Inspector identified discrepancies in the licensee's submitted Inservice Testing (ISI) program. The discrepancies identified included valves not in the proper lists and valve stoke times that did not seem appropriate. A number of resubmittals by the licensee and several inspectors b'i Regional based inspectors were required to close the issue.

23. During 1987, a DRS inspector identified improper EQ Qualification for Butt Splices, Wire Caps and Drain Holes in junction boxes. A civil penalty resulted from this finding. The licensee undertook additional EQ testing, revised EQ procedures and has upgraded their ongoing programs.

24. An Operational Readiness inspection was concluded during March 1987.

During the inspection weaknesses were identified in the area of Maintenonce Backlog, Work Scheduling and Adherence to procedures. Based on this inspection the Commission briefing and full power license issuance was delayed over a month. Licensee undertook a number of corrective actions which were reviewed and accepted by the NRC.

25. During 1987 the Resident Inspector identified a number of valves missing locking devices. Based on this finding the licensee revised their lock

valve program and redid the valve lineup, locking valves where required.

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