ML20205G547

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Advises of Completion of Plant Performance Review on 990202 to Develop Integrated Understanding of Safety Performance. Three Areas of Concern Are Operator Performance,Cap Implementation & Resolution of Engineering Design Issues
ML20205G547
Person / Time
Site: Clinton Constellation icon.png
Issue date: 03/26/1999
From: Grant G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Mcelwain J
ILLINOIS POWER CO.
References
AL-98-07, AL-98-7, NUDOCS 9904070286
Download: ML20205G547 (68)


Text

,

.jd"hg UNITED STATES '

  1. tg - NUCLEAR REGULATORY COMMISSION

[ o REGloN lil

! y E 801 WARRENVILLE ROAD

- t lisle, ILLINots 60532-4351

\ ***

/ March 26, 1999 1

Mr. John P. McElwain Chief Nuclear Officer Clinton Power Station Illinois Power Company Mail Code'V-275 P. O. Box 678 Clinton,IL 61727

SUBJECT:

PLANT PERFORMANCE REVIEW - CLINTON

Dear Mr. McElwain:

On February 2,1999, the NRC staff completed a Plant Performance Review (PPR) of Clinton Power Station. The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance. The results are used by NRC management to facilitate planning and allocation of inspection resources. Plant Performance Reviews provide NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting reviews. Plant Performance Reviews )

. examine information since the last assessment of licensee performance to evaluate long-term trends, but emphasize the last 6 months to ensure that the assessments reflect current performance. The PPR for Clinton involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period April 6,1997, to January 31,1999. The NRC's most recent summary of licensee performance was provided in a letter of June 23,1997, and was discussed in a public meeting with Illinois Power Company on July 2,1997.

As discussed in the NRC's Administrative Letter 98-07 of October 2,1998, the PPR provides an assessrnent of licensee performance during an interim period that the NRC has suspended its Systematic Assessment of Licensee Performance (SALP) program. The NRC suspended its  !

SALP program to complete a review of its processes for assessing performance at nuclear power plants. At the end of the review period, the NRC will decide whether to resume the SALP program or terminate it in favor of an improved process.

Clinton Power Station remained shut down throughout this assessment period while work was being performed to address the restart items in the NRC Manual Chapter 0350 Restart Panel l Case Specific Checklist and in your recovery plan, the Plan for Excellence. Steady progress I has been made to address these items; however, a recurring theme for many of the closure packages for the restart items presented to the NRC for review was that comprehensive plans -;

to address the items were developed but not all aspects of the plans had been sufficiently /

implemented to warrant closure of the items. Some items, most notably the development of a program to reduce main control room deficiencies, have been reviewed several times but were not ready to be closed. The result of this has been the deferral of the remaining items to the l last three NRC team inspections scheduled prior to restart. it is likely that some follow up I i

9904070286 990326 PDR 0 ADOCK 05000461 PDR i

l 1

l J. McElwain  !

inspection will be necessary after the three team inspections to ensure all restart items have been resolved.

1 The three areas of most concern with the performance at Clinton are operator performance, corrective action program implementation, and the resolution of engineering design issues.

Corrective actions to address weaknesses in operator performance were not successful in preventing or reducing the number of operations department challenges, the most problematic of which involved Technical Specification implementation, the operator requalification program, i and the implementation of emergency operating procedures. Multiple assessments'of the corrective action program have been performed by your organization and the NRC witr, l essentially the same conclusions: (1) management has not provided sufficient oversight; and (2) management is not adequately engaged in the corrective action process. In general, more j effort has been focused on the more significant conditions adverse to quality and, as a result,  !

the effective resolution of these items occurs more often than the effective resolution of lower l level items. However, several significant conditions adverse to quality have recurred over the past 6 months. The main engineering design issues include the resolution of the degraded  !

voltage problem, and the adequacy of the calculation and setpoint control processes.

Performance in plant operations remained consistent. Whib there has been some improvement it, certain areas of plant operations, overail performance has been characterized by more repetitiva issues than resolved issues. Operate,rs have improved in recognizing new degraded conditions, shift turnovers have been signifcantly improved, and performance in the tagout program has been characterized by a reduction in the amount of significant errors.

However, poor performance during the annual operating test indicated that crew members had failed to retain mastery of needed operator skills. In addition, recurring issues such as the failure to document compensatory actions for disabled annunciators, unfamiliarity with existing control room deficiencies, Technical Specification compliance problems, emergency operating procedures implementation problems during drills, and poor self-assessments indicate that much improvement is necessary in the operations area. In addition to normal core inspections, initiative inspections will be conducted to review operator readiness to startup and operate the plant, to continuously observe plant startup activities, and to review the routine conduct of operations following plant restart.

Performance in the maintenance area declined early in this assessment period from that described in the previous SALP report, but improved as the period progressed. Early in this period, both programmatic and human performance deficiencies existed in the maintenance functional area. For example, the molded case circuit breaker testing program was inadequate, troubleshooting activities were of ten conducted without properly adhering to procedures, and the scheduling and completion of surveillances was ineffective. In addition, the maintenance rule program was not adequately implemented. Improvement has been noted in all of these areas during the past several months. The adequacy of and adherence to procedures and the scheduling and completion of surveillance tasks has significantly improved. Also, the quality of condition report reviews has improved, a maintenance ruto program has been established, 4,160 V circuit breaker issues have essentially been resolved, and a new molded case circuit breaker testing program has been implemented. However, the failure to update the status of the main control room deficiency log and tags as the deficiencies were resolved is indicative of

g .~ - - , , , - - , - . .- .. .-.----._----

t J. McElwain -  !

the need to improve support to the operations department.ln addition to normal core y . inspections, the resident inspectors will perform initiative inspections to review maintenance -

! planning and implementation as the work item backlog is reduced in addition, an initiative i l inspection will be conducted to review the collective significance from a risk perspective of your ,

l maintenance item backlog.  :

Overall, engineering department performance has improved especially with regard to issue  ;

identification.- Reviews and assessments of selected systems' design bases have identified multiple examples of engineering deficiencies. In particular, the system design and functional l validation review and the fire protection re-validation project were comprehensive and effective l in identifying programmatic issues. The content of current licensee event reports suggests a 1 l lowered threshold for identification of engineering design issues and an increased engineering staff understanding of the design basis. However, the NRC determined that a significant amount of work associated with corrective actions developed to address the deficiencies identified during the engineering assessments needed to be completed prior to plant restart.

Several examples of inadequate engineering support to the operations department were also i noted. In addition to normal core inspections, the resident inspectors will perform initiative

. inspections to review modification packages and the effectiveness of the corrective actions implemented to address programmatic deficiencies.

Radiation protection and chemistry department performance improved during the assessment period, improvements in radiological planning and communications were observed during the replacement of emergency core cooling system strainers. In addition, the chemistry staff's -

adherence to sampling and quality control procedures was improved. However, personnel performance problems and program implementation issues continued to be observed, particularly early in the assessment period, t

Emergency preparedness (EP) performance declined as numerous problems were identified in the program related to drills, exercises, and other program activities. Emergency facilities, equipment, and supplies were maintained in an adequate state of readiness but the material condition of these areas was in need of improvement. The EP performance during an actual loss of shutdown cooling event in February 1998 was mixed. Provisions for staffing the on-shift emergency organization and for augmenting it were flawed. Self-assessment of EP performance was inconsistent. During the Novemoer 1998 exercise, overall performance was adequate; however, significant performance concerns were identified regarding the operating crew and responders in the Technical Support Center, Operations Support Center, and Emergency Operations Facility. In addition to normal core inspections, initiative inspections will be performed to review EP exercise performance and other aspects of plant support performance.

The NRC Manual Chapter 0350 Oversight Panel for the Clinton station continues to hold frequent public meetings with licensee management to assess progress on corrective actions necessary for safe plant restart. During the extended shutdown, core resident inspections at the Clinton station are conducted as delineated in NRC Manual Chapter 2515 and regional initiative inspections are conducted under the direction of the Oversight Panel focusing on the Case Specific Checklist items required for restart.

l

J. McElwain  !

l l Enclosure 1 contains a historicallisting of plant issues, referred to as the Plant issues Matrix (PIM), that were considered during this PPR process to arrive at an integrated view of licensee performance trends. The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and Illinois Power Company. The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately. Rather, the NRC only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance. Ir. addition, the PPR i may also have considered some predecisional and draft material that does not appear in the I attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.

This material will be placed in the Public Document Room as part of the normalissuance of NRC inspection reports and other correspondence.

This letter advises you of our planned inspection effort resulting from the Clinton PPR review. It is provided to minimize the resource impact on your. staff and to aflow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Enclosure 2 details our inspection plan for the next 6 months. The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas. Resident inspections are not listed due to their ongoing and continuous nature.

We willinform you of any changes to the inspection plan. If you have any questions, please contact Tom Kozak at 630-829-9866.

Sincerely,

/s/ G. E. Grant Geoffrey E. Grant, Director Division of Reactor Projects Docket No. 50-461 License No. NPF-62

Enclosures:

1. Plant Issues Matrix
2. Inspection Plan See Attached Distribution DOCUMENT NAME: G:\ CLIN \lNSPPLN8.CLI
  • See previous concurrences To receive a copy of this document, indicate in the box: 'C' = Copy w/o attach /enci "E" = Copy w/ attach /enci "N' = No copy OFFICE *Rlli:DRP E
  • Rill:DRP lE Rill:DRP l l NAME DuPont/dp//kic Kozak Grant Gb/

DATE 03/25/99 03/25/99 03/$/9s V OFFICIAL RECORD COPY

b.'

I l .'

'J. McElwain l This material will be placed in the Public Document Room as part of the normal issuance of .

NRC inspection reports and other correspondence.

t'

.This letter advises you of our planned inspection effort resulting from the Clinton PPR review. It-

is provided to minimize the resource impact on your staff and to allow for scheduling conflicts

' and personnel availability to be resolved in advance of inspector arrival onsite. Enclosure 2 .

details our inspection plan for the next 6 months. The rationale or basis for each inspection -

outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas. Resident inspections are not listed due to their ongoing and continuous nature.

- We will inform you of any changes to the inspection plan. If you have any questions, please

' contact Tom Kozak at 630-829-9866.

Sincerely, i l

1 l l' l

i Marc L. Dapas, Deputy Director, Division of Reactor Projects 4

Docket No.: 50-461 ]

~

License No.: NPF-62

Enclosures:

1. Plant issues Matrix
2. Inspection Plan ,

Docket No.: 50-461 License No.: NPF-62 See Attached Distribution DOCUMENT NAME: G:\ Clin \lnsppin8.cli To receive a copy of this docurnent,Indicete in the boa *C" = Copy without ettechmentlenclosure "E" = Copy with attachment /enclosurc

  • N' = No copy OFFICE Rlli ' [(, Rlll 6 Rlli NAME DuPonth dqpr Dapas DATE 02/d/99 02/yJ/99 02/ /99 OFFICIAL RECORD COPY

.- . --- ~. - .. - .. - --. -. . . .. .

J. McElwain i

' -l 1

cc w/encls: G; Hunger, Station Manager i R. Phares, Manager, Nuclear Safety

. and Performance Improvement

, J. Sipek, Director - Licensing 4

M. Aguilar, Assistant Attorney General G. Stramback, Regulatory Licensing Services Project Manager General Electric Company i Chairman, DeWitt County Board State Liaison Officer Chairman, Illinois Commerce Commission

~

M. Reidy, Clinton Police Chief j The Honorable Tom Edmunds

- The Honorable Ken Schaub

! R. Schumaker, DeWitt County Board Chairman R. Massey, DeWitt County Sheriff i

. M. Strain, DeWitt County Emergency i L Preparedness Coordinator The Honorable Thomas Brame G. C. Riss, McLean County Board Chairman 4

S. Brienan, McLean County Sheriff J. Wahls, Director, McLean County Emergency Services and Disaster Agency  !

R. Scheffer, Piatt County Board Chairman

, . F. Sawlaw, Piatt County Sheriff C. E. Morris, Emergency Services i Disaster Coordin'ator l R. Owen, Macon County Board Chairman 1 R. Walker, Macon County Sheriff D. Sanner, Emergency Services Coordinator INPO l

i 5

i 4

h J. McElwain 2 1' 8

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~ Distribution.

! - RPC (E-Mail) .

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, G. Tracy, OEDO w/encls : j t . Chief, NRR/ DISP /PIPB w/encls "

. T. Boyce, NRR w/encls j

Project Director, NRR w/encls 1 I Project Mgr., NRR 'wlencls I

~J. Caldwell, Rlli w/encls 3

B. Clayton, Rill w/encls .

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R. Lickus, Rlll w/encls i SRI Clinton w/encls

. DRP w/encis DRS (2) w!encls i Rlli PRR w/encls l l- PUBLIC IE-01 w/encls ~  !

j- Docket File w/encls i 1 GREENS i

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Pogs: 1 of 16 Dole: 03/26/1999 Unitad Stat s Nuclear R gulatory Comm. .ission nme: meo negion m PLANT ISSUE MATRIX I

CUNTON By Primary Functional Area Functional Template Octe Source Area ID Type Codes item Description i 02/16/1 W I M 002 Prh OPS NRC NEG Pri: 18 The inspectors determined that operations personnel did not meet the guidance in NRC Emergency Preporedness and Rodiotion Protection Branch Position (EPPOS) No. 2. ' Timeliness of Classification of Sec- Sec.

~ ~

Emergency Conditions." for declaration of the January 6.1999. NOUE. Specifico!!y operatioris personnel Ten dectored the NOUE 26 minutes citer the initiotion of the LOOP even though the guidance in NRC EFPOS No.

2 specified that event dectoration should occur within 15 minutet Additionolty, expectotions for the timeliness in doctoring emergency action levels in resconse to events were not specified in procedures for preparing and conducting emergency exercises 02/16/1 M I M 002 Prt OPS NRC NEG Prt 1C The inspectors determined that in most cases, the onnunciator response procedures did not reference the Technical Specifications ossociated with the clarming condtion See: Sec:

t Ter:

02/16/1000 1 M 002 Prt OPS NRC NEG Pri: 5A The inspectors determined that the licensee's critique of the LOOP event was not sufficiently critical to g *. 3 , *.

ident:fy issues involving operator knowledge weaknesses. procedure discreponcies, timeliness of event ,

dec oration, and delays in the shift turnover process. Following discussions with the inspectors, the licensee t Tet initiated on event review team and conducted on effective ossessment of the issues and concerns to identify issues involving operoror knowledge weaknesses, procedure discrepancies, timeliness of event dectoration. and delays in the shift turnover process.

02/16/1000 1 M 002 Prt OPS NRC NEG Pri: 58 The insoectors determined that the licensee's review of procedures to support Closure of Cose Specific Checklist (CSC) Restort item IL3. " Review and Revise Abnormal Opero+ ions Sections of Operations Sec- ' Sec.

  • Procedures
  • was ineffective in that the ossessment did not determine that opproximately 244 procedure -

Tec changes associated with 113 operations procedures involved technicalissues which needed to be oddressed prior to restort or prior to the next time the procedure was used 02/16/1000 1WCO2 Pri' OPS NRC POS Prt IB The inspectors determined that operations personnel responded oppropriately to o loss of offsite power (1OOP) involving o Notice of Unusual Event (NOUE) decloration in that procedures were used in-hand, peer Sec" W'~.

checks were frequently Conducted. three-way communication techniques were good, and cff-shift Ten personnel were effectively utilized without becoming a distraction to the operating crew 02/16/1000 1 N 002 Prt OPS NRC WK Prt 3B The inspectors identified operator knowledge weaknesses regarding the intertocks ossociated with the 4160V vital bus feeder breakers 3 3 Ter:

02/16/1000 1M002 01 Prt OPS NRC NCV Prt 1C The inspectors identified one Non-Cited Violation for the failure to translate design requirements into annunciotor response procedures. Specifico!!y. the design requirements for the operation of the 4160V 1 A1 Sec** Sec. '

main and reserve feeder breakers following a trip of the emergency diesel generator was incorrectly Tec translated into Procedure 5060 01. "Alorm Panel 5060 Annunciators - Row 1" 02/16/1 M 1000022-02 Prt OPS Ucensee NCV Prt 3A The insDectors Concluded that the licensee did not log EDG storts or formofly track lightly-loaded run times for each EDG. which could result in the licensee foiling to take necessory actions to ensure EDG reliability. One Sec Sec,'

Non-Clied Violation was identified conceming this issue Ten tier, Type (Cempliance.Other). From 08/18/1998 To 03'26/1999

. _ ~ _ .

Pogs: 2of16' Date: 03/26/1999 .

Unit;d Statas Nucloor Rcgulatory Comm. .ission Time: um neg!on ill - PLANT ISSUE MATRIX CUNTON By Primary Functional Area Functional Template Date Source Area ID Type Codes item Description 01/06/1999 19CS020 Prt OPS NRC NEG Pri: IC The inspectors concluded that weaknesses in the implementation of the operability determination progrom 3,c.

still ex5ted in that operations personnel had not conducted eight safety evoluotions for long standing 3,e',

use-os-is nonconforming conditions. In addition, three maintenance activities ossociated with operobility Tec determinations had not been scheduled for completion prior to restort of the facility 01/06/1999 19CS020 Pri: OPS NRC NEG PrtIC The inspectors concluded that interviewed operators were not aware of the overon status of deficient control room equipment and OWAs Sec: See:3B Tec 01/06/10W 1996020-01 Pri: OPS NRC NCV Prt SC The inspectors identified one viclotion for which enforcement discretion was exercised, concerning the 3,q.

failure of control room operators to enter nonconforming conditions into the Heensee's corrective action 3 ,c.*

  • program. Specifically, operations personnel documented four nonconforming conditions in the MCR Journd Tec but did not init!cte o condition report. The issues involved on unanticipated loss of fill and vont on the residual heat removal system o human performance error during maintenance on a station air compressor, a maintenance rule functional failure offecting the Division I switchgear heat removal unit. ond three unplanned entries into o limiting condition for operation 01/06/1909 19CS02042 Pri: OPS NRC NCV Prt IC The inspectors identified one violation. for which enforCC nent discretion was exercised. that involved the ure of p ms personnel to onnotote a late entry in the MCR journal and the repeated failure to Sec-' Sec.'

document the completion of shiftty compensofory octions Ter-11/20/19 % 1WSD27 Prt OPS NRC NEG Pri: 1C Deficiencies in emergency operating procedure (EOP) implementation were identified. Specificolly, operations personnel failed to stort the hydrogen - oxygen monitors until 40 minutes offer entering the EOP.

~ec' t Sec.'

In additiort operations personnet did not determine whether o valid entry condition into EOP-9 Tec *podiocctivity Reicose Control." existed. Similar concerns were o!so identified during on emergency precoredness drill performed in October 1998.

11/17/1993 1076018 Prt C " NRC NEG Pri: SC The inspectors and the licensee identified multiple examples of ineffective corrective action program implementation for level 3 and 4 condition reports. Specific issues involved ineffective management 3 3 .

  • oversight, poor opporent couse onolysis. inadequote extent of condition determinations, and ineffective Tec corrective actions for identified opporent causes.

11/17/1993 19CS018 Pri: OPS NRC POS Prt 1B The licensee conducted effective post event ossessments for a loss of Division I electrical power, sequential pe no e g cy resaw oudmy #cnsfoWo@cp c%m. W momment of a rodwoste Sec'- Sec: SB liner. The ossessments were timely and identified the causes ossociated with the events.

Tec 11/17/199S 10C8018 Prt OPS NRC POS PrtIC The new operations department shift turnover process. Implemented in August 1998, was on improvement from the previous me+ hod used for turnovers in that personnel used clear communications, operators osked ,

Sec'- Sec.*

clarifying questions. ond the fu!I operations crew porticipated in the briefing.

Tec Item Type (Compliance,O:her). From 08/18/1998 To 03/26/1999

Pogs: 3 of 16 Dole: 03/26/1999 9 United Statss Nucisor Ragulatory Comm. .ission Tim. m a oo negion m PLANT ISSUE MATRIX ,

CllNTON By Primary Functional Area ]

Functional Template Dote Source Area ID Type Cooes item Description  !

11/17/199S IWS018-01 Prt OPS NRC NCV Prt SB The inspectors identified one violation for which enforcement discretion was exercised. for the failure to conduct a hozords ono!ysis os port of the safety evoluotion for o temporary modification used to support Sec'- Sec.'

Division I emergency core cooling system (ECCS) testing. Specifico!!y, the safety evoluotion did not address I Tet the possible effects of temporarily instoDed cables routed in the vicinity of safety-related equipment that was !

not being tested as part of the ECCS testing activities  !

11/17/lWS 1905018-02 Prt OPS NRC NCV Pri: 1C The inspectors identified one non-cited violation which involved the foilure to odhere to procedures that i Sec, limit staff working hours. One chemistry technicion worked in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in o 48-hour period, one ,

Sec*- instrumentation technicion worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period. ond operations personnel foiled to j i

Tec conduct a monthly review of overtime use for June 1996. Recent efforts to improve monogement oversight of the program have been successfulin limiting stoff working hours 10/01/1? 3 iWS017 Prt OPS NRC NEG Prt 1C The inspectors identified that the implementotion and maintenance of the operator old program did not  :

Sec,*

meet monogement expectations in that: differences existed between two controlling procedures for Sec-'

operator cids. a lock of in-depth knowledge of the operator cid program by operoflons personnel  ;

Tet contnbuted to inconsistent implementation of the pr v;mm, and quarterly reviews of the operator old log performed by operations personnel were not effective in identifying operator cids which had been in existence for extended periods.

10/01/1WS 1WS017 Prt OPS NRC NEG Prt 5A The licensee and the inspectors identified that tracking of compensatory octions for out-of-service or disabled annunciators was inconsistent in that 12 compensofory actions were listed in the out-of-service Sec'- Sec,~

onnunciator log but were not included in the operations turnover checklist and 4 compensatory actions Tet which had been cleared from the out-of service annunciator log remained on the turnover sheet.

t 10/01/10C5 1WSGI7 Prt OPS NRC NEG Pri: SB Between May 1 ond September 1.1998. at least 15 examples of poor implementation and use of the Sm,

. Technical Specifications were identified by the licensee and the inspectors. This is of concern because ec,.

corrective actions implemented prior to May 1.1998. have not been fully successful in improvirvi Tet implementation and use of the Technical Specifications ,

i 10/01/1003 19C8017 Pri: OPS NRC NEG Prt 5B The inspectors noted mixed performance with regard to the awareness of plant conditions by operations personnel. On one occasion. operations personnel did not understond the reasons for on abnormal +

Sec- Sec.-

shutdown service water indication. However, on two occasions, operations personnel oppropriately Ten dispositioned deficiencies involving. the rod control and informo+ ion system ond. the high pressure core sproy pump breaker.

10/01/1MS 1CCS017 Pri: OPS NRC NEG Pri: SC The inspectors identified a fciture to implement corrective actions to prevent a recurrence in the untimely performance of safety screenings and evoluotions for disobled or out-of-service annunclotors. As o result of Se ~- Sec- '

the untimely performance, 13 of 27 out-of-service or disobleo annunclotors had not been evolucied to Ten determine if the degraded conditions constituted defocto changes to the focliity as described in the Updated Sofety Ano!ysis Report ,

Prt 5A The inspectors noted that operations monogement oppropriotely recognize d the need for odditional i 10/01/1993 190S017 Pri: OPS NRC POS w reness of and focus on equipment safety togging problems by suspendag operating crew activities In  ;

Sec' See: SC order to conduct a safety briefing in response to recent safety togging events invoMng temporary lifting of Ter: togs. [

Mem Type (Compliance.Other). From 08/18/1998 To 03/26/1999 r

Fogs: 4 of 16 Date: G3/26/1999 United Statas Nucisar Regulatory Comm. .ission Tim.: unoo Region iti PLANT ISSUE MATRIX CUNTON By Prir:1ory Functional Area Functiono! Template .

Date Source Area ID Type Codes item Description  !

10/01/1903 190901701 Prt OPS NRC VIOIV Pri: IC The inspectors identified one violation which involved the failure of the creo rodlotion monitor technicion to announce annunciotor alorms to the control room supervisor. The inspectors determhed that this was o routine practice for certoin clorms rather than o one-time occurrence. Corrective actions implemented by Tet the licensee were sufficient to resolve the issue .

09/21/10C3 10CS301 Prt OPS NRC NEG Pri IC The originct retake exomination materiot foiled to meet oil of the guide!!nes in NUREG-1021 for developing Se,. the job performance measures examination. Additiono! cttention was necessory to correct errors i Sec- **

concerning prescripted question content and difficulty level '

Tet OC/21/lWS 1WS301 Prt OPS NRC NEG Prt 1C The opplicant oppeared to be poor!y prepored on Technicot Specification knowledge items. and gg. 3,g.

demonstrated unfomiliarity with plant equipment locotion and operation.  !

Tet 09/21/199S 10C3301 Prt OPS NRC POS Prt 1A Operators on shift executed their duties in a professional manner and in occordance with station procedures and monogement expectotions. r Ten CC/21/19CS 10C8301 Pri: OPS NRC POS Prt 10 Implementation of the licensed opercror continuing training program invoiving scheduling and developing Sec, operating examinations according to program guidelines was chorocterized by a safety significont focus.

Sec-* '

implementation of the licensed operator continuing training progrom involving the evoluotion of operator ,

Ten pe formance in accordance with program guidelines was adequate. However, the proctice of evoluoting ,

one or more troining objectives in mu!tiple settings reduced the comprehensive effectiveness of the operating test ond placed the examinees in o double jeopardy situation.

OC/21/10CS 1908301 Prt OPS NRC WK Pri: IC Licensed operator performance during the annual operating test had declined such that it was opporent that the crew members had failed to retoin mostery of needed operator ski!!s. The facility's evoluotors ec,. Sm 3B recognized unsatisfactcry crew and individual performances and implemented steps to document ne Tet performance and prevent the crew from ossuming control room watch standing responsibilities until properly ,

remedicted. i t

08/18/19C3 1CCSON Prt OPS NRC NEG Prt IC The operations department self-assessment progrom. between January and July 1998. did not have o stable [

Sec.'

pr grom owner i ossee compMm of setosseses, weomesses NMed h operatonodh wod '

Sec- '

practices were not addressed. ond recommendations and weaknesses described in the radiction worker  !

Ten proctice and quartertv ossessment reports were not trocked or assigned o responsible owner.

1 08/18/19 S 19CSCM Prk OPS NRC NEG Prt 3B Operations personnel implemented nonconservative compensatory measures for a potential fouit condition Sec-' Sec: 5B cMg MusW Ms Sp4m Nedm WegW Wet Spedcoy, opms pemi l viewed dectoring a faulted component odministratively inoperable os on odequote compensofory measure "

Tet even though teoving the faulted NSPS inverter energized could potentiolty introduce complications with the power supply . ,

t I

tiem Type (Ccmphance.Other). From 08/18/1998 To 03/26/1999  ;

_s.______m _ _ _ - _ _ _m._____.._ - _ _ _ _ _ _ _ ___.____m_ .____-__- _ _. _ _____- .. __ __

Poge: 5 of 16 Dolo: 03/26/1999 Unit d Stat s Nuclear R gulatory Comm. .ission r.me: woo

, negion iti PLANT ISSUE MATRIX CLINTON By Primary Functional Area Functional Template ,

Date Source Areo ID Type Codes item Description 08/18/19CS 1903014 Prt OPS NRC NEG Prt SA Operations personnel did not recognize o potential reduction in ultimate heat sink inventory as a corw%on  ;

requiring on OD or mode restrairt Sec: See:

Ten 08/18/1003 1098014 Prt OPS NRC NEG Pri: SC The inspectors determ!ned that the licensee's Generic Letter 9 l-18 progrom for operobility determinations '

(ODs) was not effective in ensuring ODs were dispositioned in a time!y manner. Specificolly. 28 of 41 octive Sec-' Sec. '

ODs describing nonconforming conditions were older than 6 months. Actions token in May 1998 to ,

Tec disposition the active ODs were not successfulin it'ot only one of five shift monogers had completed the '

review of ossigned ODs by August 1.1998.

09/18/10CS 1905014 Prt OPS NRC POS Prt SB The inspectors noted that operator performance improved with respert to quesMoning deCroded or suspect i indicationi taking conservative immedicte actions. ond initioting the oppropriate corrective oction Sec- ' Sec: 2A document. The performance improvement was due. in port to implementation of the operations Tec deportment event tree performance initiative.

08/18/1993 1909014 Prt OPS NRC POS Pri: SC As a result of the corrective actions thot were implemented to improve pe'formance in the safety togout program. Including provid;ng odditional r,toffing. increasing monogement oversight, and improving training 3,g.' Sec. '

for operations and maintenance personr'ei. togout events were reduced from 11 in 1997 to 3 os of August 1 Ter: 1998.

02/16/1999 1999002 Prt MA!NT NRC NEG Prt 2B The inspectors determined that training and oversight of new molded cose circuit breaker test personnel did not ensure that expectotions for using the smallest gage wire during testing were implemented Sec- Sec.

Ten C2/16/1999 1009002 Prt MAINT NRC NEG Prt SB The inspectors determined that the licensee's ossessment of corrective action effectiveness for CSC Restort

!?em V.I. Deve!cp Process to Review Deferrols of Preventive Maintenance items? was not sufficiently critico!

Sec-' Sec* '

to identify deficiencies ossociotcd with implementation of the deferraf process forlate preventive i Ten maintenance items. Consecuentry. CSC Restort item V.1 wi'l remain open pending a review of the licensee *s ~

root cause onolysis and coirective actions ossocicted with implementation of the PM deferrol process i 02/16/1000 10C0002 Prt MAINT NRC POS Pri: 5B The inspectors determined that the licensee conducted a thorough evoluotion and inspection of the DMsion 3 ,c.'

IV nuclear system protection system bottery offer electricot maintenance personnel caused on occidento!

3 ,c.*

short circuit during maintenance on this bottery Tec 02/16/1099 1999002-03 Prt MAINT NRC NCV Prk2B The inspectors identified one violation. for which enforcement discretion was exercised. Concerning the failure to perform bte preventive maintenance items tasks or process deferrol requests prior to returning Sec* Sec-systems and components to on available status Ten 02/16/1999 1990CO2-06 Pri' MAINT NRC NCV Pri: 28 Foilure to perform required chonnei cotbrations on the drywell and containment hydrogen and oxygen gg 3,c.

onclyzers Ten e

tiem Type (Compunce.Other). From 08/18/1998 To 03/26/1999

Pogs: 6 of 16 . Date:03/26/1999 i Unitcd Statos Nuclear Rsgulatory Comm.ssion i Timeomo  ;

necion iii PLANT ISSUE MATRIX '

CLINTON By Primary Functioaol Areo Functional Template  ;

Date Source Area ID Type Codes item Description 01/06/1000 1ciS020 Prl: MAINT NRC FOS Pri: 28 Maintenance personnel conducted activities with the procedures present and in active use. Technicians Sec, were knowledgeoble of the tasks and closely followed the procedure or maintenance work request Sec- ,

Tec i

12/18/1993 1992005 41 Prl: MAINT NRC VIO IV Pri: 2B This was o violation for wNch enforcement discretion was exercised and involved not property bcluding SSCs Sec,*

n the scope of the MR. In the October 1997 QA oudit, the independent assessment, and the subsequent j Sec'- re-scoping effort, the licensee identified SSCs and functions that required inclusion in the MR scope. In the Tec recent QA oudit, the audit team identified questionable scoping decisions for several SSC functions. From the investigation for the resulting ,CR l-98-10-170. the licensee determined that on existing scoping document had been recently converted into o large database resulting in o number of errors. The Scensee was in the process of re-evoluoting and strengthening the information contoined in the datobose to clarify ,

the existing scoping. The inspectors evoluoted the licensee's resolution of the scoping issues ogoinst the requirements of the MR and concluded that scoping concerns had been property oddressed. Closed in inspection report 050-461/1998028 17/18/1003 19C5005 05 Pri: MAINT NRC V;O IV Pri: 2B This was o vio!ction for which enforcement discretion was exercised and involved estobiisNng inodequate pert rmance criterio. Based on the sensitivity study performed for the ovoilobility criterio, and the use of th9 S - ' Sec~.

statistico! cpproach as defined in the EPRI technical bulletins. the inspectors considered the licensee's Tec performonce cnterio for both ovoilobility and reliability to be consistent with the assumptions in the updated PRA and therefore acceptable. Appropriate gools and corective action plans were developed for SSCs assigned to category (oXI) of the MR. CLOSED in insoection report 1998028

~

12/18/1995 190e005-06 Pri: MAINT NRC ViOIV Pri: 2B Based on the sensitivity study performed for the avoitability criterio, and the use of the statistical opprooch as

  • defined in the EPRI technical bulletins. the inspectors considered the licensee's performance criterio for both Sec- Sec.

ovoilobility and retiobility to be consistent with the assumptions in the updated PRA and therefore Ten acceptoble. Appropriate goo!s and corrective action plans were developed for SSCs assigned to cctegory (a)(1) of the MR. CLOSED in inspection report 1998028 12/18/1908 1908005-07 Pri: MAINT NRC NCV Pri: 2B This was a violation for which enforcement discretion was exercised and involved the failure to monitor goats for (oXI) SSCs. Specifico!!y, the licensee was not identifying MPFFs not identifying and tracking Sec'* Sec. '

unovoilobility. and not monitoring unovoilobility for SSCs wNCh required monitoring and wNch were required Ten to be ovoilable during shutdown. During this inspection, the inspectors verified that the licensee was l tracking MPFFs and unovailability for SSCs needed for shutdown opero+ ions. The inspectors o!so evoluoted j i

the licensee's activities for trocking MPFFs and monitoring unovoilobility while shutdown for key sofety functions os well os for other SSCs required during the shutdown mode of operations. Bosed on these ,

evoluutions, the inspectors determined that the licensee's monitoring oCtivities were oCceptoble. This t portion of the violation is closed. Due to recent issues identified in the QA oudit concerning the inadequate implementation of the MR program, the other two issues will remain open pending further review by QA f personnel and the NRC as to the ettectiveness of the MR implementation and monitoring of ovoilobility and [

reiiobility.

12/18/lWS 1CCSOTS Pri: MAINT NRC NEG Pri: 2B Training of personnel on the on4ne risk procedures. however, needed to be completed prior to restort as port of NRC Manual Chapter 0350. Case Specific Checkhst Item 11.4.

See: See:

l Ten .

I t

i f

item Type (Cer phance.Other). From 08/18/1998 To 03'26/1999

_ _ _ __m___ _ . . _ _ ____m___--__-___m.__ _ _ _ . _ _ . - . r g

Poge: 7 of 16 Date: 03/26/1999 United Statss Nucinar Ragulatory Comm. .ission nme: u:u:oo Region 11: PLANT ISSUE MATRIX CLINTON By Primary Functional Area Functional Template Date Source Areo ID Type Codes item Dercription 12/18/1008 19CS023 Prt NWNT NRC POS Pri:2B Although the risk ranking process continued to rely on a probobilistic risk anofysis based predominantly on 3 ,g.

generic dato, the risk ranking of structures, systems and components was acceptable.

3 Ter:

12/18/1908 1903028 Prt MAINT NRC POS Prt 2B tn general, the guidance for performing periodic evoluotions met the requirements of the maintenance rule nd the intent of the industry implementing guidance. The Cycle 6 ossessment report provided good Sec- Sec-evoluotions of system performance over the period by documenting changes to molntenance activities and Ter changes to various maintenance rule program aspects.

12/18/1098 100$028 Prt MAINT NRC POS Prt 2B Based on the sensitivity study performed for the avoilobility criterio, and the use of the statistical opprooch cs defined in the Electric Power Research Institute technical bulletins, the inspectors considered the licensee's Sec** Sec,'

performance criterio for both ovoilobility and reliability to be consistent with the ossumptions in the updated Ter: probabilistic risk assessment and therefore acceptoble.

12/18/1998 1CCS028 Prt MAINT NRC POS Prt 28 Appropriate goofs and corrective action plans were developed for systems classified os (c)(1) per the 3, 3,c.

maintenance rule.

Tec 12/18/1993 1909028 Prt MAINT NRC POS Prt 2B in general structures. systems and components were being property classified under categories (oXI) and (a)(2) of the MR. Performance criterio. gools, and corrective actions, both in progress cod planned, for SC~'~ Sec. ~

structures, systems and components in (o)(1) status appeared adequate. The structure, system and Ter: component functions for the systems reviewed were property scoped under the MR. The inspectors reviewed condition reports, maintenance work requests and the periodic ossessment cod dd not identify any maintenance preventobie functional failures not previously classified or unavailability time not property trocked, 12/18/17C9 10C8023 Pri: MAINT NRC POS Pri: 5B The 1998 qua!ity ossurance cudit was thorough and probing. Based on individualissues, the auditors were -

ble to identify significont ursderyng Causes (lock of ownership and inodequate communications) for the Sec-* See: SA ineffective implementation of the maintenance rule program. Although actions have been identified and Ter: were being implemented to correct the weaknesses, it was too soon to determine their effectiveness. The use of outside personnel in the audit provided independent insights into the maintenance rule progrom and added to the overoll quality of the program ossessments 12/18/1998 1CCSO28 Prt MAINT NRC POS Prt 2B The inspectors concluded the licensee had adequate on-line and outoge risk ossessment processes and had established acceptobte thresholds for contingency planning.

See: ENG See:

Tec 12/18/1008 10C902S Prt MA!NT NRC POS Prt 28 The inspectors concluded that the process for boloncing the unovoilobility and reflobility of Mructures.

systems and components was acceptable, however, based on the Cycle 6 periodic ossessment, the See: ENG See: 5A licensee concluded that implementation rf this process was ineffective. in response to this self-identified Tec concern, the licensee took action to ensure o proper bolonce existed between the reliability and ovoitability for structures, systems and components.

Item Type lCempliance Omer). Frorn 08/18/1998 To 03/26/1999

. . - . - . .- -.- _. - - . . . _- - .~ ,. . , .

Pog2: 8 of 16 Dole: 03/26/1999 Unitsd Statas Nuclear R;gulatory Commiss. ion um.: u:u:oo negion m PLANT ISSUE MATRIX '

CiiNTON By Primary Functional Area Functional Template Dofe Sourco Areo ID Type Codes item Description 11/17/1WS IWS01 S Prl: MAINT NRC NEG Pri: 2B Ine inspectors concluded that inodequote preparations for measuring the lifting torque on high pressure c re spr y in!et check v !v resulted in the loss of os-found dato during the measurement. The failure of the Sec-* Sec- '

non-licensed opercior to attend the pre-job briefing moy have contributed to this event. No instructions Tec were included in the wcrk package os to what type of odopter was needed for the measurement and the workers did not note the prcblems with the adopter in the remorks section.

10/01/lWS 1 W OI7 Prk MAINT NRC POS Pri: 2B The inspectors concluded that the licensee odhered to the revised molded Case circuit brecker testing procedure. In addition. the newly instituted molded cose circuit breaker enclosure testing and inspection Sec-* Sec.

program revealed a significont number of deficient conditions including incorrect fuses and degraded Tec motor starter contactors.

08/lB/1WS 1WS0- Pri: MAINT NRC NEG Prt 2B The Division 11 emergency core cooling system (ECCS) integrated survelitance testing preptonning for the test could have been more thorough. Some personnel ossignments were initiofly made and/or changed at the Sec- Sec'.

briefing. communication links were not established chead of time, the placement of test cables created a Ten tripping hozord, mechonicot stops were not used on open cobinets, and test switches were installed inside energized poneis. Additionotty. :he prejob brief did not include iessons learned, Industry experience, or contingencies OS/1S/1W9 1W6014 Pri: MAINT NRC NEG Prt 2B The inspectors noted that management expectotions were not met during the review of selected condition rep ris (CRs) in that maintenance personnel did not determine and document the extent of the condition Sec-

  • Sec~.

ossociated with some level three CRs.

Tec 08/l8/1WS IWS014 Pri: MAINT NRC WK Prt 2B The inspectors identified a weakness with the scheduling of Technical Specification Surveillonce Requirements (SRs). 44 % of o!! monthly and quarterly surveillances were being performed in the 25 % groce Sec-' Sec K period offer the due da+e; 11 overdue SRs were omitted from o weekly surveillance test report; personnel Tec were unowore of the safety-related preventive maintenonce (PM) tosks that were required to meet a specific SR; and, the impoct on SRs was not evoluoted for a late safety-related PM tosk 02/16/1CW 1WoJ02 Pri ENG NRC POS Pri: 5B The inspectors determined that the licensee had resolved the concerns ossociated with CSC Restort item

. es gMCY h Gmerator Concms*

Sec: Sec:

Tec 02/16/1 W 7 10WDC2-04 Pri: ENG NRC NCY Pri: 4A The inspectors identified one Non-Cited Violation pertaining to the licensee's identificotton that design basis requirements had not been odequately translated into maintenance procedures and instructions invoMng Sec- Sec. '

the replacement of the Division i and 11 shutdown servlCe water pump oil coolers. The licensee *s corrective Ter: octions to review the generic implications of the Division i shutdown service water pump bearing failure on ,

other large safety-related motors was timely and conservative 02/16/1 W 9 lown 02-05 Prt ENG NRC NCV Prt SA The inspectors identified one Non-Cited Violation for the failure to moke o required 10 CFR 50.72(b)(2)(iii) report to the NRC within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of discovery that the shutdown service water system would not have Sec- Sec.

performed its intended safety functions

' ~

Ten .

ltem Type (Co@ance.Other). From 08/18/1998 To 03/26/1999

Page: 9 of 16 Date:03/26/1999 Unit d Stat s Nucicar Rcgulatory Comm. .ission um.:i4:ieo negion iii PLANT ISSUE MATRIX CLINTON By Primary Functional Area Functional Template  !

Dofe Source - Areo ID Type Codes ttom Description 01/06/1000 1005020 Pri: ENG NRC POS Pri: SB Quotity assurance personnel conducted a thorough evoluotion of the contractor control program See: See: I Ten 3 Pri:4A The inspectors identified one violation. for which enforcement discretion was exercised, that involved the i 01/06/1W9 19 6020-03 Pri: ENG NRC NCV repeat failure to ensure design requirements for the MCR breathing cir system were transloted into piont i Sec- kc-procedures Tec 01/06/1000 1908020 04 Pri: ENG NRC NCV Pri' 4C The failure to test the EDGs of 110 percent of roted food is a violation of TS SR 3.8.1.14.

See: See: i Tec 12/18/1908 10C5023 Pil: ENG NRC POS Prt 4C The system engineers were experienced and knowledgeoble about their systems and understood their 3, .

responsibilities with respect to the maintenance rule. l 3, .

Tec 11/30/1998 1008026 Pri: ENG NRC NEG Pri: 4A The team concluded that the Coble test documentation utilized by the licensee to support the qualificofion of Whittoker fire-rated safe shutdown cables did not edequately demonstrate that the fire-roted cobles Sec' Sec, '

provided equivo!ent fire protection as that provided by a rated fire barrier. This issue wilf remain open  ;

Ten pending NRC review prior to restort ,

s 11/30/100S 1MS0Z6 Pri: ENG NRC NEG Pri: 4A The team concluded that, due to obstructions, sprinkler systems insto!!ed in several risk significant fire creas may be incopoble of suppressing a fire. This issue will remain open pending NRC review prior to restort >

Sw: Sec.

t Tec 11/30/1 W S 100S026 01 Pri: ENG NRC VIO i:1 Prt 58 A violation was identified regarding the licensee's failure to ensure that 54 MOVs would remain free of fire [

domoge due to fke induced hot shorts in the volves' control circuitry . Enforcement discretion was exercised. '

E K SC The remaining corrective actions related to this victotion will be revewed by the NRC prior to restort Ten  ;

t 11/30/10CS 10CG6 02 Prl: ENG NRC VIOi:1 Prt 4A A violation with three (3) exomptes was identified regarding the foilure to provide adequate electrical circuit '

isolation for several safe shutdown components. Enforcement discretion was exercised 3, ; 3, ,

Ten [

I 11/17/100S 10CS018 Prl: ENG NRC POS Pri: 4C The inspectors determined that the local leck rate testing program was well controlled, that engineering personnel were knowledgeoble of locolleck rote testing requirements, and that odequate actions had ,

Sec- Sec.

been taken to implement Option B of Appendix J to 10 CFR Port 50.

l Ten I

!!ern T)pe (Comphance C her). Frorn 08/18/1998 To 03/26/1999 i

. .~- . - - -

1 Poge: 10 of 16 Date:03/26/1999 Unitcd Statcs Nuclear Ragulatory Commission ume:im0 negion m PLANT ISSUE MATRIX CLINTON By Primory Functional Area Functional , Temptote Date Source Area ID Type Codes item Descriptiori 11/17/1W3 10CS019 Pri: ENG NRC POS Pri: 5B The inspectors determined that engineering personnel actively conducted criticci self-ossessments in on effort to identify deportmento! strengths, weaknesses, and opportunities for improvement, in addition.

Sec' Sec-

~ '

wool.nesses and recommendations were odequctely trocked to ensure resolution.

Ten 11/17/lCCS 1908018 03 Pri: ENG NRC NCV Pri: 3B One non-cried vio!ation was identified due to the licensee's identification thot engineering personne! had failed to ful y understond the operational chorocteristics of the emergency reserve auxitiory transformer food Sec' Sec'.

top changer prior to testing on October 22.1998.

Tet 10/W/1993 10CS019 Pri: ENG NRC POS Pri: 4A The inspectors concluded that the SX system design and configuration controls were odequate. The SDFV ,

assessment of the SX system was very Comprehensive and thorough. The team concluded that octions  ;

3 . ' 3 ' tol<en os the resu!t of the SDR/ assessment would correct many operational problems and concerns with the .'

Tet SX system.

10/00/190S 19C3010 Prl: ENG NRC POS Pri: 4A The team concluded that the licensee's revised methodology for reviewing calculations in order to ,

determine the technical odequocy of the CPS coiculation progrom was sofistoctory. However. insufficient .

3, .' 3 . '

octivities were completed by the licensee of the conclusion of this inspection to support on odeoucte Tec review by the NRC. As o resurf, the inspect!on of this issue could not be completed during the E&TS inspection, 10/00/19CS 1998019 Pri: ENG NRC POS Pri: 4A The team concluded that the licensee's Setpoint Progrom Action Plon methodology was sound. However.

See,~

insufficient octivities were compiefed by the licensee at the conclusion of this inspection to cIlow for on j Sec- '

odequate review by the NRC As o result, the lnspection of this issue could not be completed during the Ten E&TS inspection 10/09/19C3 1WS019 Pri: ENG NRC POS Pri:4B The material condition of the woiked down systems appeared to be good. The system engineers oppeared t be knowledgeable of the systems.

Sec: Sec:

Ter. j 10/09/19CS 1009010 Pri: ENG NRC POS Pri: 4C The team concluded thof no major problems existed with the hardwore change process or with the Sec,~

selected hardware changes reviewed that had not been previousty identified by the 5censee. The Sec~~~

technical quality of the selected engineering work products was generolfy sound and the bordware Tet changes reviewed were cdequotely implemented.

10/0C/10V8 INS 01C Pri: ENG NRC POS Pri: 5A The engineering stoff was effective in the ldentfication of technicol problems. The team concluded that ,

the system design and functional vertfication progrom reviews conducted on the residuol heat removoi and

$" '" shutdown service worer systems identified significont issues and the quotity of those reviews was considered Ten exce!!ent. These issues resulted in a significant omount of corrective action work.

10/09/1C9S INS 019 Pri: ENG NRC POS Pri: 5A Based on their system reviews, the team concluded that the System Heolth Report provided on occurate t

ccounting of system stotus with regard to the numbers of CRs. MWRs. etc. No major discrepancies were Sec-' Sec. '

identified with the System Heoith Report for the systems reviewed. The automatic depressurization system Ten status could not be reviewed since the system was not addressed in the System Heoith Report.

item Type (Compance.Other). From 08/18/1998 To 03/26/1999 i

_ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ . . . _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . , _ _ _ _ _ . _ _ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ . . _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ .______e

Poge: 11 of 16 Date: 03/26/1999 Unit d Stat s Nuclear R:gulatory Comm. .ission nme: u:uoD necion m PLANT ISSUE MATRIX CLINTON By Primary Functional Area Functional Template Date Source Areo ID Type Codes item Description 10/09/1908 1995019 Pri' ENG NRC POS Pri: SB The licensee had on acceptable 10 CFR 50.59 program and that quotified personnel prepared and reviewed the 10 CFR 50.59 screenings and safety evoluotions. The 10 CFR 50.59 screenings and safety

'Sec- ' Sw. '

evoluotions reviewed were odequate with the exception of some minor errors. Although no specific issues -

Ten were identified by the inspectors. the number of licensee identified condition reports (CRs) concerning safety screenings and evoluotions revected that problems still exist.

10/09/1998 199S019 Pri: ENG NRC POS Pri: SC in most instances, the corrective action process for the CRs selected for review was odequately 3,c.

implemented and resulted in acceptob!e corrective actions.

3,e.

Ten 10/09/1908 19C6019 Pri: ENG NRC WK Pri: 1C The team concluded that the system engineers were generoily qualified and experienced. However, the team identified a weakness in that detoiled training was not provided to the system engineers for their Sec' Sec,'

ossigned systems. On October 10.1998. tne team was notified that system engineers would receive senior Ten recctor operator system training for their ossigned system (s).

10/00/100S 1006010 Pri: ENG NRC WK Pri: 4A The team Concluded that the lock of a setpoint Control progrom and a lock of trending of safety-related and maintenance rule-related instrument drift was a weakness. The team o!so concluded that lock of

  • # #3 supporting calculations for important instrument setpoints was a weakness.

Tec 4C 10/09/19CS 190F01C Pri: ENG NRC WK Pri:48 Present performance by the licensee on the SX system was excellent. However, the team noted that the licensee had not generatsd maintenance work requests (MWRs) or prev 9ntive maintennnce tasks to assure Sec*- tec.

~

  • replacement of limited life non-environmentally qualifiec equipment in the p! ant. The team considered this Ten a weakness 10/00/109S 1908019 01 Pri: ENG NRC Eri Pri: 4C A violation for which enforcement discretion was exercised was identified invoMng the instoiction of o minor m dification which caused the loss of suppression pool cooling.

Sec: See:

f Ten 10/00/1005 199S019-02 Pri: ENG NRC NCV Pri: SC An NCV was identified regarding the licensec's failure to take odequate and timely octions for excessive sat occumulations in the SX pump intoke creo. ,

3, 3 Ten 10/09/19CS 199S010-03 Pri: ENG NRC NCV Pri: 4A Licensee foiled to include the battery charger's minimurn voitage requirement in the acceptance criteria for 3,e^,

the degraded voitage transient calculation. A design change was issued to odjust the top settirgs on the 3 ,e,

  • Division 1 and 2 battery chorger transformers to assure that the minimum voltage requirement was met. The Ten inspectors did not identify any discrepancies based on their review of oppropriate calculations, design changes and corrective oction work documents.

10/01/1993 1999017 . Pri:ENG NRC NEG Pri: 5C The inspectors identified that ineffective corrective actions had been token for selected level 3 condition reports. Specifico!!y. four of ten rondomly selected closed engineering deportment condition reports either Sec* Sec- '

locked on oppropriate apparent cause. did not identify the extent of the condition, or implemented Ten corrective actions which did not oddress the coporent Couse.

Item Type (Compliance.Omer). From 08/t8/1998 To 03/26/1999

Foga: 12 of 16 Date: 03/26/1999 Unitsd Statcs Nucl:ar Ragulatory Comm. .ission um2 u:u.co cevon iii PLANT ISSUE MATRIX CLINTON By Primary Functional Area Functional Template Date Source Areo ID Type Codes item Description I

!C/01/1993 1998017-02 Prk ENG NRC NCV Pri: 4C One non-cited violation was identified for the licensee's identification of the failure to submit changes in the qu ity assurance progrom which constituted reductions in commitments mode to the NRC.

See: Sec:

Tec  ;

CS/18/1998 1995014 Pri:ENG NRC NEG Prk 4B Engineering personnel did not provide odequate support to operatlons personnel in that a CR oddressing on olready resolved issue was not closed in a timely manner See: See:

Tet 05/18/1903- 19950! 1 01 Prt ENG NRC NCV Pri: 4A lhe inspectors identified that Technical Specification requirements were not met because the Division til EDG comot adoMcoh swkWng sMHonce tesMg from N M mWo MsoWonous e os Sec*- See: SA required in response to on octual or simulated emergency core cooling system initiation signol. This item is of Tec concern because the licensee did not recognize that the design of the EDG resulted in the inobility to meet a Technical Specification requirement.  ;

02/16/19W 1909002 Pri: PLTSUP NRC POS Pri: 1C The inspectors determined that radiction protection personnel demonstrcted consenrotive decision making by using a video comero and robot to minimize exposure to only 9 mill! rem during recovery of a radiography See: Sec:

source Tec  ;

02/12/1099 1900005 Prt PLTSUP NRC POS Pri: 1C The inspector noted improvements in the ALARA program. Increasing the resources for the ALARA progrom Sec,*

contributed to more timely and critical work planning reviews and to effective monitoring of department  ;

Sec'- and station dose perfcrmance. The 1999 onnual dose gools more occurately reflected the licensee's t Ten p;onned scope of work and were effectively monitored by the plant departments. ,

02/12/1999 1909005 Prt PLTSUP NRC POS Prl: IC During routine contamination surveys and work coveroge. RP technicions demonstrated occeptoble techniques and cleorty communicated radiological conditions to plant personnel in addition. the licensee Sec- Sec.

  • property calibrated creo radiction monitors at the frequency specified in plant procedures.

' ~

Ter:

02/12/1090 1990005 Pri: PLTSUP NRC POS Pri:1C The licensee included on acceptobie level of ALARA instructions in general employee and RP technicion training. which included the use of mock-ups. The ALARA sic'f otso porticipated in bench-marking to Sec- ' Sec. -

increase its cworeness of successfulindustry proctices.

Tec C2/l2/1990 19 WOOS-01 Prl: PLTSUP Licensee NCV Pri: 3A The licensee identified ca inode tent entry of two individuals into o posted high rodlotion creo (HRA). The [

individuo!s were not on o rodiction work permit which authorized the entry into the HRA. controry to Sec'- Sec.-

procedural requirements. This failure to fo!!ow procedure was considered a Non-Cited Viofotion. The Tec inspector concluded that the licensee had performed on oppropriate review of the incident c.nd had

mplemented corrective actions. which were commensurate with the error. i I

[

i item Type (Comphance.Othe-). From 08/18/1998 To 03/26/1999 f

Poge: ' 13 of 16 Date: 03/26/1999 Unitsd Statss Nucisar Rcgulatory Comm. .ission nme: i4:i4 oo Region m Pl. ANT ISSUE MATRIX Ct1NTON By Primary Functionat Area Functional Templots Date Source Areo ID Type Codes item Description 02/12/1999 19 WOO 5 02 Prt PLTSUP Licensee VIO lV Pat SC The inspector concluded that the licensee had not odequately Corrected a repetitive problem Concerning Sec,"

the odequacy and thoroughness of radiological surveys. As a resu!t of this ongoing problem, the licensee Sec" identified a failure of the RP statt to perform on adequate radiologico! survey incident to the changes in Tec operation of the residuct heat removat system. This inodequate survey was determined to be o violation of 10 CFR Port 20. Specifically, the RP staff failed to identify and post on HRA, which resulted from known operationci changes within the facihty.

11/20/1998 10CSO27 Prt PLTSUP NRC NEG Prt 1C Overall performance of OSC management and ston was mixed, with examples of both good and poor indviduct performance. Overall command and control of the focility was insufficient. The OSC 3 , ' 3 ' .

management did not maintain good awareness of deployed teams' progress or results. The OSC Director t

Tec seldom stoyed in the command creo of the OSC where reports were being received so that these reports could promptly be ossessed and on overoll perspective of deployed teoms' octMiles could be maintained.

11/20/1993 1003027 Pri: PLTSUP NRC NEG . Prt 1C The OSC team briefings followed the some gt!delines for high priority tasks as for lower priority tasks. There were no opparent management expectotions for briefing and dispatching higher priority teams from the Sec-

  • Sec.*

OSC more expeditiously than lower priority teams.

Tec

. i 11/20/1993 1995027 Prk PLTSUP NRC NEG Prt1C The EOF protective measures staff was unable to completely respond to the Emergency Monocer's and Sec, simulated NRC responders' requests for several offsite dose projections in a timely manner.

Sec:

Tec i

11/20/10C8 1995027 Prk PLTSUP NRC NEG Prt 1C A backup power supply ceosed powering the TSC Public Address (PA) system offer 26 minutes of opcotion.

o e eon a onog rs' NdNs wem not oudM b the OSC. home Sec: Sec: 2A megophone was not utdized Tec 11/20/19CS 1W8027 Pri: PLTSUP NRC NEG Prt 2A A modem on the computer assigned to the EOF protective meosures staff actually foiled and the stoff was unowore that on available bockup computer clso had on insto!!ec modem.

Sec: Sec:

  • Ter- ,

6 11/20/1993 1005027 Prt PLTSUP NRC POS Pri: IC Overoil performance in the Simulator Main Control Room (SMCR) was odequate. During the rapidy moving ,

exercise scenorio. control room shift personnel property diognosed reactor events at the Not:ficotton of 1 Sec-

  • Sec.
  • Unusuol Event. Alert. and Site Area Emergency classification levels. Notifications were prompfty mode to  ;

Tec offsite officio!s.

11/20/1998 1005027 Prt PLTSUP NRC POS PrtIC The Technical Support Center (TSC) stoff's performance was odequate. Plant event onofysis, event ClassifiCotiort notifiCotions, briefings, Und CommuniCotions with other foCilites were Competently performed 3, . 3 by the stoff.

Tec 11/20/19CS INS 027 Prk PLISUP NRC POS Prt1C Self-critiques foltowing termination of the exercise were critical and included inputs from controllers and exercise participants. In particutor, the SMCR evotuotors critically assessed operator oerformcnce.

3 ,c. Sec.

Tet i

itc a Type (Cempliance Omer). From 08/18/1998 To 03/26/1999

Page: 14 of 16 Do'e: 03/26/1999 Unitad States Nucicar Regulatory Comm. .ission Tim 2 u:u:oo region m PLANT ISSUE MATRIX CUNTON By Primary Functionoi Area Functional Temploto

Date Source Areo ID Type Codes item Description 11/20/1WS 1WS027 Pri PliSUP NRC WK Pri
IC Emergency Plan Implementing Procedure RA-02. " Protective Action Recommendations."icentified the 3 ,c.~

default minimum Protective Action Recommendation (PAR) upon the decloration of a Genero! Emergency 3, .

to be os follows: "Evocuote 0-2 mite radius and 2-5 rnles downwind unless conditions make evacuotion ler: dongerous and advise the remainder of p!ume Emergency Pionning Zone (EPZ) to go indoors (shetter) to ,

monitor EAS (Emergency Alert System) broodcasts." However. lilinois Nuclear Accident Reporting System (NARS) message number 4. did not contoin a recommendotion to sheltemersor s in the remoinder of the EPZ.

I 11/20!1 W e INSO27 Pri PLTSUP NRC NEG Pri; IC An operator error in the SMCR resu'ted in the isolation of the Reactor Core Isolation Cooling system, the only soWeo o ng woMdor me reoN of N h Sec: OPS Sec:3B f Ter- -t t

11/17/1998 1C98013 F.1: PLTSUP NRC POS Pri: IC Licensee controllers and evoluotors in both the technical support center and the operations support center [

prov ded on occurate ossessment of activities during the October 14.1998. emergency drill. The licensee's  !

S - Sec.

observations and post drill critiques for the technicci support center and operations support center were  ;

Ter: effective it. recognizing strengths, weaknesses and creas for continued improvement .

11/17/1NS 1W501S Pri: PLTSUP NRC POS Pri: SB The licensee's ossessment of the stuck fire shield in o shipping cask was effe dive in that the licensee. based on this ossessment. determined that the event was caused by poor resolution of previously identified Sec-* Sec.

  • concerns and non-conservative decision making which resu!ted in a rodwoste liner and fire shield becoming Ter: bdged in a shipping cask. l 10/09/19CS 1W5025 Pri: PLTSUP NRC NEG Pri IC oeveral emergency medical kits were present in on Operationoi Support Center (OSC) Emergency Response 3, ;

Organization (ERO) locker. The EP stoft were unowore of their presence. ond the condition of these kits was 3

poor 3 Ter .

10f00/1W5 10:5025 Pri: PLISUP NRC NEG Pri: 2A The material condition of the Technical Support Center (TSC) was marginal os identified in the two lost Sec,'

impect ns, with conduit modification adding a considerable tripping hozord. The only change noted in Sec- ,

the f acility was o "cotolog dispicy stond" for the Emergency Pion and implementing Procedures.1he Areo  ;

Ter: Rodiction/Proces- Radiction ponel in the ISC was nonfunctional {,

, 10/09/1 W S 1W5025 Pri: PLISUP NRC POS Pri: IC The EP training program oppeared effective. ERO personnel were qualified for their emergency response  !

' positions. The offer-hours ougmentation drill was successful. The dri!! Critique documentation was good. [

$" including a summary, time line. backup dato for individual resp nse times o list of problems identified, and Ter: recommenaed solutions. l 10/09/1o05 IW2025 Pri: PLTSUP NRC PCIS Pri: SC Corrective actions had been taken on a number of issues relative to the February 1998 Alert. Effective.

cceptoble corrective actions on these issues indicated that the EP program was on on improving trend. l Sec- Sec~.

However. Several other corrective actions. such as implementation of the new outodioter collout system. ,

Ter: were yet to be completed.

t Item Type (Cometiance. Omen From 08/18/1998 To C3'26/1999

~ _ . _ _ . __ .-

-Page: 15 of 16 Date: 03/26/1999.

Unit;d Stat:s Nucisar R gulatory Comm. .ission Time: u:um Region til PLANT ISSUE MATRIX CLINTON By Primary Functional Area Functional Templete Date >ource Areo ID Type Codes item Description 10/01/1WS 1W$017 Prl' PLTSUP NRC POS Pri- 1C - The inspectors noted a centinued improvement in decontominoiion efforts in that radiction protection and f cilities personnel successful!y decontominated the residual hect removal"A* hect exchanger room from 60 Sec*' Sec.'

mrod smeoroble to less than 1.000 dpm/100 cm2.

Tec 10/01/1WS 1CG024 Pri: PLTSUP NRC NEG Pri:2A in response to self-identified and NRC-identdied deficiencies the Ecensee had improved oversight of the post occident sompling system. Recent monogement focus on the system resulted in the completion of Sec-- Sec'.

several maintenance activihes. However, the system remained inoperable pending the completion of Ten nointenance on the atmospheric sompting system.

10/01/lWS 10 % 024 Pri: PLTSUP NRC POS Pri: IC The RP staff implemented effective planning for the vocuuming of the suppression pool and the removal and replacement of the ECCS stroiners. For example, the planning documents contained recommendotions Sec*- Sec*.

contoined in NRC generic communications and the lessons learned from industry performance. In addition.

Tec the RP staff provided good dose tracking and trending of the evolution.

10 '01/lWS 1W9024 Pri: PLTSUP NRC POS Pri: IC During the ECCS suction strainer mod:fication, the inspector observed good teomwork and communicotions between the work groups. The RP staff effectively communicated radiological corxfitions to the divers and Sec- Sec.

to the work groups and provided good control of the evolution.

Tec 10/01/1WS 10:5024 Pri: PLTSUP NRC POS Pri: 1C The inspector observed chemistry technicians proporty implementing sompfing and onclysis procedures.

Chernistry technicions performed the activities with the procedures in-hand and demonstrated proper Sec- Sec.

contamination control practices. The inspector oiso noted improvements in the content of chemistry Tsc procedures, which oddressed previous inspection findings.

10/01/1WS 1 W 324 Pri: PLTSUP NRC WK Pri: 1C The licensee's proceoure for control of diving evolut ons was generoI!y consistent with NRC generic communications and industry lessons learned. However, the inspector observed weaknesses in the See: Sec.

proceoure concerning provisions for the use of remote monitoring and visuoi contact with the divers.

~

Ten 08/18/100B lWS014 Pri: PLTSUP NRC NEG Pri: IC The inspectors determined that emergency planning personnel had not verified the Copobility to stoff

  • *'O #U**P * '9 "* * " "' 9' *
  • Sec'- See: SC there had been four failures of the poger system since July 1997 Ten 5B 08/lS/1 W 9 1005014 Pri: PLTSUP NRC POS Pri: 1C lhe licensee's self contained breathing opporotus inspection progrom was tnorough in that inspections were performed of the proper frequency. oil materiot condition and functionality issues were addressed, and Sec- Sec~-

^

oppropriate actions were token when test failures were identified .

Tec OS/lS/lCCS 1CCSO14 Pri: PLTSUP NRC POS Pri: IC In preparotion for the insto!!otion of a fire separotion wolf, the licensee removed a 2-inch suppression pool cleanup line wtiich resutted in on estimated 28 person-rem dose savings for the modification. This Sec- ' Sec.'

demonstrated effective implementation of the As low As Reasonobly Achievable (ALARA) progrom Tec item Type (Com@ance.Other). From 08/18/1998 To 03/26/1999 F - - - - = - . - _ _ _ - - - .__

Pogo: 16 of 16 Dole: 03/26/1999.

Unit;d Statss Nuclear R gulatory Comm. .ission um.: i4.i4eo PLANT ISSUE MATRIX By Primary Functional Area t

Legend Type Codes: Template Codes: Functional Areas:

!BU Bul!etin 1A Normal Operations OPS Operations lCDR Construction 1B Operations During Transients MAINT Maintenance lDEV Deviction 1C Programs and Processes ENG Engineering .

! eel Esco!ated Enforcement item 2A Equipment Condition PLTSUP Plant Support inspecter follow-up item 2B Programs and Processes OTHER Other s

{IFl .,

!LER Licensee Event Report 3A Work Performance iCU Licensing issue 3B KSA

{M SC M scellaneous 3C Work Environment

!MV Minct Molation 4A- Design ,

fNCV NonCited Viciation 48 Engineering Support lNEG Negotive 4C Programs and Processes lNOED Notice cf Enforcement Discretion 5A identification 56 Anotysis

[NON Notice cf Non-Conformance

!P21 Port 21 SC Resolution POS Positive ID Codes:

,SGI Sofeguc d Esent Report NRC NRC STR Strength Self Self-Revealed l 3

URI Unresolved item Licensee Licensee i VIO Molation

!WK Weckness ,

Eels are apparent vio!ctions of NRC Requirements that are being considered for escoloted enforcement action in accordance with the " General Statement of PoEcy and  !

Procedu:e for NRC Enforcement Action"(Enforcement Policy). NUREG-1600_ However, the NRC has not reached its final enforcement decision on the issues identified by the Eels and the PIM entnes may be modified when the finoi decisions are mode.

UR's are unresols ed items about which more information is required to determine whether the issue in question is on occeptoble item, o deviction, o nonconformance, or o vio!c' ion. A URI moy olso be o po+ential violation that is not likely to be considered for escolated enforcement oction. However, the NRC hos not reached its final conclusions on the issues, and the P;M entries mm be modified when the final conclusions are mode.

t item Type (Corrpliance.Other). From 08/18/1998 To 03/26/1999 ,

- _ _ _ .___._____1 _ _ S e.

3/26/1999 PLANT ISSUES MATRIX Clinton Search soited by Date (Descending) and SMM Codes (Ascending): Search Colurnn = *SALP* , SALP Area =

  • Operations * , eeginning Data = *10/1/1997* . Ending Data = 8/18/1998*
  1. DATE TYPE 50URCE ID BY SALP SMM CODES DESCRIPTION 1 7/1f .98 Pos.tive IR 98011 Self- Operations 18 The inspectors concfuded 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.

7/-, 1998 Positive IR 98011 NRC Operations 1C Operations personnel demonstrated imornved 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.

3 7/10/1998 ED IR 98011 Licensee Operations SA One violation for which enforcement discretion was exercised was identified concerning 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.

4 7/10/1998 Negative IR 98011 NRC Operations SA The inspectors concluded that while reactor operators performed comprehensive control room panet walkdowns during shift turnover, oncoming senior reactor operators and shift managers performed cursory !

reviews of the control panels and did not examine all panels during shift turnovers. This may have contributed to performance problems involving identification of degraded or nonconfonning conditions by control room personnel 5 7/10/1998 TJegative IR 98011 NRC Operations SA 3B Eight days elapsed and inspector prompting was needed to ir'itiato 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 open as a Technical Specific *on mode restraint until prompted by the inspectors.

6 7/10/1998 Positive IR 98011 Licensee 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 111 EDG outage.

Page 1 of 18

e-.s --

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" . SALP Area = " Operations

  • Beginning Date = *10/1/1997* , Ending Date = *8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 7 7/10/1998 ED IR 98011 Licensee 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).

8 5/28/1998 Positive IR 98008 NRC Operations 1C The inspectors concluded that operation's logs included sufficient detail to describe plant activities, compensatory measures for out-of-service annunciators were appropriate, and coordination and contingency plans referenced approved procedures.

9 5/28/1998 ED IR 98008 NRC Operatione SC The inspectors identified a violation for not implementing corrective actions to preclude the failure to perform verifications on all primary containment manualisolation devices as required by Technical Specification's following a similar discovery affecting secondary containment manual isolation devices in June 1996.

10 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.

11 5/5/i998 Misc 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 11 operable. The items were resolved, and the inspectors determined that Division 11 was operable for Mode 4.

12 4/14/1998 Positive IR 98006 NRC Operations 1C Contingency plans for the Division !! Inverter outage and the reserve auxiliary transformer excavation work were thorough in that they were communicated to affected personnel and considered the potential for several events.

13 4/14/1998 Positive IR 98006 Self- Operations 2A The Division ll Emergency Diesel Cer;erator 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).

Page 2 of 18 l

mm- .---,,-.w-

/264 999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Colurnn = *0 ALP' , sALP Area =

  • Operations
  • Beginning Data = *10/1/1997* , Ending Data = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION ,

14 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 (F.0) were indicative of continued poor -

operator performance, a general disregard for main control room indications, and poor supervisory oversight (Section 01.1).

15 3/3/1998 NCV IR 98003 NRC Operations 1A 2A 2B 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 Rlil-97-001 (Section O2.1) 16 3/3/1998 NCV IR 98003 Licensee Operations 1A 38 2A Operations and engineering personnel demonstrated poor knowledge of the breathing air system in that they believed the system had been abandoned in place and were unfamiliar with system operating parameters. Not using alternate compensatory methods to recharge the breathing air system bottles after identifying that the system was required to be maintained operable at all times demonstrated a nonconservative establishment of priorities for system restoration (Section O2.2).

17 3/3/1998 NCV IR 98003 NRC Operations 1A SA Actions were not implemented to operate the service water traveling ,

screens during cold weather in order to prevent ice blockage and a potential loss of the ultimate heat sink. A delay in operating the traveling .i screens upon completion of a maintenance activity indicated poor oversight of restoring required piant systems to service by operations personnel. Implementation of procedural guidance to minimize ice blockage of the intake structure following the identification of the .' .e was delayed due to the poor prioritization of procedure revisions b :ction O2.3).

18 3/3/1998 Positive IR 98003 Licensee Operations 1B The shift supervisor limited access to the MCR by assigning an individual the responsibility to prevent entry by non-essential personnel. This action significantly reduced the number of distractions in the main control room.

Operations personnel demonstrated good use of emergency, off normal, and system operating procedures in the MCR (Section P1.1).

Page 3 of 18  :

l

/26/1999 PLANT ISSUES MATRIX -!

Clinton Search Sorted by Date (Descending) end SMM Codes (Ascending): search Column = "SALP* , SALP Area = ' Operations" Beginning Date = *10/1/1997* , Ending Date = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION i

19 3/3/1998 Weakness IR 98003 NRC Operations 1B 1C Minimum emergency plan staffing for on shift,30 minute, and 60 minute response was not met. Seven radiation protection and maintenance personnel were added to the on shift emergency planning minimum staffing requirements due to concerns regarding the ability to meet the manning requirements (Section P1.1). j 20 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.

The shift supervisor used conservative decision making to activate the emergency response organization (ERO) in order to obtain additional resources to restore shutdown cooling (Section P1.1).

21 3/3/1998 Negative IR 98003 NRC Operations 1C Implementing procedures for cold weather properations were cumbersome in that they were not easily identified and provided vague '

criteria for init;ating actions. Numerous discrepancies with cold weather requirements were identified amongst the various cold weather procedures (Section O2.4).

22 3/3/1998 Negative IR 98003 NRC Operations 1C Even though the licensee was required to replace service air intake filters ar.d 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 or the area operator logs as of March 3,1998 (Section O2.4).

23 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 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 Pctions to improve ,

procedure quality in response to Confirmatory Action Letter ill-96-013 have not been fully effective (Section O3.1).

1 Page 4 of 18 i

/26/1999 PLANT ISSUES MATRIX Clinton search sorted by Date (Descending) and sMM Codes (Ascending)- Search Column = *SALP* : SALP Area = ' Operations * . Beginning Date = *10/1/1997* ; Ending Date = '8/18/1998*

  1. DATE _ TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 24 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 trained on the remote operation of the EDGs since late 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 of the inadequate training, actions to ensure qualified personnel i were available to perform local manual operation of the EDGs were not immediately taken (Section O5.1).

T5 3/3/1998 NCV IR 98003 NRC Operations 1C SC Timely corrective actions were not implemented to prevent operations personnel from rendering both EDGs inoperable due to taking the maintenance switch for one EDG to the lockout position in preparation for surveillance testing while the other EDG was inoperable (Section 08.2).

26 3/3/1998 Negative IR 98003 NRC Operations 3A Fire watch personnel failed to perform a tour of the Division 11 EDG room in order to evaluate the presence of transient combustible materials (Section F1.1).

27 3/3/1998 Positive IR 98003 r!9C Operations 5A 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 control of field samples (Section P1.1).

28 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) 29 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 potentialloss of the division 2 NSPS bus. (Section 07.1)

Page 5 of 18

_-. -.*,.mw- ,- -w - -. w+--e--+

/26/1999 PLANT ISSUES MATRIX Clinton search Sorted by Date (Descending) and SMM Codes (Ascending): search Column = "SALP* , SALP Area =

  • Operations" . Beginning Date = *10/1/1997* , Ending Date = *8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 30 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 i and the associated supporting equipment following the loss of shutdown cooling event. This was the result of inadequate communication of the contingencies estab!ished should a loss of the NSPS bus recur. (Section ,

04.2) 31 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) 32 2/16/1998 NCV IR 98004 NRC Operations 3A 38 5A 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) f ailed to conservatively reduce EDG loading during a surveillance test when indications of an overload condition were identified. (Section 01.2) 33 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 well as the consequences of the loss of the NSPS bus on plant indications and logic inputs. (Section 04.1) 34 2/13/1998 Negative IR 97025 NRC Operations 1A The inability to explain the status of the normally operating fuel building ventilation system was an example of poor awareness of plant conditions by operations personnel. (Section 01.1.b.8) Personnel Performance Deficiency 35 2/13/1998 Negative IR 97025 NRC Operations 1A A 13-day delay in restoring SRMs to an operable status was an example of poor awareness of plant conditions and a lack of operations personnel involvement in restoring Technical Specification equipment to a fully operable status. The avoicable delayin restoration resulted in an unnecessary entry into plant Technical Specification 3.3.1.2 " Source Range Monitor instrumentation." (Section 01.1.b.5) Other/NA 36 2/13/1998 Negative IR 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. (Section 01.1.b.7) Personnel Performance

- Deficiency Page 6 of 18 J

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted tn Date (Descending) and SMM Codes (Ascending): Search Column = "SALP* , SALP Area = " Operations

  • Beginning Date = *10/1/1997* . Ending Data = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 37 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 r restraints. (Section O1.2) Inadequate Procedure / Instruction 38 2/13/1998 Positive IR 97025 NRC Operations 1A An auxiliary operator was knowledgeable of systems and provided good t responses to questions during a tour of the containment, fuel, control, and [ '

auxiliary buildings. (Section 01.4) Teamwork / Skill Level 39 2/13/1998 Negative IR 97025 NRC Operations 2B Several discrepancies were noted during a walkdown of the attemate .

l 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 40 2/13/1998 Negative IR 97325 NRC Operations 2B 1mplementation of Technical Specifications for SRM channel functional <

testing was poor in that operations personnel were unable to initially explain the basis which allowed transfer of the reactor mode switch from shutdown to run. Additiona!!y, 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 01.1.b.5) Personnel Performance Deficiency 41 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 in5 cation associated with Residual i Heat Removal (RHR) Heat Exchanger A following a transfer of shutdown cooling was an example of poor awareaess of plant indications by operations personnelin the main contro' room. (Section O1.1.b.6)

Personnel Performance Deficiency i

Page 7 of 18 i

3/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted tn Date (Descending) and SMM Codes (Ascending): Search Column = "sALP" , sALP Area = ' Operations' , Beginning Date = *10/1/1997" Ending Data = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 42 2/13/1998 Negative IR 97025 NRC Operations 38 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 01.1.b.4) Inadequate Oversight 43 2/13'1998 VIO:SL-IV IR 97025 NRC Operations 3B One violation was identified due to the failure to implement required Technical Specification actions to restore either the Division I or ll 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 44 2/13/1998 Weakness IR 97025 NRC Operations 3B 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 01.1.b.3) Personnel Performance Deficiency 45 2/13'1998 Pos,tive 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 01.3) Teamwork / Skill Level 46 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 imp lement licensing department guidance on acceptable administrative controls associated with Technical Specification 3.5.2.D.3.

(Section 01.1.b.1) Personnel Performance Deficiency 47 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)

Page 8 of 18

3/26M99 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* , SALP Area =

  • Operations
  • Beginning Date = *10/1/1997* , Ending Date = '8/18/1!'98*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 48 2/5/1998 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 Licensing Examination Standards for Power Reactors," Interim Revision 8. January 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) 49 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 with Emergency Operating Procedure (EOP) steps to initiate suppressior' pool cooling -

when required and used alternate 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) 50 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 05.4.c) 51 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 52 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 detail. Applicants were well prepared to take the written examination.

(Section 05.2) 53 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 examinatinns but were not issued operating licenses.

Licenses will be issued upon completion of 10 CFR 55 required reactivity manipulations and all Clinton Power Station training program requirements.

54 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 allowed emergency operation of the diesel fire pump with no jacket cooling water flow to cool the diesel. (Section O3.1) r) age 9 of 18

3/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* SALP Area = ' Operations

  • Beginning Data = *10/1/1997* , Ending Data = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 55 1/23/1998 Negative IP 98006 Self- Operations 1C A design deficiency, material condition issues, and the failure of 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.

56 1/23/1998 Positive IR 98006 NRC Operations SC The operations department's root cause investigation for the reactor scram was thorough and identified severai 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 over1 urn the decision and to ensure that a long-standing operator work-around was appropriately resolved.

57 1/19'1998 LEH LER 97036 Licensee Operations 2A The licensee's engineering staff determined that without the r7otor 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 coo!er causes the associated Division !! shutdown service water pump to be inoperable. It is likely thai the motor shaft key was not installed during initial manufacturing. Other/NA 58 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 inoperaole 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 technical Specifications, therefore the required actions for these monitors being inoperable were not taken. Inadequate Oversight Page 10 of 18

- - - .% -- -.e- As s-e- - - - - . - + + , m - + . - - = = = * - - - -


e -

/26d999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = 'SALP' SALP Area = " Operations" . Beginning Data = *10/1/1997* . Ending Date = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 59 1/5/1998 Weakness 97 SET NRC Operations 1A 1C 4C The SET ttoted that several fire protection issues identified in 1995 had not been effectively addressed, including structural steal components with thermal shorts, inaccessible and inoperable fuel pool i 7 detectors, some fire barrier penetration seals not installed in the control wum, and the potential for a single fire to cause less of offsite power and loss of all diesel generators. The licensee had used an hourly fire watch in lieu of addressing identified problems. 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. ,

60 1/5/1998 Strength 97 SET NRC Operations 1C 3B Fire brigade knowledge and performance were a program strength.

61 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 for program implementation told the SET that only 20 per^ ant 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 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.

62 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 extendet. to an annual inspection. The SET noted mud dauber nests blocking the inside of fire hoses in each of two hose houses opened. Subsequently, the licensee identified a total of 11 fire hoses blocked by mud dauber nests.

The last inspection had been performed in June 1997. The licensee committed to revert to monthly hose house inspections.

Page 11 of 18

o

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted t:y Date (Descending) and sMM Codes (Ascending): Search Colurnn = "sALP" SALP Area = " Operations

  • Beginning Date = *10/1/1997" . Ending Date = '8/18/199B*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 63 1/5/1998 Negat:ve 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 cbserved 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 !!! switchgear room) for automatic fire suppression allowing a reduction in core-damage frequency by a tactor of 266. Although the licensee had evaluated and taken corrective actions for the sprinkler obstructions in the cable spreading rooms, the SET noted :

significant obstructions to sprinkler flow pattems in the Division 111 ,

switchgear room.

64 1/5/1998 Weakness 97 SET NRC Operations 1C 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 seats as inoperable.

65 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. ,

66 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, and correct problems was a majorimpediment 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.

Page 12 of 18

/26/1M9 PLANT ISSUES MATRIX Clinton search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" , SALP Area = " Operations" , Beginning Date = *10/1/1997* , Ending Data = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 67 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 68 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 alternate decay heat removal source (Section 01.2).

Inadequate Oversight 69 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. Specifically, 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 08.1).

Other/NA 70 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 71 12/22/1997 Negative IR 97022 NRC Operations 3B 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 beneficialin 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 Page 13 of 18

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* ; SALP Area =

  • Operations * . Beginning Date = *10/1/1997* , Ending Date = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION j 72 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 operability determination program (Section M8.1).

Inadequate Oversight 73 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 incorrectt:* stated in the corresponding annunciator response procedures (Section O2.1).

Inadequate Procedure / Instruction 74 12/22/1997 Licensing IR 97022 NRC Operations SA NRC involvement was required for licensing personnel to recognize a 10 CFR Part 50.73 reportable condition involving the failure to verify an alternate method of decay heat removal, an operation or condition prohibited by the plant's Technical Specifications (Section O1.2).'

Other/NA 75 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 represented an improvement in the quality assurance organization's ability to perform thorough and probing evaluations (Sections 07.1 and M7.1). Self-Critical 76 12/22/1997 Weakrtess 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 Page 14 of 18

' SSSS PLANT ISSUES MATRIX Clinton Search Sorted t:y Date (Descending) and SMM Codes (Ascending): Search Column = "SALP* , SALP Area = " Operations" , Beginning Date = *10/1/1997* , Ending Date = '8/18/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION

  1. l 77 12/17/1997 LER <R 97030 Licensee Operations 1A On October 26,1997, the operations department discovered that component cooling water (CCW) was not aligned to the "A" reactor water cleanup (RWCU) non-regenerative hest exchanger (NRHX). Technical Specification Limiting Condition for Operation (LC0) 3.4.10 required verification of an available alternate method of decay heat removal for each inoperable RHR shutdown cooling subsystem. The RWCU system was being credited as one of the attemate 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 altemate method of decay heat removal had not been met. Inadequate Procedure / Instruction 78 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 determined to be inoperable due to seismic qualification concems.

Personnel Performance Deficiency 79 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 Civision I and il SX pumps. Other/NA 80 11/7/1997 Positive IR 97023 NRC Operations 3B Licensee controls to revise the licensed operator requalification training program were satisfactory (Section 05.4).

81 11/7/1997 Positive IR 97023 NRC Operations 3B Licensed operator requalification programs were implemented in accordance with 10 CFR Part 55 requirements (Sections O5.3 and 05.6).

82 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 O5.2).

83 11/7/1997 Negative IR 97023 NRC Operations 3B The development of remediation plans lacked a comprehensive root cause analysis for individual performance (Section 05.5).

Page 15 of 18

/26/1999 PLANT ISSUES MATRIX Clinton search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" , sALP Area = " Operations' Beginning Data = *10/1/1997" . Ending Data = '8/18/1998*

I

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION [

84 10/29/1997 LER LER 97024 Licensee Operations 3C On Labor Day weekend, August 30,31, and September 1,1997, Clinton ,

Power Station suspended work that was ongoing to restore Westinghouse 4160 volt safety-related breakers to an operable status.

Suspension of this work was later determined to be in conflict with the Technical Specification Action statements to immediately initiate action to <

restore operability of the affected electrical busses, sources, and/or components. Inadequate Oversight i

85 10/6/1997 Weakness IR 97019 Licensee Operations 3B The failure to activate a readily available alarm and eliminate unnecessary licensed operator trainee system reviews during a reactor  !

vessel level drain down evolution was considered a significant weakness in operator performance. Personnel Performance Deficiency 86 10/6/1997 VIO:SL-IV R 97019/VIO NRC Operations 3C One violation was identified due to a line' assistant shift supervisor failing to properly direct and monitor the activities of the reactor operators such that a drain down of the reactor vessel was promptly identified and corrected. Reactor operators did not properly monitor and control reactor vessellevel in a safe and competent manner. Personnel Performance ,

Deficiency 87 10/6/1997 VlO SL-IV IR 97019/VIO NRC Operations SA One violation was identified due to the failure to provide complete and accurate information to the Commission. Specifically, the response to ,

Notice of Violation 97009-01 stated that corrective actions in response to an inadverte,nt isolation of the reactor water cleanup system had been completed even though the actions were not scheduled for completion until February 15,1998. Inadequate Oversight 88 10/6/1997 Weakness IR 97019 NRC Operations SA During a review of the tagout program, several weaknesses with the implementation of the corrective action program were noted including:

root cause analyses which did not determine why previous corrective actions were ineffective, a lack of quality assurance involvement in deficient areas, a lack of communication between departments prior to extending corrective actions, and extending condition mports beyond 1 year without the approval of the corrective action review board. (Section ,

01.3) Inadequate Oversight 89 10/6/1997 VIO/SL-IV IR 97019/VIO NRC Operations SC One example of a corrective action violation was identified for the failure to prevent the recurrence of eleven near miss tagging events. i Inadequate Oversight .

t Page 16 of 18

/26/1999 PLANT ISSUES MATRIX Clinton search sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP' SALP Area =

  • Operations
  • Geginning Date = *10/1/1997* , Ending Date = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 90 10/6.'1997 Weakness IR 97019 NRC Operations SC The inability to track corrective actions involving responses to NRC violations was a weakness in the licensee's commitment tracking system. Inadequate Oversight 91 10/6/1997 VIO/SL-IV IR 97019/VIO NRC Operations SC One example of a corrective action violation was identified due to the failure to revise procedures associated with the restoration from a Division I bus outage. The untimely corrective action resulted in a second inadvertent isolation of the reactor water cleanup system on August 22, 1997. Inadequate Procedure / instruction 92 10/6/1997 Weakness IR 97019 NRC Operations SC One weakness was identified for the failure to implement corrective actions to ensure proficiency watches were properly credited for senior reactor operators. (Section 08.4) Inadequate Oversight 93 10/6/1997 VIO/SL-IV IR 97019/VIO NRC Operations SC 5A One example of a corrective action violation was identified for the failure to preclude a third loss of service building security lighting. Two root cause analyses were of poor quality in that they did not determine why corrective actions were untimely, not implemented, or ineffective. The delay in initiation of root cause analyses and implementation of corrective actions until receipt of an NRC Notice of Violation was considered a poor corrective action program practice. (Section 08.5) Inadequate Procedure / Instruction Page 17 of 18

3/2S/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS

  1. A counter number used for NRC intemal editing.

The date of the event or significant issue. For those items 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 docurnent that contains the issue information: IR for NRC inspection Report or LER for Licensee Event Report.

ID BY Identification of who discovered the issue - see table.

SALP S ALP 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 Details of the issue from the LER taxt 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 Penatty requirements that are being considered for A - Normal Escalated Enforcement issue - Waiting Final NRC Action escalated enforcement action in accordance B - During Transients eel

  • with the " General Statement of Policy and C - Programs and Processes LER License Event Report to the NRC Procedure for NRC Enforcement Action Licensing Licensing issue from NRR (Enforcement Policy), NUREG-1600. 2 Material Condition:

Misc Miscellaneous (Emergency Preparedness Findir,g. etc.) However, the NRC has not reached its final A - Equipment Condition RCV Non-Cited Violation enforcement decision on the issues 8 - Programs and Processes Negative Individual Poor Lie-'nsee Performance identified by the Eels and the PIM entries 3 Human Performance:

Positive Individual GooUnsee Performance may be modified when tha final decisions A - Work Performance are made. Before the NRC makes its B - Knowledge, Skills, and Abilities i Strength Overall Strong Licensee Performance enforcement decision, the licensee wi!! be U RI,,

C - Work Environment '

Unresolved Inspection item provided with an opportunity to either VIO/SL-I Notice of Violation - Severity Level I (1) respond to the apparent violation or 4 Engineering / Design:

VIO/SL-fl Notice of Victation - Seventy Level II (2) request a predecisional enforcement A - Design VIO/SL-lil Notice of Violation - Severity Level lit conference. B - Engineering Support

  • URis are unresolved items about which C - Programs and Processes VIO/SL-IV Notice of Violation - Seventy Level IV 0 " """

Weakness l Overat: Weak Licensee Performance sue e a 5 Problem identification and Resolution:

acceptable item, a deviation, a A - Identification nonconformance, or a violation. However, B- Analysis lg gy C - Resolution the NRC has not reached its final Licensee The licensed uti! sty conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final Self-Revealed identificatien by an event (e.g., equipment breakdown) conclusions are made.

Other Identification unknown Page 18 of 18

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" . SALP Area = " Maintenance" , Beginning Date = *10/1/1997* , Ending Date = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION f 1 7/10/1998 ED IR 98011 Licensee Maintenance 28 One violation for which enforcement discretion was exercised was identified concerning the failure to ensure an adequate procedure was used during testing of the high pressure core spray discharge isolation valve. The inspectors concluded that some procedural adequacy and adherence problems continued to occur at the facility. (NCV 50-461/98011-05).

2 7/10/1998 ED IR 98011 Licensee Maintenance 2B One violation for which enforcement discretion was exercised was identified for the failure of operations personnel to implement procedural requirements while performing troubleshooting activities on the logic for the outboard main steam isolation valves (MSIVs) and on main control room panel P-680.(NCV 50-461/98011-03).

3 7/10/1998 ED IR 98011 Licensee Maintenance 2B 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 meteorological monitoring tower and a process radiation monitor prior to returning the equipment to an operable 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).

4 7/10/1998 Negative IR 98011 NRC Maintenance 3B 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 5 7/10/1998 ED IR 98011 Licensee Maintenance SC One vic!ation 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 50-461/98011-06).

Page 1 of 7

/26/1999 PLANT ISSUES MATRIX Clinton Search Sor'ed by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP' , SALP Area = " Maintenance * , Beginning Date = *10/1/1997* , Ending Date = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 6 5/28/1998 ED IR 98008 NRC Maintenance 1C 2B 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 discovcry on June 18, 1996, and initial performance of the implementing surveillance procedure on December 1,1996.

7 5/28/1998 Weakness IR 98008 NRC Maintenance SA The inspectors determined that quality assurance inappropriately 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 indicators, and results from Task Performance Check Lists were not consistent with results from other performance monitoring systems.

8 5/10/1998 ED 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 probiems concerning the licensee's attention to the backup meteorological tower.

Specificallv, a 6-month preventive maintenance surveillance was schedulea for January 22,1998, but had not been performed.

9 5/7/1998 ED IR 98008 NRC Maintenance 3A The inspectors concluded that procedures were not adequately adhered to when maintenance workers failed to return 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 10 5/1/1998 ED 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-related motor power feed wire to monitor various parameters.

NCV 50-461/98008-04 11 5/1/1998 ED 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 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)

Page 2 of 7

/26/1999 PLANT ISSUES MATRIX Clinton Search Scrted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" , SALP Area = " Maintenance' , Beginning Date = *10/1/1997' . Ending Date = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 12 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.

13 4/14/1998 Positive IR 98006 NRC Maintenance 2A The visible condition of 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.

14 4/14/1998 Positive IR 98006 Licensee Maintenance 2B One example of good questioning attitude was identified when operations l personnel stopped a surveillance to address the impact of a leaking equalizing valve on a flow instrument used during testing. i 15 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 operability was not assured.

16 3/3/1998 NCV IR 98003 NRC Maintenance 28 3A Provisions of the maintenance troubleshooting procedure were not implemented during testing of the Division 11 EDG kilowatt indication.

E pecifically, 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, electrica! maintenance work practices were poor, and supervisory oversight was minimal (Section M1.2).

17 3/3/1998 Positive IR 98003 NRC Maintenance 3B 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 l learned from other utilities (Section M1.3).

18 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) 19 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 Service Water (SSW) Pump Room A Supply Fan motor without having the ~

appropriate parts on site, without having all parts approved through an accredited quality assurance program, and without having a method for greasing the motor bearings prior to installation. (Section M1.4)

Inadequate Oversight Page 3 of 7

/26/im PLANT ISSUES MATRIX Clinton Search Sorted by Date tDescending) and SMM Codes (Ascending): Search Column = "SALP" . SALP Area = " Maintenance * . Beginning Date = *10/1/1997* . Ending Date = '8/18/1998*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 20 2/13/1998 Positive IR 97025 NRC Maintenance 3A Maintenance personnel demonstrated good procedure usage during functional testing of the Division ill 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 21 2/13!1998 NCV IR 97025 NRC Maintenance 3C One example of a non-cited violation was identified for the failure to follow procedures involving the installation of an isoiation 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 22 2/13/1998 Positive IR 97025 Licensee Maintenance 5A An audit conducted by quality assurance involving receipt inspections and shelf life determinations identified several 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 23 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).

24 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 of the outage schedule. This item will be reviewed as part of the NRC 0350 Panel oversight of licensee improvement programs (Section 01.1).

Inadequate Procedure / Instruction 25 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 Page 4 of 7

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Colurnn = 'SALP" , SALP Area = " Maintenance

  • Beginning Date = *10/1/1997* . Ending Date = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION ,

26 12/22/1997 VIO/SL-IV IR 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 use of portable tachometers ,

prior to using the tachometers in the field (Section M1.2). Inadequate Procedure / Instruction 27 12/22/1997 Negative IR 97022 NRC Maintenance 2B 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 (Section M1.3). Inadequate Procedure / Instruction 28 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 29 12/22/1997 Weakness IR 97022 NRC Maintenance 5A The licensee's corrective actions in response to a previnusly identified '

motor over greasing issue were narrowly focused and untimely in that multiple departments f ailed to recognize the potential generic implications of the over greasing issue until seven weeks after the initial concern was identified (Section M8.1). Other/NA 30 12/15/1997 Weakness LER 97031 Licensee Maintenance 2B Logic circuit overlap testing did not adequately cover portions of the logic circuitry as required by the Technical Specification (TS) Surveillance 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 Drywell isolation Instrumentation. Futher, overlap testing did not adequately cover a portion of the logic circuitry for the thermal 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 31 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 bearings. Other/NA 32 10/11/1997 eel IR 97020/EA 97- NRC Maintenance 1C One apparent violation was identified for not controlling the use of 467 consumable materials which resulted in the failure of multiple safety-related components. Inadequate Procedure / Instruction Page 5 of 7

' S' SSS PLANT ISSUES MATRIX Clinton

- search Sorted by Date (Descending) and sMM Codes (Ascending): Search Column = *SALP" , SALP Area = " Maintenance * , Beginning Date = *10/1/1997* , Ending Date = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 33 10/11/1997 eel IR 97020/EA 97- NRC Maintenance 3C One apparent violation was identified due to the failure to pn. vide 467 procedural guidance commensurate with the knowledge, skills, and abilities of personnel performing neon indicating light replacement activities. The assignment of inexperienced personnel to perform this work demonstrated poor oversight by maintenance management.

Inadequate Procedure / instruction 34 10/11/1997 Negative IR 97020 NRC Maintenance SA The root cause evaluation for neon indicating light failures was an improvement over past root cause analyses. However, the root cause analysis only addressed the specific equipment failure and did not address ineffective management oversight, the poor quality of engineering evaluations, and the lack of control of consumable materials. Self-Critical 35 10/6/1997 VIC/SL-IV IR 97019NIO Self- Maintenance 2B 3B One violation was identified for the failure to provide guidance which was Revealed commensurate with the knowledge, skills, and abilities of electrical :

maintenance individuals performing the lubrication of the Division 111 Shutdown Service Water Pump. This was the third example in 4 months where technicians were unable to competently perfonn " tool box skills."

(Section M1.3) Inadequate Procedure / Instruction Page 6 of 7 l

__x 3/26h999 GENERAL DESCRIPTION OF PIM TABLE LABELS c A counter number used for NRC intemal editing.

The date of the event or significant issue. For those items 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 Th 3 categorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IR for NRC Inspection Report or LER for Licensee Event Report.

ID BY Ident:fication of who discovered the issue - see table.

SALP S ALP 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 Details 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 Jiscretion - No Civil Penalty requirements that are being considered for A - Normal escalated enforcement action in accordarice B - During Transients eel

  • Escalated ', nforcement issue - Waiting Final NRC Action with the " General Statement of Policy and C - Programs and Processes LER License Evect Report to the NRC Procedure for NRC Enforcement Action Liesnsing Licens ng issue .'.om NRR (Enforcement Policy), NUREG-1600. 2 Material Condition:

Misc Miscellaneous (Emergency Preparedness Finding. etc.) However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes Nrgative individual Poor Licensee Performance identified by the Eels and the PIM entries 3 Human Performance:

Individual Good Licensee Performance may be modified when the final decisions A - Work Performance  !

Positive are made. Before the NRC makes its B - Knowledge, Ski!!s, and Abilities Strength Overall Strong Licensee Performance enforcement decision, the licensee will be C - Work Environment URI,* Unresolved I.ispection item provided with an opportunity to either VIO/SL-I Notice of Violation - Severity Level I (1) respond to the apparent violation or 4 Engineering / Design:

VIO/SL-il Notice of Violation - Severity Level 11 (2) request a predecisions! enforcement A - Design Notice of Violation - Severity Level 111 conference. B - Engineering Support VIO!SL-ill

" URis are unresolved items about which C - Programs and Processes VIO/SL-IV Notice of Violation - Severity Level IV determine Weakness Overa l Weak Licensee Performance h e se qu o s acceptable item, a deviation, a A - Identification nonconformance, or a violation. However, B - AnaWis ID BY C - Resolution the NRC has not reached its final Licensee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the fina!

S Elf-Rtvealed Identification by an event (e.g., equipment breakdown) conclusions are made.

Othtr identification unknown Page 7 of 7

-_ _ _ a__ a ,- _ _ + _ _ _ - * - _ _ . _ _ _ __m_.- _____m_-.___ _ _._m__b

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP* , SALP Area = *Engrneering , Beginning Date = *10/1/1997* : Ending Date = 8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1 7/10/1998 Negative IR 98011 NRC Engineering 4B The adequacy of information provided in engineering and operability evaluations was mixed. Engineering personnel provided an adequate basis for continued operation of the residual heat removal 8 and C water leg pump. However, engineering personnel did not initially provide an adequate basis for the automatic transfer of the Division Ili 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.

2 7/10/1998 Negative IR 98011 Licensee Engineering SA 48 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 the generic implications of uncalibrated instrumentation on continued plant operations was not initiated until prompted by NRC inspectors.

3 5/10/1998 Positive IR 98010 Licensee Engineering 1C 4B The system engineer performed good trending of system operability for the primary meteorological tower. The calibrations and surveillances for the primary meteorological tower were properly performed.

4 3/27/1998 VIO SL-IV 1R 98007 NRC Engineering 48 One violation was identified conceming an inadequate 10 CFR 50.59 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 B, did not address the leak detection function that was attributed to the monitors by the Updated Safety Analysis Report 5 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 allowed DFT 6 3/3/1998 Negative IR 98003 NRC Engineering 3A 3B SA The shift supervisor's review of condition report 1-97-12-221 involving inadequate testing of RTDs and the diesel ventilation system was poor and lacked intrusiveness in that it was not properly classified, it did not consider possible generic implications on other plant equipment, and it did not ensure that an appropriate tracking mechanism was in place to prevent an EDG from being returned to an operable status prior to resolving the issue (Section E1.2).

Page 1 of 5

- + #__

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and sMM Codes (Ascending): Search Colurnn = *sALP" . sALP Area =

  • Engineering
  • Beginning Date = *10/1/1997* , Endog Date = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 7 3/3/1998 NCV IR 98003, LER- NRC Engineering 4A Design basis information involving ambient outside air temperature was 1 97002 not translated into specifications which effected the service life of EDG i components, and resulted in the Division 111 EDG being inoperable when t outside air temperatures exceeded 91 F (Section E1.1).

8 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 unreviewed 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).

9 3/3/1998 NCV 1R 98003 Licensee Engineering 4A Design basis information regarding the proper electricalisolation between Class IE and non-Class IE components was not translated into a modification package for replacing the Division I and 11 EDG annunciator power supplies. This resulted in improper electricalisolation between l non-Class IE and Class IE EDG circuitry for approximately six years and created an unreviewed safety question which may have prevented the Division I and l' EDGs from operating when outside air temperatures exceeded 91 F (Section E1.1).

10 3/3/1998 Negative IR 98003 NRC Engineering 4A R Engineering personnel did not recognize the significance of extreme outside air temperatures on EDG cperability. After prompting by the NRC inspectors, an appropriate engineering evaluation was performed (Section E1.1).

11 3/3/1998 NCV IR 980N NRC Engineering 4A 4C No testing of resistance temperature devices (RTDs) within the diesel ventilation 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).

12 1/28/1998 NCV IR 98006 Licensee Engineering 58 Engineering, operations, and work control personnel failed to appropriately implement the requirements of Technical Specification 5.5.7, " Ventilation 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.

Page 2 of 5

/26/1 % 9 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP* SALP Area =

  • Engineering , Beginning Date = *10/1/1997* . Ending Date = 8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 13 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 electrical bus loading '

conditic is associated with a Loss of Coolant Accident block start.

Improrser 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 14 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 fu!I 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 15 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 RC!C tank leve! instrumentation  !

standpipe, located outside of a missile protected building, were not designed to withstand missiles generated by a design basis tornado.

Engineering / Design Deficiency 16 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-Une safety-related circuit breakers were not sufficient to withstand the expected dose rates I following a worst case loss of cooling accident. Other/NA 17 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 18 12/4/1997 LER LER 97027 Licensee Engineer;ng 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, further 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 i

Page 3 of 5

3/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP* ; SALP Area =

  • Engineering" . Begir.teg Data = *10/1/1997* . Ending Date = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 19 10/28/1997 LER LER 97025 Licensee Engineering 4A A hot short could potentially cause motor operated valves (MOVs) required for safe shutdown of *he plant from the remote shutdown panel to spuriously operate, bypassing the MOV control circuitry protective features. When the MOV control circuit protective features are bypassed, -

the potential exists for the valve to be damaged to the extent that the valve could not be operated. Engineering / Design Deficiency 20 10/6/1997 Weakness IR 97019 NRC Enginecting 4A Three discrepancies with the Updated Safety Analysis Report were identified involving alarm set points n'ssion of sensitivity studies, and the de'ection capability of radiction monitors. (Section E8.1) Other/NA 21 10/6/1997 NCV 1R 97019 Self- Engineering 4B A non-cited violation was identified for the failure to maintain required Revealed technical specification indications for leakage detection systems.

Engineering / Design Deficiency Page 4 of 5

3/26/1999 GENERAL DESCRIPTION OI FIM TABLE LABELS

  1. A counter number used for NRC intemal editing.

The date of the event or significant issue. For those items 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 information: IR for NRC Inspection Report or LER for Licensee Event Report.

ID BY 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 Details of the issue frt,m the LER text or from the IR Executive Summaries.

l TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements Eels are apparent violations of NRC 1 Operational Performance: i ED Esca!ated Discretion - No Civil Penalty requirements that are being considered for A - Normal Escalated Enforcement issue - Waiting Final NRC Action escalated enforcement action in accordance B - During Transients EEI' C - Programs and Processes LER License Event Report to the NRC with the

  • General Statement of Policy arjd .

Procedure for NRC Enforcement Action Lictnsing Licensing tssue from NRR (Enforcement Policy). NUREG-1600. 2 Material Condition:  !

Misc Misce!!aneous (Emergency Preparedness Finding. etc.) However, the NRC has not reached its final A - Equipment Condition j Non-Cited Violation enforcement decision on the issues B - Programs and Processes NCV N?gative Individual Poor Licensee Performance identified by the Eels and the PIM entnes 3 Human Performance:

may be modified when the final decisions A - Work Performance Positive Individual Good Licensee Perforrr.ance are made. Before the NRC makes its B - Knowledge, Ski!!s, and Abilities Strength Overall Strong Licensee Performance enforcement dec,s,on, the licensee will be ii C - Work Environment i URl** Unresolved Inspection item provided with an opportunity to cither VIO/SL-1 Notice of Violation - Severity Level I (1) respond to the apparent violation or 4 Engineering / Design:

VIO/SL-il Notice of Violation - Severity Level 11 (2) request a predecisional enforcement A - Design Notice of Violation - Severity Level ill conference. B - Engineering Support VIO/SL-Ill

" URis are unresolved items about which C - Programs and Processes VIO/SL-IV Nottce et Violation - Severity Level IV Weakness Overail Weak L ensee Performance wh e e q st sa 5 Problem identification and Resolution:

accaptable item, a deviation, a A - identification nonconformance, or a violation. However, B - Analysis lg gy C - Resolution the NRC has not reached its fhal Licensee The licensed utility conclusions on the issues, t.n l the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final S:lf-Revealed identification by an event (e g. equipment breakdown) conclusions are made.

Other Identifica'icn unknown Page 5 of 5

/26M999 PLANT ISSUES MATRIX Clinton search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP' , SALP Area = " Plant Support' . Beginning Date = *10/1/1997" . Ending Date = '8/18/1993*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1 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.

2 6/25/1998 Positive IR 98013 NRC Plant 1C Air sampling activities for the containment a'id orywell 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.

3 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 it, 4 air samplers and associated sample analysis results. These areas were being addressed by the licensee 4 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.

5 5/10/1998 Positive IR 98010 NRC Plant 1C The radiation protection staff properly implemented the extemal dosimetry 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.

6 5/10/1998 Negative IR 98010 NRC Plant 1C The 1spector identified problems in the documentation of quality control Support test results and corrective actions performed during routine thermoluminescont dosimeter processing.

7 5/10/1998 Negative IR 98010 NRC Plant 1C The .adiation 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 sorr.a reduction in radiation worker problems was noted, the inspector observed that radiation worker practices and RP technician 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.

Page 1 of 10

3' 6"S89 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descendeng) and SMM Codes (Ascending): Search Column = *SALP" , SALP Area =

  • Plant Support' , Beginning Date = *10/1/1997* , Ending Data = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 8 5/10/1998 Posi'ive IR 98010 NRC Plant 1C 5A 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.

9 5/10/1998 Positive IR 98010 NRC Plant 1C SA Environmental sample results did not indicate any discernable 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 a' samplers.

10 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 building. 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 properly posted. I 11 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 maintaine'i ALARA. With the exceptior of one individual's total effect?ve dose equivalent (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 i errors in the licensee's quarterly comparisons of doses measured via thermoluminescent dosimeters and electronic dosimeters.

12 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 a.. radiation protection technician. The licensee performed a thorough investigation of the t incident and implemented immediate corrective actions.

Page 2 of 10 .

/28/im PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" , SALP Area = " Plant Support" , Beginning Date = *10/1/1997" ; Ending Data = '8/18/199B*

  1. l DATE TYPE SOURCE ID BY SALP f SyM CODES DESCRIPTION f 13 5/10/1998 Negative IR 98010 NRC Plant 3B The inspector identified some problems conceming technician knowledge Support level and techniques. In addition, performance problems conceming well water compositors were not fully evaluated by the radiation protection sta'f to ensure that a representative sample was obtained.

14 5/8/1998 Positive IR 98009 NRC Plant 1B A timely and comprehensive critique of the Emergency Response Support Organization performance was held following the loss of shutdown cooling event.

15 5/8/1998 VIO/SL-IV IR 98009 NRC Plant 1B !n one case, on-shift staffing was inadequate during the 2/13/98 event, Support because only one cf two mechanical maintenance workers on site was appropriately trained. This was a violation.

16 5/8/1998 Positive IR 98009 NRC Plant 1B 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.

17 5/8/1998 Negative IR 98009 NRC Plant 1B Initial .1otifications of the Alert on 2/13/98 were made in a timely manner Support but contained some inaccurate meteorological information.

18 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. ,

i 19 5/8/1998 VIO'SL-iV 1R 98009 Self- Plant 1B 1C The Emergency Response Data System was not initiated within the Revealed Support required timeframe of one hour after the Alert on 2/13/98 was declared.

This was a violation.

20 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.

21 5/8/1998 Positive IR 98009 NRC Plant 1C An excellent decision was made to continue the Emergency Operations 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 projection could not be performed in the EOF due to backup fa.itures. All emergency exit lighting failed almost immediately. Emergency power supplies failed quickly, well before expected failure times.

Page 3 of 10

3'26/1999 ;

PLANT ISSUES MATRIX Clinton Seach Sorted by Date (Descending) and SMM Codes (Ascending): Search Coturnn = "SALP" SALP Area =

  • Plant Support" Beginning Date = *10/1/1997* , Ending Data = '8/18/1998*

!# DATE TYPE ll SOURCE ID BY SALP SMM CODES DESCRIPTION 22 5/8/1998 Positive IR 98009 NRC Plant 1C Overall, the Emergency Preparedness program has been generally Support maintained in an adequate state of operational readiness. Emergency response facilities, equipment, and supplies have generally been adequately maintained, with some exceptions.

23 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 f acility access, but security had to call the '

main corerol room for access approval for some personnel ~a potential distraction at a critical time.

24 5/8/1998 Negative IR 98009 NRC Plant 1C 2B The material condition of t *aical Sun-u Center (TSC) was Support marginal, as was noted in the io.. inspection. The failure of the TSC ,

backup dose assessment laptop computer to function indicated that its test frequency was not adequate.

25 5/8'1998 Positive IR 98009 NRC Plant SA 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, but were weak in the area of equipment maintenance, particularly considering identified equipment operability problems.

1 26 4/14/1998 Positive IR 98006 NRC Plant 1C The fire brigade responded prompt!y during the performance of a fire Support drill 27 4/7/1998 Negative IR 98006 Licensee Plant 3A Numerous ernergency response personnel failed to respend several Support pager tests. Specifically, only 1 of 6 pager tests had 100 percent response from emergency response personnei.

28 3'27/1998 Negative IR 98007 NRC Plant 1C The inspector found radiological hazards in the radiologically controlled 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 radioactivei, ontaminated areas.

29 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 concerning the basis for waiving an employment termination whole body count Page 4 of 10 L________- __

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Colurnn = "SALP" . SALP Area = " Plant Support" , Beginning Date = "10/1/1997* , , Data = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 30 3/27/1998 Negative IR 98007 NRC Plant 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 31 3/27/1998 Negative IR 98007 NRC Plant 1C 2B 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 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 identified and resolved by the staff. -

32 3/27/1998 Negative IR 98007 NRC Plant 5A 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 monitorindications were generally  ;

consistent, the inspector identified problems conceming the RP staff's j routine review of radiation monitor performance, which included the  ;

identification and resolution of anomalous monitor responses  ;

33 3/27/1998 Positive IR 98007 Licensee Plant SB The licensee performcd a comprehensive review of the design basis of l 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 '

replace the radiation monitor console in the control room and to ins * !!

monitor readout capabilities in the RP area and in the technical support center Page 5 of 10 i

/26/1999 PLANT ISSUES MATRIX Clinton ,

Search Sorted t y Date (Descending) and sMM Codes (Ascending): search Column = *sALP* , sALP Area =

  • Plant support' , Beginning Date = *10/1/1297* , Ending Date = '8/18/1998*
  1. DATE ITYPE SOURCE l lD BY SALP SMM CODES l DESCRIPTION 34 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 determine the proper trip setpoints '

for the main steam line radiation monitors. Although the licensee identified and corrected the deficiency in 1997, the RP staff had noted the problem in 1990 but did not completely assess and resolve the issue.

35 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 36 2/13'1993 Negative IR 97025 NRC Plant 3A One example of an individualincorrectly processing through a PCM-18 Support was identified. (Section R4.1) Personnel Performance Deficiency 37 2/2/1999 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 38 2/2/1998 NCV IR 98002 NRC Plant 2B The licensee maintained effective oversight of the respiratory protection Support program and implemented numerous program improvements. Required !

surveillances and maintenance were completed as required, and the equipment was in good working order. Perscnnel using the equipment j were properly trained, medically qualified, clean-shaven, and properly fit- ,

tested. However, one non-cited violation was identified concerning the i failure of plant security force members and supervisors to maintain their required respiratory protection qualifications (Section R1.1). Involved Management ,

39 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 indiccting i the need for additional review of procedures (Section R3.1). Inadequate Procedure / Instruction 40 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 (Sectiw R1.3). Teamwork / Skill Level Page 6 of 10

' S '"

PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP' , SALP Area = " Plant Support' , Beginning Date = *10/1/1997 . Ending Data = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION l 41 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 determine whether the use of respiratory protection would maintain the total effective dose equivalent as-low-as-is-reasonably-achievable (ALARA) (Section R1.2). Teamwork / Skill Level 42 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 43 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 performahce-based and compliance-based observations and identified issues, which were being resolved by the RP staff (Section R7.1). Self-Critical 44 2/2/1998 Weakness IR 98002 NRC Plant SA The licensee had difficulty maintaining operability of the area and process Support radiation monitoring (AR/PR) equipment. Although the staff recognized the problem 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 inspectors concluded that (1) there was a lack of clear, reliable indication of AR/PR readings in the main control room; (2) frequent nuisance alarms were distracting operators from their ass. ned 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 these problems remained uncertain (Section R2.1). Inadequate Oversight 45 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 Page 7 of 10

.... -n, n

/2sn999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Searth Column = "SALP" , SALP Area = " Plant Support' Beginning Date = *10/1/1997* : Ending Data = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 46 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 administe ;d.

(Section S1.1) Personnel Performance Deficiency 47 1/2/1998 Negative IR 97024 NRC Plant 3B 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 48 12/22/1997 Positive IR 97022 NRC Plant 1B The shift supervisor's efforts to provido 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 decisior making processes (Section P1.1).

Other/NA 49 12/22/1997 Weakness IR 97022 NRC Plant 18 3B Performance in the technical support center during the off hours exercise Support was poor in that persor.nel 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 informal communications (Section P1.1). Personnel Performance Deficiency 50 12/22'1997 Weakness IR 97022 NRC Plant 1B 3B A number of problems were identified with operator performance during Support the off hours emorgency 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 prucedures, did not effectively communicate priorities, and did not perform periodic site wide announcements (Section P1.1).

Personnel Performance Deficiency Page 8 cf 10

/261999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Coturnn = "SALP" ; SALP Area =

  • Plant Support" ; Beginning Date = *10/1!1997* ; Ending Date = '8/18/1998*
  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 51 12/22/1997 Negative IR 97022 NRC- Plant 1C During the drill, the shift supervisor / command authority did not consult Support with security personnel to determine if an attemate response location should be established for personnel in the emergency response organization. This was considered significant 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 52 12/22/1997 Weakness IR 97022 NRC Plant 5A Licensee drill observers did not critically assess performance during the 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 53 19/6/1997 Weakness IR 97019 NRC Plant SC 5A Several weaknesses with the implementation of the corrective action Support program were noted including: the completion of root cause analyses which did not determine why previous corrective actions were ineffective, poor integration of quality assurance (OA) findings, a lack of OA involvement during the closure of condition reports initiated by OA inspectors, and poor trending of deficient conditions. (Section R8.1)

Inadequate Oversight Page 9 of 10

_ . . .. - - - . .. ~ ._ . =. . . . .

3/26/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS

  1. - A counter number used for NRC internal editing. l The date of the event or significant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date ,

DME 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 information: 1R for NRC Inspection Report or LER for Licensee Event Report. p ID BY 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 Details 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 Escalatr J Discretion - No Civil Penalty requirements that are being cunsiderr d for A - Norma!

eel

  • Escale ed Enforcement issue - Waiting Final NRC Action escalated enforcement action in accordance B - During Transients w neral mammm d Mcy ap C - % grams and hesses LER Licen;e Event Report to the NRC Procedure for NRC Enforcement Action Licensing Lier ising issue from NRR (Enforcement Policy), NUREG-1600. 2 Material Condition:

Misc Miscellaneous (Emergency Preparedness Finding. etc.) However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the imes B - Programs and Processes N!gative Individual Poor Licenseo Performance identified by the Eels and me PIM entries - 3 Human Performance:

Positive Individual Good Licensee Performance may be modified when the final decisions A -Work Performence are made. Before the NRC makes its B - Knowledge, Skills, and Abilities Strength Overati Strong Licensee Performance enforcement decision, the licensee will be C - Work Environment URI,, Unreserved Inspection item provided with an opportunity to either VIO/SL-l Notice of Violation - Severity LevelI (1) respond to the apparent violation or 4 Engineering / Design:

VIO/SL-II Notice of Violation - Severity Level ll (2) request a predecisional enforcement A - Design VIO/SL-Ill Notice of Violation - Severity Level ill conference. B - Engineering Support

    • URis are unresolved items about which C - Programs and Processes VIO/SL-IV Notice of Violation - Severity Level IV Weakness Overalt Weak Licensee Performance [h e e quest nsa 5 Problem Identification and Resolution:

acceptable item, a deviation, a A - Identification nonconformance, or a violation. However, B - Analysis ID BY C - Resolution the NRC has not reached its final Licensee The licensed utility conclusions on the issues, and the PIM i NRC The Nuclear Regulatory Commission entries may be modified when the final  ;

Self-Revealed identification by an event (e.g.. equipment breakdown) conclusions are made.  ;

Other Identification unknown ,

i i

Page 10 of 10

/26/1999 PLANT ISSUES MATRIX Clinton Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* , SALP Area = *All/ Multiple" Beginning Date = *10/1/1997* , Ending Data = '8/18/1998*

  1. l DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1 1/5/1998 Weakness 97 SET NRC All/ Multiple 1C 3B 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 end integrated effects of the decisions.

Management did not ensure that there were appropriately qualified staff, integrated programs and processes, and appropriate resources to support implementation of the reengineering and downsizing effort.

2 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.

3 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 implement effective performance  :

standards was a root cause of the significant dect:ne in safety performance. Management fa!!ed to establish and communicate appropriate, clearly defined expectations and priorities, and failed to monitor 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.

4 10/11/1997 eel IR 97020/EA 97- NRC Ali/ Multiple 1A One apparent violation was identified for the failure to implement 467 corrective actions for multiple failures of safety related components.

Maintenance, operations, and management did not recognize the significance of multiple safety-related component failures. The failure to take prompt and effective corrective actions demonstrated a lack of ,

ownership in the facility, a poor questioning attitude, and a willingness to accept substandard workmanship. Conservative Decision Page 1 of 3 i

w_- _ _m._--_____

^ _ _ _ _ - _ _ . - _ _ _ _ _ _ - _ _ - _ _ _ _ _ m_ __ _ _ _ . - - - _ __ -

<2elim PLANT ISSUES MATRIX Clinton Search sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* , SALP Area = J/ Multiple * , Beginning Date = *10/1/1997* , Endhg Date = '8/18/1998*

  1. DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 5 10/11/1997 Weakness IR 97020 NRC All/ Multiple SC Management demonstrated poor oversight of the corrective action program in that the initiation of efforts to determine the causes for inadequate control of consumable materials were delayed until August 1997, even though deficiencies were noted in February and June 1997.

Inadequate Oversight S 10/6/1997 Positive IR 97019 Licensee All/ Multiple 3C The plant manager declared a site wide stand down on September 11,

  • 1997, due to an increase in personnel errors. involved Management i

l Page 2 of 3

3/26/1999 GENERAL DESCRIPTION OF PIM TABLE LABELS

  1. A counter number used for NRC intemal editing.

The date of the event or significant issue. For those items 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 information:. IR for NRC Inspection Report or LER for Licensee Event Report.

ID BY identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering. Maintenance, Operations Plant Support and Alliluttiple (i.e., more than one SALP area affected).

SMM CODES Senier Manager Meeting Codes - see table.  ;

DESCRIPTION Details 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 Opectional Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal eel

  • Escalated Enforcement issue - Waiting Final NRC Action escalated enforcement action in accordance B - During Transients with the " General Statement of Policy and C - Programs and Processes LER License Event Report to the NRC Procedure for NRC Enforcement Action i Licensing L.icensing issue from NRR (Enforcement Policy), NUREG-1600. 2 Material Condition:

Misc Miscellaneous (Emergency Preparedness Finding. etc.) However, the NRC has not reached its final A - Equipment Condition  ;

NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes ,

N tgative Individual Poor Licensee Performance identified by the Eels and the PIM entries 3 Human Performance:

Positive Individual Good Licensee Performance may be modified when the final decisions A - Work Performance Strength Overall Strong Licensee Performance

' made. Before the MRC makes its B - Knowledge, Skills, and Abilities enforcement decision, the licensee will be C - Work Environment U Rl" Unresolved inspection item provided with an opportunity to either VIO/SL-l Notice of Violation - Severity Level I (1) responti to the apparent violation or 4 Engineering / Design:

A - Design VIO/SL-tl Notice of Violation - Severity Level II (2) request a predecisional enforcement VIO/SL-ill Notice of Violation - Seventy Level 111 conference. B - Engineering Support Notice of Violation - Severity Level IV ** URis are unresolved items about which C - Programs and Processes VIO/SL-IV O " " "

Weakness Overall Weak Licensee Performance 5 Problem Identification and Resolution:

e e e o s acceptable item, a deviation, a A - Identification i nonconformance, or a violation. However, B - Analysis 1 ID BY C - Resolution the NRC has not reached its final '

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 Identefication by an event (e.g., equipment breakdown) conclusions are made. j Other Identification unknown Page 3 of 3

CLINTON INSPECTION / ACTIVITY PLAN IP - Inspection Procedure ,

Tl - Temporary Instruction Core - Minimum NRC inspection Program (mandatory all plants)

Regional Initiative - Discretionary inspections NUMBER OF TYPE OF INSPECTION NRC INSPECTION /

/ TITLE / PROGRAM AREA INSPECTORS / PLANNED DATES ACTIVITY-ACTIVITY INDIVIDUALS COMMENTS IP93802 Operational Readiness 5 March 29 - Apr 3,1999 Regional Initiative @

IP81700 Security (SEC2) 1 March 1 - 5,1999 Core IP82301 Special Emergency Prcparedness 4 March 9 - 12,1999 Regional Initiative 2 IPS2302 Exercise 84750 Radiation Protection / Chemistry 1 June 28 - July 2,1999 Core IP73753 Inservice inspection 1 June /July 1999 Core IP82701 Emergency Preparedness 1 July 19 - 23,1999 Regional Initiative @

Program Maintenance IPS1700 Security (SEC1) 1 July 19 - 23,1999 Core IP81110 Security OSRE 1 November 15 -19,1999 Special IP71707 Control Room Oversight 7 During Restart Regional Initiative IP71001 Licensed Ooerator Recual 2 October 4 - 8 1999 Core Notes.

1 Followup on previous concerns and determination of operational readiness for unit restart.

2 Followup on previously identified concerns.

5