ML20197J947
| ML20197J947 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/02/1998 |
| From: | Dapa M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Walter MacFarland ILLINOIS POWER CO. |
| References | |
| NUDOCS 9812160040 | |
| Download: ML20197J947 (47) | |
Text
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December 2, 1998 Mr. Walter G. MacF: rland IV Senior Vice President l
Clinton Power Station Illinois Power Company Mail Code V-275 P. O. Box 678 Clinton,IL 61727
Dear Mr. MacFarland:
l On November 3,1998, the NRC staff held an inspection resource planning meeting (IRPM).
The IRPM provided a coordinated mechanism for Region lil to adjust inspection schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in April 1999. This letter advises you of our planned inspection effort for the next 6 months at Clinton Power Station (CPS).
On September 15,1998, a revised Case Specific Checklist (CSC) specifying the items that the NRC considered necessary to be resolved prior to plant restari and the associated NRC inspection plan for those items were forwarded to Illinois Power Company. Based on October 19 and November 24,1998, letters from you requesting deferral of three inspections, we have modified our inspection plan. The new inspection activity plan is enclosed. We have also enclosed a revised CSC which reflects the closure of two items and the addition of one item concerning the operator requalification program. Additionally, the plant issues matrix covering the past 6 months inspection activities at CPS is enclosed.
Finally, as you are aware, Mr. Stuart A. Richards, Project Director Ill-2, Office of Nuclear Reactor Regulations, has been assigned as the new Site improvement and Restart Oversight Panel Vice-Chairman.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of thir. letter and its enclosure will be placed in the NRC Public Document Room.
Please contact me if you have any questions concerning this issue.
Sincerely,
/s/ M. L. Dapas Marc L. Dapas, Deputy Director Division of Reactor Projects
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Docket No.: 50-461 License No.: NPF-62
Enclosures:
1.
Inspection Activity Plan 2.
Core Specific Checklist l
i 3.
Plant issues Matrix l
l See Attached Distribution See Previous Concurrences DOCUMENT NAME: G:\\ CLIN \\lNSPPLN7.CLI To receive a copy of th a doca.pnent. Imscate in the bos "C" e Copy w/o attacNond T e Copy w/snacNonet *>r' = No copy OFFICE Rlll l
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9812160040 981202 PDR ADOCK 05000461 0
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W. MacFarland IV,
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G. Hunger, Station Manager R. Phares, Manager, Nuclear Safety l
and Performance improvement J. Sipek, Director - Licensing N.' Schloss, Economist j
Office of the Attomey General G. Stramback, Regulatory Licensing Services Project Manager General Electric Company Chairman, DeWitt County Board State Liaison Officer Chairman, Illinois Commerce Commission Distribution:
RPC (E-Mall) l
' Project Mgr., NRR w/encis l
J. Caldw0ll, Rlll w/encls C. Pedersen, Rlli w/encls B. Clayton, Rlll w/encls SRI Clinton w/encls DRP w/encls TSS w/encls DRS (2)w/encls Rill PRR w r3efs 1
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l Mr. Walter G. MacFarland IV Senior Vice President Clinton Power Station i
lilinois Power Company Mail Code V-275 P. O. Box 678 Clinton,IL 61727
Dear Mr. MacFarland:
On November 3,1998, the NRC staff held an inspection resource planning meeting (IRPM).
The IRPM provided a coordinated raechanism for Region 111 to adjust inspection schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in April 1999. This letter advises you of our planned inspection effort for the next 6 months at Clinton Power Station (CPS).
On September 15,1998, a revised Case Specific Checklist (CSC) specifying the items that the NRC considered necessary to be addressed prior to plant restart and the associated NRC inspection plan for those items were forwarded to Illinois Power Company (IP). Based on October 19 and November 24,1998, letters from you requesting deferral of three inspections, we have modified our inspection plan. The new inspection plan is enclosed. We have also enclosed a revised CSC which reflects the closure of two items and the addition of one item concerning the operator requalification program. Additionally, the plant issues matrix covering the past 6 months inspection activities at CPS is enclosed. Finally, as you are aware, Mr. Stuart A. Richards, Project Director lll-2, Office of Nuclear Reactor Regulations, has been assigned as the new Site Improvement and Restart Oversight Panel Vice-Chairman.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
Please contact me if you have any questions concerning this issue.
Sincerely, Marc L. Dapas, Deputy Director l
Division of Reactor Projects Docket No.: 50-461 License No.: NPF-62
Enclosures:
1.
Inspection Activity Plan 2.
Restart Plan 3.
Plant issues Matrix See Attached Distribution:
DOCUMENT NAME: G:\\ CLIN \\lNSPPLN7.CLI t.- *.... a n.*c m a m mm. w e.co e. - - r.cm m.e v.mem OFFICE Rlli 6
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NAME Kozak/mf*%c Grobe h/
Richards"df/.G;/
Dapas DATE n/w/91
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/S/a/Hr OFFidlAL RECORD COPY l
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CLINTON INSPECTION / ACTIVITY PLAN INSPECTION /
TITLE /
NUMBER OF NRC PLANNED TYPE OF INSPECTION /
ACTIVITY PROGRAM AREA INSPECTORS /
DATES ACTIVITY-COMMENTS INDIVIDUALS IP 82701 Emergency Preparedness 3
During 1" quarter RegionalInitiative to 1999 EP drill review IP 62706 Maintenance Ru!e Followup 3
12/14-18/98 Regional Initiative to review improvement efforts in risk assessment and maintenance rule implementation IP 93809 Safety System Engineering 6
1/4-23/99 Regional Initiative to inspection (SDFV Followup)
To be rescheduled review design verification pending licensee's project readiness IP 40500 Effectiveness of Licensee 4
2/8-19/99 Regional Initiative to Controls in Identifying, review response to DFt Resolving, and Preventing and new corrective action Problems /Onsite Engineering program IP 81700 Security 2
1/25-29/99 Core inspection IP 83750 Radiation Protection 1
2/8-12/99 Core inspection
l CLINTON INSPECTION / ACTIVITY PLAN INSPECTIONI TITLE /
NUMBER OF NRC PLANNED TYPE OF INSPECTION!
ACTIVITY PROGRAM AREA INSPECTORS /
DATES ACTIVITY-COMMENTS INDIVIDUALS IP 64100 Fire Protection 3
2/16-22/99 Regional Initiative to verify safe shutdown capabilities IP 93802 Operational Readiness S
3/8-12/99 Regionalinitiative to inspection review conduct of operations in the control room; and deferred condition reports, preventative and corrective maintenance items.
IP 71001 Operator Requalification 1-2 Ongoing Regional Initiative to review effectiveness of corrective actions and improvements to the requalification program.
t Legend:
IP Inspection Procedure Tl Temporary Instruction Core inspection Minimum NRC Inspection Program (mandatory at all plants)
Regional Initiative Additional Inspection Effort Planned by Region lll
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CLINTON RESTART PLAN: CASE-SPECIFIC CHECKLIST MATRIX DESCRIPTION RESTART LICENSEE RESPONSIBLE DATE ITEM NUMBER PLAN ACTION ORGANIZATIONI CLOSEDI REFERENCES STATUS INSPECTION MECHANISM PLAN Management and Supervision 1.1 Estabhsh and implement Management Expectations Root cause from the OPEN Resdent staff NRC Safety Evaluation Team (SET) Report. CPS Plan For Exce:lence (PFE) Summary Sedion 2.1.
II.
Conduct of Operations it.1 Estabitsh and implement Continuing Operator Training Emphasizsng NRC Inspecten OPEN Resdent staff and TS Adherence / Knowledge and Recognition of Degraded Conditons Reports 97022 DRS Operations 97025 and 98003.
Evaluation PFE Summary Sectons 2.2 and 2.4.
- 11. 2 Estabhsh and implement an Effective Equipment Clearance Program NRC Inspection COMPLETED Resdent staff Closed at 0350 Report 97019.
intemal meeting 10/1/98 NRC Inspection Report 98017
- 11. 3 Revew and Revise Ab:ormat Operatens Sedions of Operations NRC Letter uated OPEN Resdent s'aff and June 9,1997 DRS Operations
" imposition of Civil Evaluation Penalty? NRC Inspection Report 98003. PFE Summary Sedion 2 2 1
DESCRIPTION RESTART LICENSEE RESPONSIBLE DATE ITEM NUMBER PLAN ACTION ORGANIZATION /
CLOSEDI REFERENCES STATUS INSPECTION MECHANISM PLAN ununummmmmmmmmmuni Il4 Establish and implement an Effective Risk Assessment Program NRC Inspecbon OPEN DRS Marntenance Report 97022. PFE Rule Follow-up Summary Section 2.2 and 2.4.
II.5 Provxte Reasonable Assurance that Deficiencaes Found Dunng Re-Identifed after Sept OPEN DRS followup 1
Qualification Exams Have Been identified and Corrected.
1998 requal failures.
Discussed at 10/1/98 intema! 0350.
Ill.
Corrective Actions 111. 1 Establish and implement Acbons to Achieve and Sustain Demand For OPEN DRS 40500 improvement in the Corrective Action Wrogram information (DFI)
Inspection item 1. SET Report.
PFE Summary 2.3.
111. 2 Establish and implement Performance Measures To Assess DFI ttem 1. SET COMPLETED Resident Staff Closed at 0350 Performance Report. PFE intemat meeting Summary 2.3.
10/1/98 NRC Inspection Report 98017 IV.
Structures, Systems, and Components (SSCS) Operational Readiness IV.1 Estabhsh Program to Reduce and Maintain Main Control Room Confirmatory Action COMPLETED Resident Staff Deficiencies Letter R!il-97-001 NRC Inspection Report 98003. PFE Summary Section 2.4.
IV.2 Provide Reasonable Assurance that Deficiencies Affecttng Safety DFlitem 2. PFE OPEN Resident Staff and Retsted SSCs Have Been identdied and Corrected.
Summary DRS 40500 Inspection Section 2.3.
IV.3 Reselve issues Associated With C6rcutt Breaker Failures Confirmatory Action OPEN DRS AIT Follow-up Letter Rlll-97-009.
PFE Summary Section 2.4.
IV.4 Resolve Degraded Voltage and Electncal Distnbution Concems NRC inspecbon OPEN DRS-SSEt Report 97012. PFE Summary Sede 2 4 2
DESCRIPTION RESTART LICENSEE RESPCNSIBLE DATE ITEM NUMBER PLAN ACTION ORGANIZATIONI CLOSED /
REFERENCES STATUS INSPECTION MECHANISM PLAN IV.5 Resolve Fire Protection Safe Shutdown Concems SET Report. PFE OPEN CRS - Fire Protechon Summary inspection Section 2.4.
IV.6 Complete Root Cause Analysis of Recirculation Pump Seal Fadures PFE Section 2.4.
COMPLETED Resdent staff and Develop Field Performance Measures NRC inspection Report 97012.
IV.7 Resolve EDG Concems SET Report.
OPEN Resident staff V.
Maintenance V.1 Develop Process to Revew Deferrals of Preventrve Maintenance SET Report. PFE OPEN Resdent staff iterns.
Summary Section 2.4 V.2 Provde Reasonable Assurance that Quahfied Matenals and Parts LERs 98001 and OPEN Resident staff are installed in Plant Systems 98004, NRC Inspedion Report 97020.
V.3 Estabhsh Maintenance Rule Program PFE Summary OPEN DRS - Maintenance Section 2.4.
Rule Follow-up Inspection VI.
Design and Configuration Control VI.1 Provide Reasonable Assuance That Safety Related SSCs Wdt SET Report. PFE OPEN ORS - E&TS and Perform Their intended Safety Functions as Descnbed in the Design Summe<y Section SSEl and Licensing Basis 2.4. System Design and Funcional Validation (SDFV)
Program.
VI.2 Valdate the Adequacy and Control of Calculabons SET Report. SDFV OPEN DRS - E&TS and Program SSE1 VI.3 Valdate the Adequacy and Control of the Setpoint Prngram SET Report. SDFV OPEN ORS - ESTS and Prograrr SSEl VII.
Emergency Preparedness Program Vll.1 Develop and Implement EP Improvement in6atrves NRC Inspecbon COMPLETED Resdent staff and Report 98003. 97022 DRS -EP inspection 3
l 1
ITEM DESCRIPTION RESTART LICENSEE RESPONSIBLE DATE NUMBER PLAN ACTION ORGANIZATION 1 CLOSEDI REFERENCES STATUS INSPECTION MECHANISM PLAN Vill.
Licensing Actions V!!!.1 Develop a List and Schedule for Antcpated Licensing Action General OPEN None Required l
Submrttahs Affectino Plant Restart l
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. PLANT ISSUES MATRIX Clintsn Search Sorted by Date (Descending) and SMM Codes (Ascending): search Cdumn = *Date' ; Begtnrung Data = *10/30/1997*, Erdng Data = *10/30/1998*
DATE TYPE SOURCE ID BY l SALP SMM CODES DESCRIPTION 1
8/18/1998 Negative IR 98014 NRC Operations 1A 5A Operations personnel did not recognize a potential reduction in ultimate heat sink inventory as a condition requiring an operability determination or i
mode rcstraint.
2 8/18/1998 Positive IR 98014 NRC Operations 1A SA The inspectors noted that operator performance improved with respect to questioning degraded or suspect indications, taking conservative immediate actions, and initiating the appropriate corrective action document. The performance improvement was due, in part, to implementation of the operations department event free performance initiative.
3 8/18/1998 Positive IR 98014 NRC Plant 1C in preparation for the installation of a fire separation wall, the licensee Support removed a
,2-inch suppression pool cleanup line which resulted in an estimated 28 person-rem dose savings for the modification. This demonstrated effective imolementation of the As Low As Reasonab!y Achievable (ALARA) program.
4 8/18/1998 Positive IR 98014 NRC Plant 1C The licensee's self contained breathing apparatus inspection program Support was thorough in that inspections were performed at the proper frequency, a!! material condition and functionality issues were addressed, and appropriate actions were taken when test failures were identified.
5 8/18/1998 Negative IR 98014 NRC Plant 1C The inspectors determined that emergency planning personnel had not Support verified the capability to statt emergency response organization positions following a failure of the autodialer pager system even though there had been four failures of the pager system since July 1997.
Page 1 of 37 F
PLANT ISSUES MATRIX Clintan Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Cotumn = *Date* ; Beginring Date = *10/30/1997* ; Erdng Data = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 6
8/18/1998 NCV IR 98014 NRC Engineering 28 One violation was identified for which enforcement discretion was exercised. The inspectors identified that Technical Specification requirements were not met because the Division Ill EDG cannot automatically switch during surveillance testing from the test (droop) mode to the isochronous mode as required in response to an actual or simulated emergency core coo!ing system initiation signal. This item is of concem because the Division ill EDG test conditions were such that the high pressure core spray (HPCS) pump, which is powered by Division lit, would not have been able to supply the required flow to the core if a valid HPCS signal was received while the EDG was being tested. Also of concem is that the licensee did not recognize that the design of the EDG resulted in the inability to meet a Technical Specification requirement.(NCV 50-461/98014-01).
7 8/18/1998 Negative IR 98014 NRC Maintenance 28 Although the Division 11 emergency core cooling system (ECCS) integrated loss-of-offsite-power and loss-of-coolant-accident survei!!ance testing was completed without complications, the preplanning for the test could have been more thorough. For example, some personnel assignments were initially made and/or changed at the briefing, communication links were not established ahead of time, the placement of test cables created a tripping hazard, mechanical stops were not used on open cabinets, and test switches were installed inside energized panels. Additionally, the prejob brief did not inc!ude lessons leamed, industry experience, or contingencies 8
8/18/1998 Positive IR 98014 NRC Maintenance 2B The inspectors concluded that the licensee's revised molded case circuit breaker testing program conformed to the latest NRC and industry guidance.
9 8/18/1998 Weakness IR 98014 NRC Maintenance 2B 3B The inspectors identified a weakness with the scheduling and ' completion of Technical Specification Surveillance Requirements (SRs). The identified issues included: 44 percent of all monthly and quarterly survei!!ances were being performed in the 25 percent grace period after the due date; 11 overdue Technical Specification SRs were omitted from a weekly survei!!ance test report; personnel were unaware of the safety-related preventive maintenance (PM) tasks that were required to meet a i
specific Technical Specification SR; and, the impact on Technical Specification SRs was not evaluated for a late safety-related PM task.
Page 2 of 37
PLANT ISSUES MATRIX 1 /2/1998 '
Clinton search Sorted by Date (Descerxhng) and SMM Codes (Ascending): Search Column = *Date*, Begirnng Data = *10/30/1997*, Ending Date = *10/30/1998*
t DATE TYPE SOURCE ID BY SALP SMM CODES l DESCRIPTION 10 8/18/1998 Negative IR 98014 NRC Engineering 4B Engineering personnel did not provide adequate suppon to operations personnel in that a CR addressing an already resolved issue was not closed in a timely manner.
11 8/18/1998 Negative IR 98014 NRC Maintenance SA The inspectors noted that management expectations were not met during the review of selected condition reports (CRs) in that maintenance personnel did not determine and document the extent of the condition associated with some level three CRs.
12 8/18/1998 Negative IR 98014 NRC Operations SA The inspectors
- review of the operations department self-assessment
(
program revealed that, between January and July 1998, it did not have a '
stable program owner to oversee completion of self-assessments, l
weaknesses identified in operator radiation work practices were not addressed, and recommendations and weaknesses described in the radiation worker practice and quarterly assessment reports were not l
tracked or assigned a responsible ownar. These findings were indicative !
of the need for improvement in the operations department's formal self-assessment program 13 8/18/1998 Negative IR 98014 NRC Operations SC The inspectors determined that the licensee's Generic Letter 91-18 program for operability determinations (ODs) was not effective in ensuring ODs were dispositioned in a timely manner. Specifically,28 of 41 active ODs describing nonconforming conditions were older than 6 months. Actions taken in May 1998 to disposition the active ODs were not successfulin that only one of five shift managers had completed the review of assigned ODs by August 1,1998 14 8/18/1998 Positive IR 98014 NRC Operations SC As a result of the corrective actions that were implemented to improve performance in the safety tagout program, including providing additiona!
staffing, increasing management oversight, and improving training for operations and maintenance personnel, tagout events were reduced from :
11 in 1997 to 3 as of August 1,1998.
i 15 8/18/1998 Negative IR 98014 NRC Operations SC Operations personnel implemented nonconservative compensatory
[
measures for a potential fault condition affecting the Division i Nuclear System Protection System (NSPS) inverter. Specifically, operations l
personnel viewed declaring a faulted component administrative!y i
inoperable as an adequate compensatory measure even though leaving l
the faulted NSPS inverter energized could potentially introduce complications with the power supply.
l i
Page 3 of 37
12/2/1993 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): search Column = *Date* ; Begirr.ing Date = *10/30/1997* ; Erxfiag Date = *10/30/1998*
I DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 16 7/10/1998 Positive IR 98011 Self-Operations 1B The inspectors concluded that operations personnel responded well to Revealed the loss of three of four offsite power sources during a storm. A Notice of Unusual Event was conservatively declared and safety system restoration was appropriately prioritized and accomplished in a reasonable timeframe.
17 7/10/1998 Positive IR 98011 NRC Ope ations 1C Operations personnel demonstrated improved command and control, appropriate prioritization of restoration activities, and good procedure adherence following a momentary loss of the emergency reserve auxiliary transformer (ERAT). The development of just-in-time training regarding electrical transients and plant response prior to an ERAT outage was considered a positive effort towards improving operator performance.
18 7/10/1998 ED IR 98011 NRC Maintenance 28 One viotation for which enforcement discretion was exercised was identified for the failure of operations personnel to imp!ement procedural requirements while performing troubleshooting activities on the logic for the outboard main steam isolation valves (MSIVs) and on main contro!
l room panel P-680.(NCV 50-461/98011-03).
19 7/10/1998 ED IR 98011 Ucensee Maintenance 28 One violation for which enforcement discretion was exercised was identified conceming the failure to ensure an adequate procedure was used during testing of the high pressure core sprey discharge isolation valve. The inspectors concluded that some procedural adequacy and adherence problems continued to occur at the facility. (NCV 50-461/98011-05).
20 7/10/1998 ED IR 98011 NRC Maintenance 28 1C Two examples of a violation for which enforcement discretion was exercised were identified due to the failure to implement procedures to perform required testing on the meteorotegical monitoring tower and a process radiation monitor prior to retuming the equipment to an operable i
condition. The failure to perform required surveillances prior to returning equipment to service is a repeat of previous, similar issues at the station.
(NCV 50-461/98011-02).
21 7/10/1998 Negative IR 98011 NRC Maintenance 38 The inspectors observed two poor electrical maintenance work practices during testing of 480 Vac molded case circuit breakers MCCBs which involved the use of excessive torque on fasteners and improper use of megger test equipment Page 4 of 37
't
PLANT ISSUES MATRIX
' SS8 Clinton Search Sorted by Date (Descerwhng) and SMM Codes (Ascending): Search Column = "Date". Begmng Data = *10/30/1997*. Ending Data = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCR PTION 22 7/10/1998 Negative IR 98011 Self-Engineering 4B The adequacy of information provided in engineering and operability Revealed evaluations was mixed. Engineering personnel provided an adequate basis for continued operation of the residual heat removal B and C water leg pump. However, engineering personnel did not initially provide an adequate basis for the automatic transfer of the Division lit electrical safety bus or adequate assurance that a piece of copper tube was not located in the tube oil system of the Division i Emergency Diesel Generator.
23 7/10/1998 ED IR 9801
- NRC Operations SA One violation for which enforcement discretion was exercised was identified conceming the failure of reactor operators to appropriately identify and resolve unusual trends in the shut down service water, reactor recirculation, and standby gas treatment systems during the performance of control room panel walkdowns.
24 7/10/1998 Negative IR 98010 NRC Operations SA The inspectors concluded that while reactor operators performed comprehensive control room panel walkdowns during shift tumover, oncoming senior reactor operators and shift managers performed cursory reviews of the control panels and did not examine all panels during shift tumovers. This may have contributed to performance problems involving identification of degraded or nonconforming conditions by control room personnel 25 7/10/1998 Negative IR 98011 NRC Operations SA 3B Eight days elapsed and inspector prompting was needed to initiate a condition report to document the repetitive failure of the outboard MSIVs to open during a monthly preventive maintenance task. Additionally, operations personnel did not recognize the failure of the MSIVs to cpen as a Technical Specification mode restraint until prompted by the inspectors.
26 7/10/1998 Negative IR 98011 NRC Engineering SA 4B One example of a degraded condition affecting the calibration of control room indications was identified by engineering personnel but not brought to the attention of operations personnel. Consequently, an evaluation of 3
the generic implications of uncalibrated instrumentation on continued plant operations was not initiated until prompted by NRC inspectors.
27 7/10/1998 Positive IR 98011 NP.C Operations 5B Operations personnel conservatively directed an inspection of the Divisions I and 11 emergency diesel generators (EDGs) following the discovery of fastener issues during the Division ill EDG outage.
Page 5 of 37 i
PLANT ISSUES MATRIX 12/2/1998 Clinton Search Sorted by Date (Descerxting) and SMu Codes (Ascending): Search Column = *Date* ; Beginning Date = *10S00997* ; Ending Data = *10004998*
O DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 28 7/10/1998 ED 1R 89011 NRC Operations SC One violation for which enforcement discretion was exercised was identified for the failure to implement corrective actions in response to a long-standing, nonconforming condition involving excessive shut down service water flow to the residual heat removal heat exchanger bypass.
Operations personnel did not challenge engineering personnel to seek a remedy for the condition (NCV 50-461/98011 -01).
29 7/10/1998 ED IR 98011 NRC Maintenance SC One violation for which enforcement discretion was exercised was identified when the inspectors determined that corrective actions to address 4160 Vac circuit breaker testing problems were not applied to molded case circuit breakers (MCCBs). Specific MCCB test program deficiencies included: improper test cable size, not performing a low current instantaneous trip, excessive test current pulse length, excessive instantaneous test current, improper instantaneous trip times, preconditioning of breakers, not documenting valid test attempts, and not evaluating breaker coordination issues for failed breakers. In addition, the inspectors determined that the licensee did not effectively utilize industry information and experience even though it was involved in the development of standard industry guidance for testing of 480 Vac MCCBs
. (NCV 50-461/98G11-06).
30 6/25/1998 Positive IR 98013 NRC Plant 1C Whole body contamination monitoring and counting instrumentation was Support properly calibrated and maintained. Radiation protection oversight of this equipment, including instrument technician performance, was considered good.
32 6/25/1998 Negative IR 98013 NRC Plant 1C The inspector noted that station procedures did not instruct personnel Support when to perform air sampling and did not contain a formal process for tracking the assignment of lapel air samplers and associated sample analysis results. These areas were being addressed by the licensee 32 6/25/1998 Negative IR 98013 NRC Plant 1C Numerous documentation errors were identified in whole body Support contamination monitor calibration records and the documentation of instrument maintenance histories warranted improvement.
33 6/25/1998 Positive IR 98013 NRC Plant 1C Air sampling activities for the containment and drywell containment Support coatings work were properly performed and representative of work activities. Observations of work confirmed that workers were using good radiation work practices and that radiation protection technician coverage was appropriate.
Page 6 of 37
PLANT ISSUES MATRIX 12/2/1998 Clintsn Search Sorted by Date (Descending) and SMM Codes (Ascerdng): Search Column = *Date* ; Begirnng Date = *10/30/1997" : Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 34 5/28/1998 Positive IR 98008 NRC Operations 1C The inspectors concluded that operation's logs included sufficient detail to I describe plant activities, compensatory measures for cut-of-service annunciators were appropriate, and coordination and contingency plans referenced approved procedures.
c 35 5/28/1998 VIO/SL-IV IR 98008 NRC Maintenance 1C 28 The inspectors identified a violation for the failure to verify each secondary containment manual isolation device closed every 31 days as required by Technical Specifications between discovery on June 18,
[
1996, and initial perforn;ance of the implementing surveillance procedure l on December 1,1996.
l 36 5/28/1998 Weakness IR 98008 NRC Maintenance SA The inspectors determined that quality assurance inappropriately l
provided a positive review of maintenance department self-assessments ;
in that: only five of eight scheduled audits were completed, condition reports were not generated, action items were assigned without due dates for completion, due dates for action items were allowed to be extended without approval by the respective manager, Task Performance,
Check Lists were not tracked or trended to provide performance t
indicators, and results from Task Performance Check Lists were not i
consistent with results from other performance monitoring systems.
37 5/28/1998 VIO/SL-IV IR 98008 NRC Operations SC The inspectors identified a violation for not impfementing corrective actions to preclude the failure to perform verifications on a!! primary containment manual isolation devices as required by Technical Specification's following a similar discovery affecting secondary i
containment manualisolation devices in June 1996.
38 5/15/1998 Negative IR 98008 NRC Operations 3B The inspectors identified one example of a poor questioning attitude which involved the ability of operations personnel to recognize changing plant risk conditions during periods of degraded grid voltage.
39 5/10/1998 Positive IR 98010 NRC Plant 1C The radiation protection staff properly implemented the extemal dosimetry L Support quality control program. The licensee maintained National Voluntary Laboratory Accreditation Program accreditation in accordance with 10 CFR Part 20. In addition, periodic thermoluminescent dosimeter quality control tests were performed as required, and the results were evaluated for long term biases or trends.
Page 7 of 37
1 PLANT ISSUES MATRIX 2/2/1998 Clinton Search Sorted by Date (Descerdng) and sMM Codes (Ascending): search Colurnn = *Date* - Begirnng Date = *10/30/1997*, Erdng Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 40 5/10/1998 Negative IR 98010 NRC Plant 1C The radiation protection (RP) staff continued to initiate improvement Support actions to address radiation worker practices and RP program weaknesses and to perform self assessments to monitor performance.
Although some reduction in radiation worker problems was noted, the inspector observed that radiation worker practices and RP techrucian performance continued to be a challenge. The inspector also noted that planned RP improvement actions were not always met with a high level of plant-wide commitment.
41 5/10/1998 Negative IR 98010 NRC Plant 1C The inspector identified problems in the documentation of quality control Support test results and corrective actions performed during routine thermoluminescent dosimeter processing.
42 5/10/1998 Positive IR 98010 NRC Engineering 1C 48 The system engineer performed good trending of system operability for the primary meteorological tower. The calibrations and survei!!ances for the pimary meteorological tower were properly performed.
43 5/10/1998 Positive IR 98010 NRC Plant 1C 5A Environmental sample results did not indicate any discemable effects Support from plant operations and/or radioactive releases. The 1996 and 1997 annual reports were well written, and the licensee had replaced some sampling instrumentation to improve operability of the air samplers.
44 5/10/1998 Posi3ve IR 98010 NRC Plant 1C SA Quality assurance assessments of the licensee's radiological Support environmental monitoring program, including the performance of the vendor laboratory, were thorough. In particular, the audit of the vendor laboratory identified notable weaknesses in the vendor's implementation of its quality control program. The inspector observed that the radiation protection organization was aware of the issues and was taking actions to address audit findings and recommendations.
45 5/10/1998 Negative IR 98010 NRC Plant 1C SC The licensee continued to maintain administrative extemal dose levels to Support ensure that personnel doses were maintained ALARA. With the exception of one individual's total effective dose equivafent (TEDE),
personnel doses for 1996 and 1997 were below the administrative dose levels. Although the radiation protection staff investigated the incident and implemented corrective actions, the inspector noted that the licensee's actions were not timely. In addition, the inspector noted some errors in the licensee's quarterly comparisons of doses measured via thermoluminescent dosimeters and electronic dosimeters.
Page 8 of 37
PLANT ISSUES MATRIX 12/2/1998 Clintrn Search Sorted by Date (Descending) and SMM Codes (Ascending): search Column = *Date*
Beginning Date = *10/30/1997*, Ending Data = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 46 5/10/1998 VIO/SL-IV IR 98010 Licensee Plant 1C SC A violation was identified conceming the failure to post a radiation area in Support the control rod drive filter area within the turbine buil ding. Although the licensee identified this violation, the radiation protection (RP) staff missed two prior opportunities to identify and correct this violation. On two independent radiological surveys, RP technicians measured and documented radiation levels in the area which would have required a radiation area posting but did not recognize that the area was not prope'1y posted.
47 5/10/1998 NCV IR 98010 Licensee Maintenance 28 One non-cited violation was identified conceming the failure to perform monthly meteorological tower operability verifications at the required frequency. In addition, the inspector identified some continuing problems concerning the licensee's attention to the backup meteorological tower.
Specifically, a 6-month preventive maintenance survei!!ance was scheduled for January 22,1998, but had not been performed.
48 5/10/1998 NCV IR 98010 Licensee Plant 3A SA SC Two non-cited violations were identified conceming the deliberate Support falsification of a radiological survey record by an radiation protection technicia 1. The licensee performed a thorough investigation of the incident and implemented immedate corrective actions.
49 5/10/1998 Negative IR 98010 NRC Plant 38 The inspector identified some problems concerning technician knowledge Support level and techniques. In addition, performance problems conceming well water compositors were not f>f y evaluated by the radiation protection H
staff to ensure that a representative sample was obtained.
50 5/8/1998 Negative IR 98009 NRC Plant 1B Control of in-plant operators was not well-coordinated between the main Support control room (MCR) and the Technical Support Center (TSC) during the 2/13/98 Alert.
51 5/8/1998 VIO/SL-IV 1R 98009 NRC Plant 1B in one case, on-shift staffing was inadequate during the 2/13/98 event, Support because only one of two mechanical maintenance workers on site was appropriately trained. This was a violatian.
52 5/8/1998 Positive IR 98009 NRC Plant 18 The Shift Supervisor's decision to classify an Alert in response to a loss of Support shutdown cooling event on February 13,1998 was conservative and defensible.
53 5/8/1998 Negative IR 98009 NRC Plant 18 Initial notifications of the Alert on 2/13/98 were made in a timely manner Support but contained some inaccurate meteorological information.
Page 9 of 37
PLANT ISSUES MATRIX 12/2/1998 Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search C6umn = *Date*, Beginning Data = *10/30/1997. Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 54 5/8/1998 Positive IR 98009 NRC Plant 1B A timely and compretiensive critique of the Emergency Response Support Organization performance was held fo!!owing the loss of shutdown cooling event.
55 5/8/1998 VIO/SL-IV 1R 98009 Self-Plant 18 1C The Emergency Response Data System was not initiated within the Revealed Support required timeframe of cne hour after the Alert on 2/13/98 was declared.
l This was a violation.
56 5/8/1998 Negative IR 98009 NRC Plant 1B SC Involvement of the Shift Technical Advisor in making initial notifications Support during the 2/13/98 event detracted from his primary duties. This was a repeat of events that occurred during the 9/5/96 recirculation pump seal failure event.
57 5/8/1998 Positive IR 98009 NRC Plant 1C Overall, the Emergency Preparedness program has been genera!!y Support maintained in an adequate state of operational readiness. Emergency response facilities, equipment, and supplies have generally been adequately maintained, with some exceptions.
58 5/8/1998 VIO/SL-IV IR 98009 NRC Plant 1C The call-in system and lack of Emergency Response Organization Support badges delayed Technical Support Center activation beyond goal timeframes during the 2/13/98 Alert. This was a violation. A good decision was made to control facility access, but security had to call the main control room for access approval for some personnel-a potential distraction at a critical time.
59 5/8/1998 Positive IR 98009 NRC Plant 1C An excellent decision was made to continue the Emergency Operations i
Support Facility (EOF) training drill during the actual power loss to the EOF.
Participants coped well with the effects of the power outage. Some emergency ceiling lighting allowed participants to gather and position other lighting equipment. Dose prcjection could not be performed in the EOF due to backup failures. A!! emergency exit lighting failed almost immediately. Emergency power supplies failed quickly, well before expected failure times.
60 5/8/1998 Negative IR 98009 NRC Plant 1C 28 The material condition of the Technical Support Center (TSC) was Support marg:nal, as was noted in the last inspection. The failure of the TSC 3
backup dose assessment laptop computer to function indicated that its test frecuency was not adequate.
i Page 10 of 37
PLANT ISSUES MATRIX 12/2/1998.
Clint@n Search Sorted by Date (Descending) and SMM Codes (Ascendmg): Search Column = "Date* ; Beginning Data = "10G0/1997*. Ending Date = *1000/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 61 5/8/1998 Positive IR 98009 NRC Plant 5A The licensee's 1997 and 1998 Emergency Preparedness audits were Support adequate and satisfied the requirements of 10 CFR 50.54(t). The audits were of adequate scope and depth, bt t were weak in the area of equipreent maintenance, particularly considering identified equipment operability problems.
62 5/7/1998 NCV IR 98008 NRC Maintenance 3A The inspectors concluded that procedures were not adequately adhered to when maintenance workers failed to retum an Maintenance Work Request to planning personnel for revision following the change in scope of the Division i Emergency Diesel Generator Var meter calibration on two occasions. NCV-98008-03 63 5/5/1998 Weakness IR 98008 NRC Operations 1C The inspectors identified several items that had not been considered during the licensee's material condition review to declare Electrical Division !! operable. The items were resolved, and the inspectors determined that Division 11 was operable for Mode 4.
64 5/1/1998 NCV IR 98008 NRC Maintenance 2B The inspectors concluded that an adequate procedure was not established and implemented for the installation of a clamp-on device on a safety-re!ated motor power feed wire to monitor various parameters.
NCV 50-461/98008-04 65 5/1/1998 NCV IR 98008 NRC Maintenance SC The inspectors identified a violation for failing to implement corrective actions for licensee identified discrepancies in the air operated valve i
program. Maintenance department self-assessments were weak in that four of five completed assessments did not determine if program elements were effectively implemented. (NCV 50-461/98008-05) 66 4/14/1998 Negative IR 98006 NRC Maintenance 1C Inadequate planning and work control resulted in two occasions where an available train of standby gas treatment was not maintained.
67 4/14/1998 Positive IR 98006 NRC Operations 1C Contingency plans for the Division 11 inverter outage and the reserve auxiliary transformer excavation work were tnorough in that they were communicated to affected personnel and considered the potential for several events.
68 4/14/1998 Positive IR 98006 NRC Plant 1C The fire brigade responded promptly during the performance of a fire Support drill i
Page 11 of 37 5
PLANT ISSUES MATRIX 2/2/1998 Clinton Search Sorted by Date (Descend;ng) and SMM Codes (Ascendang): Search Column = *Date* ; Beginning Date = *1000/1997*, Ending Data = *10G0/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 69 4/14/1998 Positive IR 98006 NRC Maintenance 2A The visible condition nf coatings inside the containment and drywell was considered good. The amount of coatings which were loose or flaking was negligible and did not present an appreciable source of debris which could clog the emergency core cooling system suction strainers.
70 4/14/1998 Positive IR 98006 Self-Operations 2A The Division 11 Emergency Diesel Generator and Residual Heat Removal Revealed Systems B and C were returned to an operable status. These systems had been declared inoperable but available in August 1997 (Plant Summary).
71 4/14/1998 Positive IR 98006 Licensee Maintenance 28 One example of good questioning attitude was identified when operations personnel stopped a surveillance to address the impact of a leaking equalizing valve on a flow instrument used during testing.
72 4/14/1998 Negative IR 98006 NRC Maintenance SC Past corrective actions to address degraded coatings were inadequate.
As a result, degradation developed such that emergency core cooling system (ECCS) suction strainer clogging may have occurred under certain circumstances and ECCS operabi!ity was not assured.
73 4/7/1998 Negative IR 98006 Licensee Plant 3A Numerous emergency response personnel fai!ed to respond several Support pager tests. Specifically, only 1 of 6 pager tests had 100 percent response from emergency response personnel.
74 3/27/1998 Negative IR 98007 NRC P: ant 1C The licensee performed a thorough assessment of a February 4,1998, Support incident involving a malfunction of a high range calibrator and the staff's decision to use the instrument after the malfunction was identified.
Although no unexpected personnel doses were received, the staff's decision to permit a third measurement with the malfunctioning high level source was a non-conservative decision, which was addressed by RP management 75 3/27/1998 Negative IR 98007 NRC Plant 1C The inspector found radiological hazards in the radiologica!!y contro!!ed Support area to be properly controlled and posted. However, access to certain safety related equipment, including the emergency core cooling system pump rooms, was encumbered by radioactively contaminated areas.
76 3/27/1998 NCV IR 98007 Licensee Plant 1C One Non-Cited Violation was identified for the failure to adequately Support implement Radiological Protection procedures conceming the basis for waiving an employment termination whole body count Page 12 of 37
PLANT ISSUES MATRIX
'2/2/1998-Clinton Search Sorted by Date (Descending) and SMM Codes (Ascerxhng): Search Cotumn = *Date". Beginning Date = *10/30/1997*. Erdng Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 77 3/27/1998 Negative IR 98007 NRC Plant 1C 28 The licensee performed calibrations of area and process radiation Support monitoring system monitors in accordance with procedures, which were consistent with regulatory guidance. However, the inspector identified that about 20 percent of the calibrations and functional tests were i
performed in the
- grace period" (i.e., between 1.00 and 1.25 times the stated performance frequency). The inspector also identified a problem with certain calibration procedures which had not been properly ident:fied and resolved by the staff.
78 3/27/1998 VIO/SL-IV IR 98007 NRC Engineering 4B One violation was identified conceming an inadequate 10 CFR 50.59 l
analysis which had been performed to address discrepancies between the plant configuration and the description of the plant in the Updated Safety Analysis Report. Specifically, the inspector identified that the safety analysis, which was performed by the licensee to address the absence of radiation monitors in the residual heat removal rooms A and i
B, did not address the leak detection function that was attributed to the monitors by the Updated Safety Analysis Report t
79 3/27/1998 Negative IR 98007 NRC Plant SA SC The material condition of radiation monitors was generally acceptable, Support with a few exceptions. Corrective actions were in progress to resolve shaft seal problems with the liquid process radiation monitors and to resolve operability problems with the standby gas treatment system and the heating, ventilation, and air conditioning system high range radiation monitors. Although radiation monitor indications were generally consistent, the inspector identified problems conceming the RP staff's routine review of radiation monitor performance, which included the identification and resolution of anomalous monitor responses 80 3/27/1998 Positive IR 98007 Licensee Plant SS The licensee performed a comprehensive review of the design basis of Support the area and process radiation monitoring system and the monitoring
[
console. The inspector noted that the current system configuration did not conflict with the design basis. Although the RP area was not equipped with monitor readout capability, plans were developed to l
replace the radiation monitor console in the control room and to install j
monitor readout capabilities in the RP area and in the technical support j
center i
t t
Page 13 of 37
m PLANT ISSUES MATRIX 12/2/19 %
Clinton Search Sorted by Date (Descerdng) and SMM Codes (Ascerwing): Search Column = "Date ; Beg vung Date = *10/30/1997*, Endire Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 81 3/27/1998 NCV IR 98007 Licensee Plant SC One Non-Cited violation was identified conceming the failure to Support implement an adequate procedure to dete*mine the proper trip setpoints t
for the main steam line radiation monitors. Although the licensee identified and corrected the deficiency in 1997, the RP staff had noted the i problem in 1990 but did not completely assess and resolve the issue.
82 3/19/1998 NCV IR 98006 Licensee Engineering 4A Engineering personnel inappropriately determined that the dry film thicknesses (DFT) for containment coatings applied in November 1997 were acceptable without performing an adequate evaluation of coatings with less than the minimum a!! owed DFT 83 3/3/1998 NCV IR 98003 NRC Operations 1A Control room operators intentionally deleted information from a control room computer screen in an attempt to maintain mental awareness.
Although the line assistant shift supervisor (LASS) was aware of this practice, he failed to take action to address the situation. The actions of the LASS and the reactor operator (RO) were indicative of continued poor }
operator performance, a general disregard for main control room indications, and poor supervisory oversight (Section 01.1).
84 3/3/1998 NCV IR 98003 NRC Operations 1A 2A 28 The inspectors identified that the corrective actions implemented failed to prevent another unmonitored increase in main control room (MCR) deficiencies and operator workarounds, even though both issues were the !
subject of a response to NRC Confirmatory Action Letter Rlli-97-001 l
(Section O2.1) l 85 3/3/1998 NCV IR 98003 NRC Operations 1A 3B 2A Operations and engineering personnel demonstrated poor knowledge o' the creathing air system in that they believed the system had been
[
abandoned in place and were unfamiliar with system operating r
parameters. Not using alternate compensatory methods to recharge the breathing air system bottles after identifying that the system was required l to be maintained operable at all times demonstrated a nonconservative i
establishment of priorities for system restoration (Section O2.2).
i Page 14 of 37 i
PLANT ISSUES MATRIX 1 /2/1998 Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *Date*, Beginning Date = *10/30/1997*, Ending Data = *10/30/1998*
.Il #
l DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 8S 3/3/1998 NCV IR 98003 NRC Operations 1A 5A Actions were not implemented to operate the service water traveling screens during cold weather in order to prevent ice blockage and a potentialloss of the ultimate heat sink. A delay in operating the traveling t screens upon completion of a maintenance activity indicated poor oversight of restoring required plant systems to service by operations personnel. Implement & tion of procedural guidance to minimize ice blockage of the intake structure following the identification of the issue was delayed due to the poor prioritization of procedure revisions (Section '
O2.3).
87 3'3/1998 Positive IR 98003 NRC Operations 1B The shift supervisor limited access to the MCR by assigning an individual the responsibility to prevent entry by non-essential personnel. This acticn significantly reduced the number of distractions in the main control room.
Operations personnel derronstrated good use of emergency, off normal,'
and system operating procedures in the MCR (Section P1.1).
j 88 3/3/1998 Weakness IR 98003 NRC Operations 1B 1C Minimum emergency plan staffing for on shift,30 minute, and 60 minute I
response was not met. Seven radiation protection and maintenance personnel were added to the on shift emmency planning minimum i
staffing requirements due to concems rega dirig the ability to meet the manning requirements (Section P1.1).
89 3/3/1998 Positive IR 98003 NRC Operations 1B 3A During the Alert, the shift supervisor maintained an oversight role of activities in the control room and prompted actions when appropriate.
The LASS controlled the activities of ROs and non-licensed operators.
l The shift supervisor used conservative decision making to activate the i
emergency response organization (ERO) in order to obtain additional resources to restore shutdown cooling (Section P1.1).
90 3/3/1998 URI 1R 98003 NRC Operations 1C Following an overload of the Division 11 Emergency Diesel Generator (EDG), the licensee identified that non-licensed operators had not been l
trained on the remote operation of the EDGs since lute 1992 or early
[
1993. In addition, some non-licensed operators were unaware of the significance of indications provided on the local EDG panels. After discovery nf the inadequate training, actions to ensure qualified personnel,
were available to perform local manual operation of the EDGs were not immediately taken (Section 05.1).
Page 15 of 37 t
PLANT ISSUES MATRIX 12/2/1998-Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date*, Beginring Date = *10/30/1997*, Ending Data = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPT10N 91 3/3/1998 Negative IR 98003 NRC Operations 1C Implementing procedures for cold weather preparations were cumbersome in that they were not easily identified and provided vague criteria for initiating actions. Numerous discrepancies with cold weather requirements were identified amongst the various cold weather procedures (Section O2.4).
92 3/3/1998 Negative IR 98003 NRC Operations 1C Even though the licensee was required to replace service air intake filters and secure ventilation systems due to icing on February 8,1998, a requirement to verify the intake filters were free of obstructions during cold weather periods had not been added to system operating procedures o the area operator logs as of March 9,1998 (Section O2.4).
93 3/3/1998 Weakness IR 98003 NRC Operations 1C Several deficiencies were identified in the procedure change process which included the implementation of multiple one time procedure i
changes to address the same situation on 4 out of 51 procedures, the lack of periodic reviews to determine if changes needed to be incorporated into the procedures, untimely procedure changes due to poor prioritization of procedure revisions, and inadequate performance of independent technical reviews and impact assessments. Collectively, the deficiencies signified that the licensee's corrective actions to improve procedure quality in resoonse to Confirmatory Action Letter 111-96-013 have not been fully effective (Section O3.1).
94 3/3/1998 NCV IR 98003 NRC Operations 1C SC Timely corrective actions were not implemented to prevent operations I
personnel from rendering both EDGs inoperable due to taking the maintenance switch for one EDG to the Icuout position in preparation for surveillance testing while the other EDG was inoperable (Section 08.2).
l 95 3/3/1998 NCV IR 98003 NRC Maintenance 2B 3A Provisions of the maintenance troubleshooting procedure were not implemented during testing of the Division 11 EDG kilowatt indication.
Specifically, maintenance personnel did not have a procedure or test plan for performing specific tasks, the activities were not approved by operations personnel, tasks being performed were not documented as they occurred, the chronology of events did not specify all actions taken, electrical raaintenance work practices were poor, and supervisory oversight was minimal (Section M1.2).
96 3/3/1998 Negative IR 98003 NRC Operations 3A Fire watch personnel failed to perform a tour of the Division II EDG room in order to evaluate the presence of transient combustible materials (Section F1.1).
Page 16 of 37
PLANT ISSUES MATRIX 12/2/1998 Clinton Saarch Sorted by Date (Descending) and SMM Codes (Ascending): Search Colu.nn = *Date*, Beginning Data = *10/30/1997*, Ending Data = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 97
?*W1998 Negative IR 98003 NRC Eng!neering 3A 3B SA The shift supervisor's review of condition report i 97-12-221 involving inadequate testing of RTDs and the diesel ventilation system was poor and lacked intrusiveness in that it was not property classified, it did not consider possit !e generic implications on othe; plant equipment, and it did not ensure that an appropriate tracking mechanism was in place to prevent an EDG from being retumed to an operable status prior to resolving the issue (Section E1.2).
98 3/3/1998 Positive IR 98003 NRC Maintenance 38 The briefing given prior to performing a special test procedure on the Division 11 EDG was improved from previous briefings and included information on communications, self checking, safety, and lessons teamed from other utilities (Section M1.3).
99 3/3/'998 NCV IR 98003, LER-NRC Engineering 4A Design basis information involving ambient outside air temperature was 97002 not translated into specifications which effected the service life of EDG components, and resulted in the Division 111 EDG being inoperable when outside air temperatures exceeded 91 F (Cection E1.1).
100 3/3/1998 NCV IR 98003 Licensee Engineering 4A Design basis information regarding the proper electrical isolation between Class IE and non-Class IE components was not translated into a modification package for replacing the Divisioil l and 11 EDG annuncia*or power supplies. This resulted in improper electrical isolation between non-Class IE ano Class IE EDG circuitry for approximately six years and created an unreviewed safety question which may have prevented the Division I and 11 EDGs from operating when outside air temperatures exceeded 91 F (Section E1.1).
101 3/3/1998 NCV IR 98003 NRC Engineering 4A An adequate 10 CFR Part 50.59 safety evaluation was not performed to ensure that changes in the testing methodology for the diesel ventilation system did not constitute an unreviewod safety question. Specifically, changes were made to delete test requirements from procedures even though the USAR clearly specified the testing to be performed (Section E1.2).
102 3/3/1998 Negative IR 98003 NRC Engineering 4A 3B Engineering personnel did not.ecognize the significance of extreme outside air temperatures on EDG operability. After prompting by the NRC inspectors, an appropriate engineering evaluation was performed (Section E1.1).
Page 17 of 37
PLANT ISSUES MATRIX
' ' " S*8*
Clintsn Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *Date*. Beginning Date = *10/30/1997* ; Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 103 3/3/1998 NCV IR 98003 NRC Engineering 4A 4C No testing of resistance temperature devices (RTDs) within the diesel ventilatioa system was performed to demonstrate that the RTDs would perform satisfactorily in service even though the Updated Safety Analysis Report (USAR) clearly delineated the requirement (Section E1.2).
104 3/3h908 Positive IR 98003 NRC Operations SA 3B The licensee performed a critical assessment of ERO performance during the Alert. Deficiencies noted by the licensee included offsite notifications, activation of the technical support center (TSC), operation of the autodialer, control of field teams, communications between the TSC and the MCR, site wide announcements, use of ERO badges, and controt '
of field samples (Section P1.1).
105 2/16/1998 NCV IR 98004 NRC Operations 1B Licensee personnel failed to adequately assess the risk involved with tagging out the division 2 NSPS regulating transformer and, as a result, failed to develop contingency plans for the potential loss of the division 2 NSPS bus. (Section 07.1) 106 2/16/1998 Positive IR 98004 NRC Operations 1B Operator response to a loss of shutdown cooling event on February 13, 1998, was generally good. One weakness identified was an emphasis on restoration of the division 2 nuclear system protection system (NSPS) bus as the sole success path for the restoration of shutdown cooling.
(Section 01.1) 107 2/16/1998 NCV IR 98004 NRC Operations 1B 3B 3A Some operators exhibited significant knowledge deficiencies regarding the configuration, operation, and availability of the division 2 NSPS bus and the associated supporting equipment following the loss of shutdown coc!ing event. This was the result of inadequate communication of the contingencies established should a loss of the NSPS bus recur. (Section 042) 108 2/16/1998 NCV IR 98004 NRC Operations 18 3C Procedures used to address the loss of shutdown cooling event failed to provide adequate instructions which unnecessarily challenged operators to respond to the event. (Section O3.1) 109 2/16/1998 NCV IR 98004 NRC Operations 3A 3B SA Operations personnel failed to take prompt actions to address a potential division 2 emergency diesel generator (EDG) overload event which occurred on February 11,1998. In particular, the shift resource manager (SRM) and *B' control room operator (CRO) failed to cor:servatively reduce EDG loading during a surveillance test when indications of an overload condition were identified. (Section O1.2)
Page 18 of 37
Y PLANT ISSUES MATRIX 12/2/1998 C Clinton Search Sorted by C.te (Descending) and sMM Codes (Ascending): Search Colurnn e *Date" ; Beginning Date = *10/30/1997*, Ending Data = *10/30/1993*
DATE TYPE SOURCE l
lD BY SALP SMM CODES DESCRIPTION 110 2/16/1998 Negative IR 98004 NRC Operations 3B Some operators were not adequately knowledgeable regarding the operation of the division 2 NSPS bus static switch as weil as the consequences of the loss of the NSPS bus on plant indications and logic inputs. (Section O4.1) 111 2/16/1998 NCV IR 98004 NRC Maintenance SC 2B The licensee failed to correct deficiencies associated with the division 2 NSPS inverter despite repeated failures. (Section M1.1) 112 2/13/1998 Positive IR 97025 NRC Operations 1A An auxiliary operator was knowledgeable of systems and provided good responses to questions during a tour of the containment, fuel, control, and duxiliary buildings. (Section O1.4) Teamwork / Skill Level 113 2/13/1998 Negative 1R 97025 NRC Operations 1A The failure to notice or provide a reason for the abnormal vent valve position indication associated with RHR Heat Exchanger A was an example of poor awareness of plant indications by operations personnel in the main control room. (Saction 01.1.b.7) Personnel Performance 3
Deficiency 114 2/13/1998 Negative IR 97025 NRC Operations 1A The inability to explain the status of the normally operating ft;el building ventilation system was an example of poor awareness of p' ant conditions by operations personnel. (Section 01.1.b.8) Personnel Performance Deficiency A 13-day' delay in restoring SRMs to an operable status was an example 115 2/13/1998 Negative IR 97025 NRC Operations 1A of poor awareness of plant conditions and a lack of operations personnel involvement in restoring Technical Specification equipnrnt to a fully operable status. The avoidable delay in restoration resulted in an unnecessary entry into plant Technical Specification 3.3.1.2, " Source Range Monitor instrumentation." (Section O1.1.b.5) Other/NA 116 2/13/1998 Negative IR 97025 NRC Operations 1A Several deficiencies were identified involving the operations mode restraint tracking system, which included: condition reports and engineering evaluations which were not identified as mode restraints; condition reports and engineering evaluations which were classified as mode restraints but not tracked on a mode restraint list; ineffective implementation of corrective actions for previously identified mode restraint issues; and multiple departmental tracking systems for mode restraints. (Section 01.2) Inadequate Procedure / Instruction 117 2/13/1998 Positive IR 97025 NRC Plant 2A No deficiencies were noted during a lighting tour of the protected area.
Support (Section S2.1) Other/NA Page 19 of 37 l
PLANT ISSUES MATRIX
' /2/1998-Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date* ; Beginning Date = *10/30/1997*
Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 118 2/13/1998 Negative IR 97025 NRC Operations 2B Several discrepancies were noted during a walkdown of the attemate source of control room ventilation including: incorrect revisions of procedures, an uncontrolled vendor manual, and a lack of implementation of vendor recommended preventive maintenance items. (Section O2.1)
Inadequate Oversight 119 2/13/1998 Negative IR 97025 NRC Maintenance 28 Maintenance personnel did not effectively plan work activities for the initial 480VAC motor inspections in that work began on the Shutdown Sen/ ice Water (SSW) Fump Room A Supply Fan motor without having the appropriate parts on site, without having all parts approved through an accredited quality assurance program, and withcut having a method for greasing the motor bearings prior to installation. (Section M1.4)
Inadequate Oversight 120 2/13/1998 Negative IR 97025 NRC Operations 2B Implementation of Technical Specifications for SRM channel functional testing was poor in that operations rersonnel were unable to initially explain the basis which allowed transfer of the reactor mode switch from shutdown to run. Additionally, operations personnel did not document the applicable Special Operation Technical Specification which allowed the deviation from the requirements of Technical Specification 3.3.1.2 prior to >
manipulating the reactor mode switch. (Section O1.1.b.5) Personnel Performance Deficiency 121 2/13/1998 Positive IR 97025 NRC Maintenance 3A Maintenance personnel demonstrated good procedure usage during functional testing of the Division til 4.16 KV Bus under voltage relay in that -
they reviewed each step prior to performance, exhibited good independent verification techniques, were aware of the purpose of the surveillance test, and understood problems which could be encountered if the surveillance was not successfully completed. (Section M1.2)
Teamwork / Skill Level 122 2/13/1998 Negative IR 97025 NRC Operations 3A The failure to notice or provide a reason for the abnormally low cooling water inlet and outlet temperature indication associated with Residual Heat Removal (RHR) Heat Exchanger A following a transfer of shutdown cooling was an example of poor awareness of plant indications by operations personnel in the main control room. (Section O1.1.b.6)
Personnel Performance Deficiency 123 2/13/1998 Negative IR 97025 NRC Plant 3A One example of an individualincorrectly processing through a PCM-1B Support was identified. (Section R4.1) Personnel Performance Deficiency Page 20 of 37
PLANT ISSUES MATRIX
/2/1998,
Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Co;umn = *Date*. Beginning Data = *10/50/1997*, Endmg Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 124 2/13/1998 Weakness IR 97025 NRC Operations 38 Fourteen examples of the failure of operations personnel to implement the Technical Specifications since January 1996 were identified by NRC inspectors and/or the licensee. The multiple failures represent a -
weakness in the ability to implement the requirements of the Technical Specifications and a poor awareness of plant conditions which impact Technical Specification requirements. (Section O1.1.b.3) Personnel Performance Deficiency 125 2/13/1998 VIO!SL-IV IR 97025 NRC Operations 3B One violation was identified due to the failu6 to implement required Technical Specification actions to restore either the Division I or 11 inverter to service. Specifically, operations personnel failed to recognize that declaring all 480VAC motors inoperable required an entry into Technical Specification 3.8.8, " Inverters-Shutdown."
(Section 01.1.b.2) Personnel Performance Deficiency 126 2/13/1998 Negative IR 97025 NRC Operations 3B The decision to continue work even though three out of four source range monitors (SRMs) were exhibiting unexpected responses indicated a poor awareness of conditions with the potential to impact Technical Specifications, and was an example of a poor questioning attitude and oversight of maintenance activities by operations personnel. (Section O1.1.b.4)
Inadequate Oversight 127 2/13/1998 Positive IR 97025 NRC Operations 3B During the transfer of shutdown cooling from RHR Train B to RHR Train A, operations personnel appropriately referenced procedures, acknowledged annunciators, and performed the transfer without any significant complications. (Section 01.2) Teamwork / Skill Level 128 2/13/1998 VIO/SL-IV IR 97025 NRC Operations 3C One violation was identified due to the failure to implement required Technical Specification actions to restore isolation capability to secondary containment penetrations between October 18 and December 16.
Additionally, on-shift operations personnel were unfamiliar with how to implement licensing department guidance on acceptable administrative controls associated with Technical Specification 3.5.2.D.3.
(Section 01.1.b.1) Personnel Performance Deficiency Page 21 of 37
PLANT ISSUES MATRIX 12/2/1998-Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date*, Beginning Date = *10/30/1997*. Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES l DESCRIPTION 129 2/13/1998 NCV 1R 97025 NRC Maintenance 3C One example of a non-cited violation was identified for the failure to follow procedures involving the installation of an isolation transformer during testing of SRMs. Two examples of a poor questioning attitude were identified which involved the continuance of a maintenance activity even though there was an unexplained increase in test parameters and an unexplained increase in main control room SRM indications. (Section M1.5) Inadequate Oversight 130 2/13/1998 Positive IR 97025 Licensee Maintenance SA An audit conducted by quality assurance involving receipt inspections and shelf life determinations identified severai weaknesses in the material management program and represented a continued improvement in the quality assurance organization's ability to perform thorough evaluations.
(Section M7.1) Self-Critical 131 2/5/1998 Negative IR 97313 NRC Operations 3B Rigorous enforcement of motor operated valve test preparation switch use appeared to be lacking and needed improvement. (Section 05.4 132 2/5/1998 Weakness IR97313 NRC Operations 3B Examination developers failed to meet the guidelines of NUREG 1021 when developing the JPM examination outline. Validation of the JPM examination by facility personnel was weak. (Section OS.4.c) 133 2/5/1998 Negative IR 97313 NRC Operations 3B Individual communications practices of some of the applicants was poor and needed improvement. Applicants failed to comply v ith Emergency Operating Procedure (EOP) steps to initiate suppression pool cooling when required and used altemate injection systems when preferred injection systems were available. One applicant unnecessarily delayed execution of an EOP step resulting in unnecessary core uncoverage.
(Section 05.5) 034 2/5/1998 Positive IR 97313 NRC Operations 3B Training department personnel developed a written examination that proved to be a good evaluation tool for determining applicant competence. However, the examination showed a lack of attention to detali. Applicants were well p apared to take the written examination.
(Section 05.2)
Page 22 of 37
PLANT ISSUES MATRIX
*84 Clinton Search Sorted by Date (Devending) and sMM Codes (Ascending): Search Colurnn = *Date*, Beginning Date = *10/30/1997* ; Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 135 2/5/1996 NCV IR 97313 NRC Operations 3B Contrary to the requirements of 10 CFR 55.49, unauthorized people gained access to a copy of NUREG 1021, " Operator Ucensing Examination Standards for Power Reactors," Interim Revision 8, January 1
1997. Form ES-301-2. Individual Walk-Through Test Outline, listing the proposed examination Job Performance Measures (JPMs) by title. This resulted in a breach of examination security. Additional examples of examination security problems were noted. (Section 05.1) 136 2/5/1998 Misc IR 97313 NRC Operations 3B Two SRO license applicants passed all portions of their respective examinations and were issued SRO licenses. Two SRO license applicants failed portions of the examination and were denied operator licenses. Three SRO and two RO license applicants passed all portions of their respective examinations but were not issued operating li:enses.
Licenses will be issued upon completion of 10 CFR 55 required reactivity manipulations and all Clinton Power Station training program requirements.
137 2/5/1998 Positive IR 97313 NRC Operations 3B Control room operators were observed monitoring control room instrumentation at acceptable time intervals. Their demeanor was business like and professional during observed periods. (Section 01.1) 138 2/5/1998 Negative IR 97313 NRC Operations 3C 3B CPS No. 3213.01, Fire Detection and Protection, Rev.19, was inadequate in that it a!! owed emergency operation of the diesel fire pump with no jacket cooling water flow to cool the diesel. (Section O3.1) 139 2/2/1998 Negative IR 98002 NRC Plant 2B Radioactive material and waste shipping procedures were consistent with Support regulatory requirements. However, the inspectors identified some problems and inconsistencies within and between procedures indicating the need for additional review of procedures (Section R31' Inadequate Procedure / Instruction i
140 2/2/1998 NCV IR 98002 NRC Plant 28 The licensee maintained effective oversight of the respiratory protection Support program and implemented numerous program improvements. Required i
surveillances and maintenance were completed as required, and the equipment was in good working order. Personnel using the equipment were property trained, medically qualified, clean-shaven, and properly fit-tested. However, one non-cited violation was identified conceming the failure of plant security force members ano superviscrs to maintain their required respiratory protection qualifications (Section R1.1). Involved Management Page 23 of 37
PLANT ISSUES MATRIX 12/2/1998 Clinton Search Soned by Date (Descerding) and SMM Codes (Ascending): Search Column = *Date", Beginnir2 Date = *10/30n997*. Ending Data = *10/30n998*
DATE TYPE SOU..CE ID BY SALP SMM CODES DESCRIPTION 141 2/2/1998 Negative IR 98002 NRC Plant 2B The licensee properly packaged and classified radioactive material and Support waste shipments in accordance with regulatory requirements. However, the inspectors identified that procedures lacked guidance in determining the level of fixed contamination on material packaged and shipped under the surface contaminated object classification. The shipping documentation and low level waste manifests contained the information required by 49 CFR Part 172 and Appendix F of 10 CFR Part 20 (Section R1.4). Inadequate Procedure / Instruction 142 2/2/1998 Positive IR 98002 NRC Plant 3B Respiratory protection evaluations were sound and were consistent with Support NRC guidance. The RP staff properly evaluated radiological conditions to -
deten ne whether the use of respiratory protection would rnaintain the total effective dose equivalent as-to y-as-is-reasonably-achievable (ALARA) (Section R1.2).
Tean... ark / Skill Level 143 2/2/1998 Positive IR 98002 Licensee Plant 3B The RP staff properly determined the activity of radioactive waste Support shipments via scaling factors. The inspectors noted good evaluation of radionuclide data but identified one error in the interpretation of the vendor's radioanalytical results (Section R1.3). Teamwork / Skill Level 144 2/2/1998 Positive IR 98002 Licensee Plant 3C The licensee had identified problems concerning the control of work Support hours and overtime for RP personnel, which will be reviewed as part of the NRC 0350 Panel (Section R4.1). Other/NA 145 2/2/1998 Weakness IR 98002 NRC Plant cA The licensee had difficulty maintaining operability of the area and process Support radiation monitoring (AR/PR) equipment. Although the staff recognized the prob!em in October of 1997, late and/or missed surveillances had resulted in equipment operability problems with these monitors during 1997. With respect to the AR/PR remote monitoring console the i
inspectors concluded that (1) there was a lack of clear, reliable indication of AR/PR readings in the main control room; (2) frequent nuisance alarrns :
were distracting operators from their assigned duties and the monitoring of plant conditions; and (3) previous modification plans were unsuccessful because of various technical and licensing problems and uncertainties.
Although plant management had recently placed a high priority on the AR/PR system, the licensee's final plans to resolve thes6 problems remained uncertain (Section R2.1). Inadequate Oversight Page 24 of 37
PLANT ISSUES MATRIX 1 /2/1998 q Clinton r
S3 arch Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date', Beginning Date = *10/30/1997*, Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 146 2/2/1998 Positive IR 98002 Licensee Plant SA Audits of the radioactive waste management and shipping programs were '
Support of good depth. The audit team maintained a balance of performance-based and compliance-based observations and identified issues, which were being resolved by the RP staff (Section R7.1). Self-Critical 147 1/28/1998 NCV 1R 98006 Licensee Engineering 5B Engineering, operations, and work control pesonnel failed to appropnately implement the requirements of Technicai Specification 5.5.7, " Venti!ation Filter Testing Program." As a result, testing of the HEPA filter and the charcoal adsorber bed for the standby gas treatment system was not performed following painting in a ventilation zone which directly communicated with the standby gas treatment system.
148 1/23/1998 Negative IR 98006 Self-Operations 1C A design deficiency, material condition issues, and the failure d an Revealed operator to appropriately communicate plant conditions to the control room resulted in a loss of service air and a subsequent manual reactor scram.
149 1/23/1998 Positive IR 98006 NRC Operations SC The cperations department's root cause investigation for the reactor scram was thorough and identified several actions to improve equipment and operator performance. Although one of these actions was initially disapproved by the engineering work review board, operations personnel took the initiative to overtum the decision and to ensure that a long-standing operator work-around was appropriately resolved.
150 1/19/1998 LER LER 97036 Licensee Operations 2A The licensee's engineering staff determined that without the motor shaft key which connects the motor to the fan hub of the Division 11 shutdown service water pump room cooler, the Division 11 shutdown service water pump room cooler could not be considered operable. The inoperability of the room cooler causes the associated Division il shutdown service water pump to be inoperable. It is likely that the motor shaft key was not installed during initial manufacturing. Other/NA i
Page 25 of 37 l
PLANT ISSUES MATRIX 12/2/19 %
Clinten Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *Date*, Beginning Date = *10/30/1997*, Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 151 1/16/1998 LER LER 97033 Licensee Operations 1A The shift supervisor recognized that the Containment Building Fuel Transfer Pool Ventilation Plenum Exhaust Radiation Monitors, which have been inoperable since October 18,1997, impacted the status of some isolation dampers. These monitors isolate secondary containment and secondary containment bypass dampers on the detection of a high radiation condition. Administrative control was not in place to ensure isolation capability of these dampers. The cause of this event is due to a misinterpretation of techn.tcal Specifications, therefore the required actions for these monitors being inoperable were not taken. inadequate Oversight 152 1/16/1998 LER LER 97034 Licensee Engineering 4A During degraded voltage conditions, the Divisions 1 and 2 emergency diesel generator (EDG) room vent fans could cause offsite power supply breakers to trip on undervoltage during transient electrica; bus loading conditions associated with a Loss of Coolant Accident block start.
Improper cable resistance values and brake horsepower ratings were used in the original design of the Divisions 1 and 2 EDG vent fans.
Engineering / Design Deficiency 153 1/16/1998 LER LER 97035 Licensee Engineering 4A The Divisions 1 and 2 safety-related battery chargers had not been analyzed in the degraded voltage calculations. Further, the battery chargers may not be capable of supplying full rated voltage and current flow at the degraded voltage trip setpoint with the present battery charger transformer tap setting at 480 volts. Engineering / Design Deficiency 154 1/5/1998 Weakness 97 SET NRC Operations 1A 1C 4C The SET noted that several fire protection issues identified in 1995 had not been effectively addressed, including structural steel components with :
thermal shorts, inaccessible and inoperable fuel pool fire detectors, some fire barrier penetration seals not installed in the control room, and the potential for a single fire to cause loss of offsite power and loss of all diesel generators. The licensee had used an houriy fire watch in lieu of addressing identified prob; ems. This action is counter to NRC guidance in GL 91-18. "Information to Licensees Regarding NRC inspection Manual Section on Resolution of Degraded and Nonconforming Conditions," which discourages the use of compensatory measures instead of restoring equipment to full operability.
Page 26 of 37
PLANT ISSUES MATRIX 1 /2/1998 c Clinten Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *Date*, Beginning Date = *10/30/1997*, Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 155 1/5/1998 Weakness 97 SET NRC Maintenance 1C 2B 4A The effect of heat exchanger fouling on equipment operability was difficult to determine due to the inadequate implementation of Generic Letter 89-
- 13.
- Service Water System Problems Affecting Safety Related Equipment"(page 16 of the SET report).
156 1/5/1998 Strength 97 SET NRC Operations 1C 3B Fire brigade knowledge and performance were a program strength.
157 1/5/1998 Weakness 97 SET NRC All/ Multiple 1C 2B 4C Management did not ensure that the infrastructure was suitable to support major changes. The SET concluded that management did not recognize that the infrastructure at CPS was insufficient to support major changes.
As a result, management made organizational, programmatic, and resource decisions in the context of reengineering without appropriately considering the longer term and integrated effects of the decisions.
Management did not ensure that there were appropriate'f qualified staff, integrated programs and processes, and appropriate resources to support implementation of the reengineering and downsizing effort.
158 1/5/1998 Negative 97 SET NRC Operations 1C 4B The SET noted that the current number of fire protection staff was consistent with the industry standard. However, in 1995, the fire protection staff was assigned additional duties. One engineer responsible 7
for program implementation told the SET that only 20 percent of his time was available for fire protection activities. The SET also noted that during that period, there was a significant increase in the number of CRs related to fire protection and in the number of fire protection impairments. The t
SET concluded that the increased number of CRs and impairments occurred, in part, because the staff had insufficient time to devote to fire protection activities.
159 1/5/1998 Weakness 97 SET NRC Operations 1C 4C The SET noted that the licensee had extended surveillance for some fire protection systems beyond that previously approved by NRC or specified in NFCs. Monthly hose house inspections had been extended to an annual inspection. The SET noted mua dauber nests blocking the inside of fire hoses in each of two hose houses operied. Subsequently, the licensee identified a total of 11 ffre hoses blocked by med dauber nests.
The last inspection had been performed in June 1997. The licensee committed to revert to monthly hose house inspections.
t Page 27 of 37
PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date*, Beginning Data = *10/30/1997*, Ending Date = *10f30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 160 1/5/1998 Negative 97 SET NRC Operations 1C 4C The SET noted, in general, that fire detection systems appeared to comply with the National Fire Code (NFC). However, the service water pump rooms were observed to have an elevated ceiling and the fire detection system did not appear to comply with the current NFC for such a ceiling. Also, the licensee's individual plant extemal event examination (IPEEE) stated that credit was taken in three fire areas (two cable spreading rooms and the Division ill switchgear room) for automatic fire suppression allowing a reduction in core-damage frequency by a factor of 266. Although the licensee had evaluated and taken corrective actions for the sprinkler obstructions in the cable spreading rooms, the SET noted sianificant obstructions to sprinkler flow pattems in the Division 111 switchgear room.
161 1/5/1998 Weakness 97 SET NRC Operations iC 4C The licensee was unable to give the SET the requested test data to demonstrate that three randomly selected fire barrier penetration seals were installed in a configuration validated by a fire test. The licensee did not classify the fire barrier penetration seals as inoperable.
162 1/5/1998 Positive 97 SET NRC Operations 1C 4C The SET noted that the licensee, during plant licensing, had been granted numerous deviations from NRC fire protection guidance. Many of the deviations were, in part, based on having fire detection and suppression in a fire area. The SET observed that the licensee's staff was closely monitoring the performance of associated fire protection systems to ensure that extending maintenance and surveillance frequencies beyond the NFC did not affect system performance.
163 1/5/1998 Weakness 97 SET NRC All/ Multiple 2B 1A 3C CPS programs, processes, and procedures did not consistently provide defense in depth to assure plant activities were conducted in a safe manner. The SET concluded that programs, processes, and procedures failed to integrate activities across departments, incorporate industry information, and clearly delineate ownership and accountability. Program implementation was not effective in
, attaining the intended objectives. Processes and procedures were overly cumbersome and by failing to provide appropriate guidance unnecessarily challenged workers performing an activity. Programs and processes did not provide effective monitoring and feedback.
Page 28 of 37 1
PLANT ISSUES MATRIX
'2/2/in8.
Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Coturnn = "Date*, Beginning Data = *10/30/1997*, Erving Data = *10/30/1998*
l DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION j
164 1/5/1998 Weakness 97 SET NRC Operations SA 2A 1C Problem identification was inconsistent and evaluation and corrective actions were generally ineffective. The SET concluded that the inability to identify, evaluate, ant correct problems was a major impediment to improvement. Inconsistencies in problem identification resulted in failure to ensure that problems were effectively captured. Ineffective evaluation of identified problems contributed to failure to develop effective corrective actions. Failure to monitor and ensure implementation of CA plans contributed to recurring problems and an attitude of living with problems.
165 1/5/1998 Weakness 97 SET NRC All/ Multiple SA 3A 3C Management generally did not establish and implement effective performance standards. The SET concluded that the failure of IP and CPS management to establish and imp!ement effective performance standards was a root cause of the significant decline in safety performance. Management failed to establish and communicate appropriate, clea:ly defined expectations and priorities, and failed to morntor their implementation for the desired performance. Management decisions that were inconsistent with stated expectations contributed to declining performance. In addition, management did not give the staff sufficient feedback and failed to establish accountability.
166 1/2/1998 Positive IR 97024 NRC Plant 1C The security organization was knowledgeable of security requirements Support and implemented the physical security program in an effective manner.
Security management showed appropriate attention to detail and program ownership, which contributed to effective implementation of security requirements and reduction of security errors. Effective maintenance support activities contributed to the reliable performance of security equipment. (Section S6.1 and 2) Other/NA 167 1/2/1998 Negative IR 97024 Licensee Plant 3A A licensee-identified violation occurred when an in-processing employee Support improperly characterized a fitness for duty allegation as an anonymous allegation when it should have been characterized as a credible allegation. The actions of the employee were attributed to poor judgement when he was advised of the allegation. The significance of the failure was reduced because a fitness for duty test was administered.
(Section S1.1) Personnel Performance Deficiency r> age 29 of 37
PLANT ISSUES MATRIX
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Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *Date" : Beginning Date = *10/30/1997* ; Erdng Data = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 168 1/2/1998 Negative IR 97024 NRC Plant 38 The inspector identified a safety / security vulnerability regarding the Support untimely closing of an active vehicle barrier gate. The barrier was normally left in the open position after vehicle traffic passed through the barrier. Barrier effectiveness was reduced when the barrier was left in the open position. (Section S.2.1) Personnel Performance Deficiency 169 1/2/1998 LER LER 97032 Licensee Engineering 4A Plant Operations determined that protions of the High Pressure Core Spray (HPCS) pump suction piping, Reactor Core isolation Cooling (RCIC) pump suction piping, and RCIC tank level instrumentation standpipe, located outside of a missile protected building, were not designed to withstand missiles generated by a design basis tomado.
Engineering / Design Deficiency 170 12/23/1997 Weakness LER 97028 Licensee Engineering 4A The environmental qualification of the power shield trip units associated with all thirty-three inservice ABB 480-volt K-Line safety-related circuit breakers were not sufficient to withstand the expected dose rates following a worst case loss of cooling accident. Other/NA 171 12/22/1997 Weakness IR 97022 NRC Operations 1A One example of a violation of TS 3.0.2 was identified due to the failure to implement a TS Required Action. Specificatty, actions were not pursued to restore the Division I and 11 electrical subsystems to an operable status immediately on two separate occasions. Corrective actions for the first occasion were narrow in focus in that they failed to prevent recurrence (Section O8.1).
Other/NA 172 12/22/1997 Negative IR 97022 NRC Maintenance 1A Work control procedures for outages did not provide guidance on evaluating risk associated with the daily implementation cf the outage schedule. This item will be reviewed as part of the NRC 0350 Panel oversight of licensee improvement programs (Section O1.1).
inadequate Procedure / Instruction Page 30 of 37
PLANT ISSUES MATRIX 12/2/1998.
Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *Date*, Beginning Date = *1U30/1997" Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION l
173 12/22/1997 Negative IR 97022 NRC Operations 1A One example of a violation of Technical Specification (TS) 3.0.2 was identified due to the failure to implement a TS Required Action.
Specifically, between July 28 and October 26,1997, an attemate method of decay heat removal was not verified within one hour and every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter following the declaration of an inoperable train of residual heat removal. Consequently, component cooling water remained aligned to the "B" Reactor Water Cleanup Heat Exchanger even though the "A" Reactor Water Cleanup Heat Exchanger was being credited as the heat sink for the attemate decay heat removal source (Section 01.2).
Inadequate Oversight 174 12/22/1997 Negative IR 97022 NRC Operations 1A One example of nonconservative decision making was identified for not assessing the impact of shutdown risk due to reduced onsite electrical power availability. Specifically, the Division 11 Emergency Diesel Generator (EDG) was removed from service for maintenance while the Division i EDG was inoperable due to silting of the service water system (Section 01.1). Inadequate Oversight 175 12/22/1997 Positive IR 97022 NRC Plant 1B The shift supervisor's efforts to provide additional supervisory oversight Support during the exercise were prudent in that he recognized degrading command and control of activities in the simulator control room and inserted himself in the decision making processes (Section P1.1).
Other/NA 176 12/22/1997 Weakness IR 97022 NRC Plant 18 3B A number of problems were identified with operator performance during Support the off hours emergency exercise. Simulator main control room personnel failed to recognize a loss of all DC control power, did not attempt to restore the reactor core isolation cooling system, did not initiate the standby gas treatment system as required by the emergency operating procedures, did not effectively communicate priorities, and did not perform periodic site wide announcements (Section P1.1).
Personnel Performance Deficiency Page 31 of 37
PLANT ISSUES MATRIX 1 /2/1998 -
Clinton Search Sorted by Date (Descending) and SMM Codes (Ascerdng): Search Colurnn = *Date". Beginning Date = *10/30/1997* ; Erdng Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION l
177 12/22/1997 Weakness IR 97022 NRC Plant 1B 3B Performance in the technical support center du ing the off hours exercise Support was poor in that personnel did not recognize when minimum manning requirements were met, did not ensure priorities for restoration of plant equipment were communicated, did not ensure field teams were accounted for, did not update status boards with information regarding field teams and degraded equipment, did not adequately reference emergency operating procedures, and transmitted inaccurate information concerning system availability due to the use of inforrnal communications (Section P1.1).
Personnel Performance Deficiency 178 12/22/1997 Negative IR 97022 NRC Plant 1C During the dri!!, the shift supervisor / command authority did not consult Support with security personnel to determine if an altemate response location should be established for personnel in the emergency response organization. This was considered signilicant in that the effectiveness of the emergency response organization could have been significantly compromised during an actual security threat event (Section P1.1).
Personnel Performance Deficiency 179 12/22/1997 Weakness IR 97022 NRC Maintenance 2B One violation was identified due to the failure to provide maintenance work instructions for repairing safety related hydramotors as required by procedures. Additionally, the use of a MWR with broad instructions instead of a procedure with specific hydramotor repair and overhaul guidance was considered a weakness (Section M1.4). Inadequate Procedure / Instruction 180 12/22/1997 Positive IR 97022 NRC Operations 2B Improvements were made in sampling of the Diesel Fuel Oil System following the inspectors
- identification that the fuel oil day tanks were inspected for water after recirculating the day tank to the fuel oil storage tank (Section O2.1). Inadequate Procedure / Instruction L
181 12/22/1997 Negative IR 97022 NRC Maintenance 28 inconsistent guidance was provided in Procedure CPS 8170.06,
" Maintenance Troubleshooting." Section 2.1.2 stated that the procedure may be used as guidance when troubleshooting under a job stepped maintenance work request (MWR) while Section 1.0 stated that the procedure should not replace or be used in addition to a job stepped MWR (Secticn M1.3). Inadequate Procedure / Instruction Page 32 of 37
PLANT ISSUES MATRIX 1 /2/1998 ;
Clinten search sorted by Date (Descending) and SMM Codes (Ascerxsng): Search Column = *Date* ; Beginning Data = *10/30/1997*. Ending Data = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1C2 12/2"/1997 VIO/SL-IV 1R 97022 NRC Maintenance 28 One violation was identified due to the failure to provide controlled copies of vendor manuals and instructions for measuring and test equipment.
Operations personnel were not trained in the c:9 of portable tachometers i prior to using the tachometers in the field (Section lvi t.?).
Inadequate r
Procedure / Instruction 183 12/22/1997 Positive IR 97022 NRC Maintenance 3A 2B While problems were noted with the procedure for hydramotor work, it was considered a positive step that work was stopped on two occasions so that procedural instructions could be modified. Other/NA 184 12/22/1997 Negative IR 97022 NRC Operations 38 Training provided to operations personnel did not include all systems which are available to reduce containment pressure. Additionally, the emergency operating procedures did not include all systems which may be beneficial in reducing containment pressure. These omissions contributed to operations personnel in the simulator main control room not taking emergency operating procedure actions to reduce containment pressure using available plant systems (Section P1.1). Other/NA 185 12/22/1997 Negative IR 97022 NRC Operations 3C Operations personnel did not ensure that information needed to perform an operability determination for over-greasing of 480V motors was provided in a timely manner. This demonstrated a lack of plant ownership and leadership by the operations department and was indicative of a weakness in the operab!!ity determination program (Section M8.1).
inadequate Oversight 186 12/22/1997 Negative IR 97022 NRC Operations 4B The inspectors identified that the low level alarm setpoint for both the Division I and 111 fuel oil day tanks were incorrectly stated in the corresponding annunciator response procedures (Section O2.1).
Inadequate Procedure / Instruction 187 12/22/1997 Weakness IR 97022 NRC Maintenance SA The licensee's corrective actions in response to a previously identified motor over greasing issue were narrowly focused and untimely in that 1
multiple departments failed to recognize the potential generic implications of the over greasing issue until seven weeks after the initial concem was identified (Section M8.1). Other/NA i
188 12/22/1997 Licensing IR 97022 NRC Operations SA NRC invo!vement was required for licensing personnel to recognize a 10 CFR Part 50.73 reportable condition involving the failure to verify an attemate method of decay heat removal, an operation or condition prohibited by the plant's Technical Specifications (Section 01.2).
Other/NA Page 33 of 37
PLANT ISSUES MATRIX 12/2/1998 -
Clinton c
Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "Date", Beginning Data = *10/30/1997*
Ending Date = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 189 12/22/1997 Weakness IR 97022 NRC Plant 5A Licensee driti observers did not critically assess performance during tt'e Support off hours exercise in that several problems were either not recognized or were inappropriately classified as positive attributes by evaluators (Section P1.1). Personnel Performance Deficiency 190 12/22/1997 Positive IR 97022 NRC Engineering SA Although trending of equipment deficiencies was not actively performed in the past, the engineering department was taking action to identify adverse trends in equipment performance (Section E1.1). Other/NA 191 12/22/1997 Positive IR 97022 Licensee Operations SA 2B Quality assurance identified several weaknesses in the adequacy and implementation of the self assessment and maintenance rule programs.
The audits represen'ed an improvement in the quality assurance organization's ability to perform thorough and probing evaluations (Sections 07.1 and M7.1). Self-Critical 192 12/22/1997 Weakness IR 97022 NRC Operations SC Two weakness in the implementation of the corrective action program were identified. The weaknesses involved downgrading the significance of a condition report without supervisory review and operations, licensing, and corrective action review board personnel not being familiar with significance criteria associated with condition reports (Section O1.2).
Inadequate Oversight 193 12/17/1997 LER LER 9703C Ucensee Operations 1A On October 26,1997, the operations departrnent discovered that component cooling water (CCW) was not aligned to the "A* reactor water cleanup (RWCU) non-regenerative heat exchanger (NRHX). Technical Specification Limiting Condition for Operation (LCO) 3.4.10 required verification of an available attemate method of decay heat removal for each inoperable RHR shutdown cooling subsystem. The RWCU system was being credited as one of the alternate methods of decay heat removal, and because of the unknown CCW system alignment to the "A*
RWCU NRHX, the TS LCO action statement for verifying an attemate method of decay heat removal had not been met. Inadequate Procedure / Instruction Page 34 of 37
PLANT ISSUES MATRIX
' ' 'S8
- Clinton Search Sorted by Date (Descending) ard SMM Codes (Ascerxtng): Search Column = *Date* ; Beginning Date = *10/30/1997* ; Erxing Data = *10/30/1998*
DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 194 12/15/1997 Weakness LER 97031 Licensee Maintenance 28 Logic circuit overlap testing did not adequately cover portions of the logic circuitry as required by the Technical Specification (TS) Survei!!ance Requirement (SR) 3.3.6.4.7 for the Suppression Pool Makeup System Instrumentation, and TS SR 3.3.6.1.6 for the Primary Containment and DryweII isolation Instrumentation. Futher, overlap testing did not adequately cover a portion of the logic circuitry for the therman overload bypass circuit of motor-operated valves (MOV) 1SM001 A,1SM001B, 1SM002A, and 1SM002B, supression pool dump valves, to verify that TS SR 3.6.2.4.4 was met. Other/NA 195 12/15/1997 LER LER 97029 Licensee Operations 3A A scaffold was found partially supported by the Low Pressure Core Spray room area cooler,1VYO1S The effect that this scaffold had on the room cooler could not be positively determined; therefore, the room cooler was detemiined to be inoperable due to seismic qualification concems.
Personnel Performance Deficiency 196 12/5/1997 LER LER 97023 Licensee Maintenance 2B lt was determined that all safety related motors that contain bearings requiring the periodic addition of grease may potentially fail. The possible premature failure of the motors is due to the use of an incorrect method for adding grease to safety-related motor l' earings. Other/NA 197 12/4/1997 LER LER 97027 Licensee Engineering 4B On August 31,1990, maintenance completed installation of the first portion of a modification to add interlocks to the residual heat removal (RHR) system. In October,1997, furthw review determined that the addition of a relay to two of the RHR loops increased the probability for an equipment malfunction which would affect the ability of the plant to use the suppression pool cooling mode of operation. Therefore, addition of this relay resulted in an unreviewed safety question. The cause of this event was a misinterpretation of 10 CFR 50.59. Engineering / Design Deficiency 198 11/13/1997 LER LER 97026 Licensee Operations SA Plant engineers identified that the level of silt in the area of the shutdown service water system (SX) pump intake area exceeded the level required to ensure the operability of the Division I and 11 SX pumps. Other/NA 199 11/7/1997 Strength IR 97023 NRC Operations 3B All portions of the annual requalification examination were judged to be effective tools for determining operator weaknesses (Section 05.2).
200 11/7/1997 Positive IR 97023 NRC Operations 3B Licensee controls to r-a e the licensed operator requalification training program were satis' d / (Section 05.4).
Page 35 of 37
PLANT ISSUES MATRIX
/2/1998 Clintnn Searen Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *Date* ; Beginning Date = *10/30/1997*, Endng Date = *10/30/1998*
I DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 201 11/7/1997 Negative IR 97023 NRC Operations 3B The development of remediation plans lacked a compreWive root cause analysis for individual performance (Section 05.5).
202 11/7/1997 Positive IR 97023 NRC Operations 3B Licensed operator requalification programs were implemented in accordance with 10 CFR Part 55 requirements (Sections 05.3 and 05.6).
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GENERAL DESCRIPTION OF PIM TABLE LACELS a
A counter number used for NRC intemal editing.
The date of the event or significant issue. For those stems that have a clear date of occurrence use the actual date. If the actual date is not known, use the date DATE the issue was identified. For issues that do not have an actual date or a date of identification, use the LER or inspection report date.
TYPE The categorization of the issue - see the TYPE ITEM CODE table.
SOURCE The document that contains the issue informatiort IR for NRC inspection Report or LER for Licensee Event Report.
IDC.Y Identification of who discovered the issue - see table.
SALP SALP Functional Area Codes - Engineering, Maintenance. Operations, Plant Support and All/ Multiple (i.e., more than one SALP area affected).
SMM CODES Senior Manager Meeting Codes - see table.
DESCRIPTION Detoils of the issue from the LER text or from the IR Executive Summaries.
TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements
- Eels are apparent violations of NRC 1
Operational Performance:
ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal EEI*
Escalated Enforcement Issue - Waiting Final NRC Action escalated enforcement action in accordance B - During Transients e ene emen f and C-Programs and Wocesses LER License Event Report to the NRC Procedure for NRC Enforcement Action Licensing Licensing issue from NRR (Enforcement Policy). NUREG-1600.
2 Material Conditiort Misc Miscellaneous (Emergency Preparedness Finding, etc.)
However, the NRC has not reached its final A - Equipment Ccndition NCV Non-Cated Violation enforcement decision on the issues 8 - Programs and Processes Negative individual Poor Licensee Performance identified by the Eels and the PIM entries 3
Human Performance:
Positive Individual Good Licensee Performance may be modified when Qe final decisions A - Work Performance are made. Befom the NRC makes its Strength Overall Strong Licensee Performance B - Knowledge, Ski!!s, and Abilities enforcement decision, the licensee wt!! be C - Work Environment URt**
Unresolved inspection item provided with an opportunity to either VIOISL-l Notice of Violation - Severity Level I (1) respond to the apparent violation or 4
Engineering / Design:
VIO/SL-t!
Notice of Vio!ation - Severity Level !!
(2) request a predecisional enforcement A - Design VIOfSL-III Notice of Violation - Seventy Level lit conference.
B - Engineering Support VIO/SL-IV Notice of Violation - Seventy Level IV
- URis are unresolved items about which C - Programs and Processes o onna s
u ese Weakness Overall Weak Licensee Performance g g 5
Problem Identification and Resolution:
accepiable item, a deviation, a A - Identification ID BY nonconformance, or a violation. However, B-AnaWis the NRC has not reached its final C - Resolution Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed identifcation by an event (e.g., equipment breakdown) conclusions are made.
Other
-Identification unknown Page 37 of 37
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