ML20212B587

Discusses Concerns Re Fuel Load Readiness,Including Facility Mgt & Staff to Operate & Maintain Plant at Powers Greater than 5%.Mgt Reluctant to Make Improvements on Own Initiative

ML20212B587
Person / Time
Site:	Clinton
Issue date:	07/30/1986
From:	Dupont S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20212B581	List: ML20212B578 ML20212B587
References
NUDOCS 8608070172
Download: ML20212B587 (3)

Text

b ventan svaras g NUCLEAR REGULATORY COMMIS$loN

1. k sit e 0 N lll

[

g

} .

vos moosavatv mono sten attyw. itunon mat JUL s a gggg MEMORANDUM FOR: Mark A. Ring, Chief Test Programs Section Stevie G. DuPont, Reactor Inspector, Test Programs Section FROM:

SUBJECT:

CONCERNS RELATED TO CLINTON READINESS FOR FUEL LOAD On July 18, 1986, Mr. A. Bert Davis discussed with me Clinton's preparedness for fuel load and any concerns that I might have with licensing of Clinton in August. In general, I did not have any new technical concerns that might delay a license to load fuel; however, I did have concerns with Clinton's management and staff pertaining to operating and maintaining Clinton at powers greater than 5%. These concerns are as follows:

1. Clinton's management is reluctant to tde improvements on their own initiative.

a. Since January 1986, we have discussed with the Manager-CPS and hisis Their program staff the inadequacies of their turnover program.

in three parts--a " Phase II" release which transfers jurisdiction of a system from startup to plant staff, a " Ready to Support Fuel Load" category which detennines that a system is in a condition to support This does not mean that the system is operation and fuel load.

" Operable" as defined in Technical Specifications but that the system has been tested and that the outstanding open items related to that system are manageable. Finally, some, but not all, systems will be declared " Technical Specifications Operable" after the systems' Mode 4 or 5 surveillances and checklists have been completed. Only the systems determined by Clinton to be needed Allfor I

fuel load,will complete all three phases prior to fuel load.

other systems will be declared " Technical Specifications Operable" prior to those systems being required to be operable by Tech Specs.

We have had concerns with this program because the first two parts did not have any acceptance criteria for " Phase II" or " Ready to Support Fuel Load" turnovers. Only recently did Illinois Power Company include any acceptance criteria in the program and even now it only applies to the Technical Specifications Operable portion of the program. We found that management was reluctant to change the Additionally, first two portions of the program for six months.

this change has only been in effect since about July II,1986.

b. In February 1986, the maintenance procedures for the station batteries were identified to the licensee as being inadequate by not meeting the requirements of IEEE-450 (1975) and by not adhering to ge0{g %

( A

3

, L- ; .

2 Mark A. Ring JUL s o ngg the cautions and warnings of the vendor manual. Six to eight weeks later, three violations and one deviation were issued because no actions had been taken, and the condition of the safety related batteries had degraded from their condition after preoperational testing.

c. Similar conditions related to housekeeping problems with the batteries were also found in the Diesel Generator rooms on June 16 through 18,1986. During a tour on the 16th. I found and removed oil soaked rags on the Division I diesel generator. During the same tour, I found the same condition on the Division II diesel In this case I left the rags in place to evaluate the 9enerator.

licensee's program for inspecting and cleaning. Dn June 18th ]

removed the rags and gave them to the Manager-CPS even though seven shiftly tours by plant staff operators and two daily tours by all of the plant managers and directors did not identify or remove the rags.

The Manager-CPS did not see this as a problem and argued against this violation. Two weeks later, plant staff found a large bundle of oil-soaked rags on a diesel generator and then the Manager-CPS took corrective actions.

These are examples of some of the issues that required long hours on the Additional areas part of NRC inspectors to improve Clinton's programs.

include the Plant-Wide Punch List, maintenance work request closure (several violations have been issued on failure to follow procedures and inadequate closure of work packages), failure to train and control contractors (Stone and Webster).

2. Clinton's Modification Pr_ogrjLm Since January 1986. Clinton has completed over 100 major and minor modifications on safety related systems with between 50 and 60 additional modifications to be completed currently. Region III is not scheduleSince to of most review the modifications or testing until after fuel load.

these modifications were done on preoperationally tested systems and Clinton is not experienced at modifications, there is a potential for similar problems as were found at LaSalle and Dresden.

3. Clinton has not been fully upfront with the NRC on their status and progress.

Clinton does not include the preoperational test result review in their stata's for completion of preoperational testing. When Clinton informed Mr. Denton that they were 90% complete with preoperational testing in early June, they did not include the fact that 60 out of 153 preoperational

,'a, -

r

- 1

.*a Mark A. Ring 3 M S0 g -

tests were not through the review process or that 41 retests (as of July 18,1986) were still to be completed. We (NRC) have considered a preoperational test complete only after the review was complete and the test results accepted. This has falsely created the appearance that we (Region III) are holding things up since we had only e.ompleted 50% of our program.

4. Clinton's Staff Experience On the average, all of the plant staff, except senior management, have This between three and five years of nuclear plant operations experience.

includes the Technical, Operations, and Engineering staffs. This has led to problems in maintaining and controlling systems after preoperational testing was completed. An example of this was the inadequate maintenance and operation of the safety related batteries.

These concerns do not necessarily affect the fuel load license, but they will have impacts on the ability of the plant to operate in a safe manner at powers These concerns are being documented to you so that you can greater than 51. discuss them with Messrs. Davis and Keppler in my absence at the July 31,1986.

If you have any further questions, please contact me.

tevie G. Du nt Reactor Inspector cc: C. W. Hehl R. C. Knop

. . . _ .