ML20212H541

Notice of Violation from Insp on 860701-1010 & Proposed Imposition of Civil Penalty in Amount of $75,000.Violations Noted:Design Control Measures Did Not Ensure That Design Bases for Structures & Sys Correctly Translated Into Specs

ML20212H541
Person / Time
Site:	Clinton
Issue date:	03/03/1987
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212H502	List: ML20212H498 ML20212H541
References
50-461-86-48-1, 50-461-86-53, 50-461-86-54, EA-87-011, EA-87-11, NUDOCS 8703060140
Download: ML20212H541 (5)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Illinois Power Company Docket No. 50-461 Clinton Power Station Construction Permit No. CPPR-137 EA 87-11 As a result of the inspection conducted'during the period July 1 through October 10, 1986, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

-10 CFR Part 2, Appendix C (1986), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

A. 10 CFR Part 50, Appendix B, Criterion III, requires that measures be established to assure that applicable regulatory requirements and design bases for structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, design control measures did not ensure that the design bases for structures, systems, and components were correctly translated into specifications, drawings, procedures and instructions.

Specifically:

1. Approximately 36 motor operated valves (MOVs) were modified during the first six months of 1986 in such a way that valve operation under the design conditions of low voltage could not be assured.

Section 8.7.3.12 of Maintenance Procedure CPS 8451.02 incorrectly allowed the modification of the limiter plate for Limitorque valve operator torque switches and therefore rendered the valves inoperable under low voltage conditions.

2. Field Engineering Change Notice No. 12329, issued on September 28, 1985, changed the configuration of the power wiring to valve motors from that specified on design drawings. However, this change was not incorporated or referenced on later electrical wiring drawings.

3. The design bases for flood protection of the circulating water screenhouse was not correctly translated into specifications, drawin s rocedures, and instructions in that Shutdown Service WaterfSSW system valves ISX011A and ISX011B and the SSW system equipment in the Division II pump cubicle, located below the maximum probable flood level in the circulating water screenhouse, had not been protected against the effects of flooding as described in FSAR Sections 9.2.1.2.3 and 3.4.1.1. A construction opening, a manway, and four piping penetrations would have allowed water into the screenhouse, directly affecting the SSW system equipment.

8703060140 870303 gDR ADOCK 05000461 PDR

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' Notice of Violation 2 MAR 3 1987 B. 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in

-accordance with these instructions, procedures, or drawings.

Contrary to'the above, activities affecting quality were not adeguately accomplished in accordance with the prescribed procedures. Specifically:

1 1. .Although Section 8.1.3 of Procedure CPS 1005.06 requires analyses be performed to support any statements made on the safety evaluation 4

form, including the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question, licensee personnel did not document the bases for the conclusion that no unreviewed safety question existed for modifications DG-24

, and SX-12.

2.. Although Section 8.1.13.2 of Procedure CPS 1003.01 requires testing documentation to be attached to the Plant Modification Package licensee personnel failed to place test results in the modification i package for seven modifications (PR-11, AP-12, SX-12, HP-17, RH-17,-

DG-24, and DG-39) performed between March 26 and August 5, 1986.

l- 3. CPS Procedure GTP-55 was found to be inadequate to ensure that valve

stem threads were completely lubricated in that some threads cannot

be checked because they are within the valve operator or are '

lubricated through a fitting.

C. 10 CFR Part 50,-A)pendix B, Criterion XI, requires that a test program i shall be establis1ed to demonstrate that systems will perform satisfactorily

.and perform in accordance with written test procedures. These procedures i ' shall include provisions for assuring that all prerequisites for a given ,

j' test have been met and that adequate test instrumentation is used.

Contrary to the above, the test program did not demonstrate that systems l

, would perform satisfactorily or that all prerequisites for a given test l had been met. Specifically:

1. Post-maintenance testing did not identify that a modification to 17 valves resulted in the limit switches being set backwards.

j This resulted in the failure of one of the 17 valves. t

. 2. Modification DG-24 for the changing of a seal-in feature for the  ;

1 Diesel Generator start signal, was completed and released for i operation on April 19, 1986, without acceptance criteria being identified or testing being performed to verify the adequacy of

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Notice of Violation 3 MAR 3 WS!

the modification. In addition, nine other modifications (HP-06,-

PR-11, AP-12, SX-12, SX-15, HP-17, RH-17, DG-35, and DG-39) were completed and released for operation between March 26 and August 13, 1986, without acceptance criteria for verifying the adequacy of the modification. Although post-modification testing was performed in each instance, the lack of acceptance criteria precluded the evaluation of test results.

D. 10 CFR nart 50, Appendix B, Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

Contrary to the above, established measures to assure that conditions adverse to guality are promptly identified and corrected were not adequately implemented. Specifically:

1. The torque switch limiter plate of 36 safety-related valves were improperly modified during the first six months of 1986 without adequately determining the cause of the low thrust output found during testing. The low thrust values were later found to be in error and the modification was not actually necessary.

2. Condition Report No. 1-85-10-091, dated October 17, 1985, identified a deficiency in Field Engineering Change Notice (FECN) 12329 which changed the wiring configuration for MOVs; however, as of September 5, ~

1986 valve schematic drawings were still not corrected to preclude repetition of the problem.

3. The corrective action for Condition Report No. 1-86-06-001, dated May 19, 1986, for the unauthorized replacement of a motor, was found to be inadequate in that the corrective actions did not address contractor activities.

4. Condition Report No. 1-86-02-089, dated February 6, 1986, identified deficiencies in Procedure CPS 8227.01 for maintenance on the Standby Liquid Control Pump; however, as of August 28, 1986, the procedure had not been revised to provide adequate instructions.

Collectively, the above violations have been categorized as a Severity Level III problem (Supplement II).

Lumulative Civil Penalty - $75,000 assessed equally among the violations.

Notice of Violation 4 3 1987 MAR Pursuant to the provisions of 10 CFR 2.201, Illinois Power Company is hereby

" required to submit to the Director, Office of Inspection a'nd Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 with a copy to the Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road, Glen Ellyn, IL 60137, within 30 days of datethe, of Region this III, Notice a written statement or explanation, including for each alleged violation: (1) admission or denial of the alleged violation; (2) the reasons for the violation, if' admitted; (3) the corrective steps that have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may-issue an order to show cause why.the license should not be modified, suspended, or

. revoked or why such other action as may be proper should not be taken.

Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act response shall be submitted under oath or affirmation., 42 U.S.C. 2232, this Within the same time as provided for the response required above under 10 CFR 2.201 Illinois Power Company may pay the civil penalty by letter with a addressed check, toor draft, the Director, money Office order of Inspection payable and Enforcement,ted to the Treasurer of the Uni States in the amount of Seventy Five Thousand Dollars ($75,000) or may. protest imposition of the civil penalty in whole or in part by a written answer Office of Inspection and Enforcement. Should addressed Illinois Power to the Director,l Company fal to answer within the time specified, the Director office of Inspection and Enforcement, will issue en order imposing the civil ,

penalty in the amount proposed above. Should Illicois Power Company elect to file suchan answer answer may:in accordance (1) deny the with 10 CFR listed violations 2.205 inprotesting the in this Notice civil penalty,in whole or part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may requires remission or mitigation of the penalty.

the five factors addressed Inrequestingmitigationoftheproposedpenaltyldbeaddressed..Anywritten in Section V.B of 10 CFR Part 2, Appendix C shou answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. Illinois Power Company attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

Notice of Violation 5 MAR 3 1987 Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be. referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.

FOR THE NUCLEAR REGULATORY COMMISSION N h -

A. Bert Davis Acting Regional Administrator Dated at Glen Ellyn, Illinois this 3 day of March, 1987

-4 U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-461/86048(DRP)

Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Conducted: July 1-28, 1986 Inspectors: T. P. Gwynn P. L. Hiland H. M. Stromberg C. H. Scheibelhut Y

F. .* 31onskiGb z5 T[2// S [o Date '

K. A. Connaughton Approved By: o h f/2//f[o Project's Section IB

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Inspection Summary Inspection on July 1-28, 1986 (Report No. 50-461/86048(DRP))

Areas Inspected: Routine safety inspection by three resident inspectors, one regional based inspector, and two contractor inspectors of preoperational testing and operational preparedness activities including applicant action on previous inspection findings; generic letter followup; review of 10 CFR 21 report; employee concerns; functional or program areas (including site surveillance tours, operating procedures review; emergency procedure review; and plant procedures review); regional requests (including Safeteam status, diesel generator event followup, potential equipment tampering incidents, and operational readiness assessment); and site activities of interest.

Results: Of the thirteen areas inspected, two violations and one deviation were identified.

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s The first violation (Paragraph 2.q.) indicated a continuing failure of plant staff maintenance technicians to pay attention to the details of their work and a continuing failure of their supervisors to identify and correct poor performance. A single example of this violation was identified, however the item is more significant since it represents repeat of a previous violation.

The second violation (Paragraph 6.a.(3)) was more significant to plant operational safety in that the cooling water source to one train of emergency core cooling system equipment would have been lost during an abnormally high lake level (flood). The violation resulted from the failure of the applicant's operational quality assurance program to identify and correct a construction deficiency prior to acceptance of the screenhouse by the operating organization.

The deviation (Paragraph 2.p.) indicated that the applicant's safety evaluation performed in accordance with the requirements of 10 CFR 50.59 prior to approval of the affected procedures had been ineffective in assuring that commitments contained in the Final Safety Analysis Report had been met by the procedures 2

r j DETAILS

1. Personnel Contacted Illinois Power Company (IP)

+*K. Baker, Supervisor, I&E Interface, Licen:ing and Safety

• D. Burke, Lead, General, Instructor

+*R. Campbell, Director, Quality Systems and Audits

+*W. Connell, Manager, QA

• E. Corrigan, Director, Quality Engineering and Verification

+ H. Daniels, Project Manager

+*S. Fisher, Manager, Nuclear Planning and Support

+ W. Gerstner, Executive Vice President

+*J. Greene, Manager, Nuclear Station Engineering Department (NSED)

+*D. Hall, Vice President, Nuclear

+*H. Lane, Manager, Scheduling and Outage Management

• J. Loomis, Construction Manager

+*J. Perry, Manager, Project Control Center

+ T. Riley, Supervisor, Licensing Operations

+ R. Schaller, Director, Nuclear Training

+*F. Spangenberg, Manager, L&S

+*J. Weaver, Director, Licensing

+*J. Wilson, Manager, Clinton Power Station (CPS) i Soyland/Wipco

+ E. Williams, Vice President

• J. Greenwood, Manager, Power Supply U.S. NRC

+R. Bernero, Director, Division of BWR Licensing, Office of Nuclear Reactor Regulation (NRR)

+W. Butler, Director, BWR Project Division 4, NRR

+B. Siegel, Clinton Licensing Project Manager, NRR

+*T. Gwynn, Senior Resident Inspector, Operations

• D. Keating, Senior Resident Inspector, Construction

• P. Hiland, Resident Inspector

, +C. Norelius, Director, Division of Reactor Projects t

+R. Knop, Chief, Projects Section IB

+B. Grimes, Director, Division of QA, Vendor & Tech. Training Center, Office of Inspection and Enforcement

+S. Black, Technical and Operations Support Branch, NRR

• R. Barnett, Region III

• Denotes those attending the monthly exit meeting on July 28, 1986.

! + Denotes those attending the management meeting on July 10, 1986.

The inspectors also contacted and interviewed other staff and contractor

! personnel.

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2. Applicant Action On Previous Inspection Findings'(92701)-(92702)

a. (Closed) Open Item (461/85005-43): Verify that commitments listed

in SSER2, Paragraph 9.3.5 are incorporated into the Clinton Core -

Damage procedure. prior to fuel load (TMI Item II.B.3).

This item was previously reviewed by the inspector as documented in

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Inspection Report No. 50-461/85065, Paragraph 2. During that review, the inspector identified a number of discrepancies which required additional action by the applicant, specifically the applicant was to provide an implementing procedure or instruction, approved by the Facility Review Group (FRG), which referenced Technical Specification Requirement 6.8.4.c and which was responsive to the SER requirements. ,

During this report period, the applicant again presented this item

. to the inspector for closure. The inspector reviewed procedure

! CPS No. 1890.30, Post Accident Sampling Program, Revision 0, dated 4

July 3, 1986. The inspector noted that the procedure provided the

, information which had been missing in the previous inspection. This

! item is closed,

b. (Closed) Open Item (461/86016-03): Verify that containment isolation valves are properly tagged. During the conduct of a special NRC l team inspection of the Clinton Technical Specifications, it was i noted that a significant number of containment isolation valves were 1 not identified with proper tags.

The applicant presented this item to the inspector for closure. The j applicant provided a complete list of containment isolation valves, l annotated during a walkdown they had performed. Discrepancies

identified during their walkdown were documented as corrected. The i inspector reviewed the valve tagging list and performed a spot inspection of nineteen valves. All valves inspected were properly tagged. This item is closed.

!' c. (Closed) Open Item (461/85039-01): " Demonstration of capability to augment the onsite staff during an emergency to meet the 30 and 60 minute goals of table B-1 of NUREG-0654, Revision 1." i i

! Upon activation of the emergency organization, key personnel must 1 respond to augment onsite personnel in the manning of the Technical '

i Support Center (TSC), the Operations Support Center (OSC), the

Emergency Operations Facility (EOF), and the Joint Public Informa-i tion Center (JPIC). Table B-1 of NUREG-0654, Revision 1, delineates

! minimum personnel and time response goals to activate. The applicant's ,

capability had not been demonstrated.

l l The applicant conducted an actual shift augmentation drill (personnel called and arrival at the site logged) on February 13, 1986. The i drill identified weaknesses in the notification scheme which resulted j in a number of late arrivals. The applicant evaluated the test  ;

results and subsequently issued more pagers to shorten the notifica-tion time. The applicant then performed another drill for the i groups having excessive late arrivals on April 14, 1986. The second l  !

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4 4 drill was found to be successful. To demonstrate the overall capability of the staff augmentation program, the applicant initiated l a call-out on June 23, 1986, in which the applicant exercised the notification system. Each notified emergency response organization i member completed a questionnaire identifying notification time and

estimating site arrival time. The applicant reviewed the simulated

call-out drill results and considered the drill successful. The ,

inspector reviewed the results and agreed that the applicant had demonstrated the capability to augment the onsite staff in the event i of an emergency. This item is closed,

d. (Closed) Open Item (461/85039-10): Equipment (sample containers, 4

shielding, handling, and transport equipment) needed to enable.  !

sampling at existing grab sample ports for the plant vent stack and i

Standby Gas Treatment system (SGTS) stack had not been developed and ,

tested.  !

The applicant presented this item to the. inspector for closure. As l l a method of demonstrating that their system for sampling would >

function as required, the applicant simulated a condition where it was necessary to obtain a sample via a drill. The drill sequence l required plant personnel to obtain a sample from the SGTS accident  !

i range monitor exhaust. During the drill, the applicant demonstrated  ;

that, while dressed in anti-contamination clothing and self contained

! breathing apparatus, they could perform operations necessary for

! obtaining samples. Their sample assembly consisted of a shielded j sampling unit in which a charcoal cartridge and filter had been j installed. The sample assembly was connected into the sample path

! by using quick disconnect couplings that appeared to work easily and i to seal completely. Once the sample assembly was connected in the

! sample path, the sample was drawn through the sample assembly. The j sample assembly was removed and transferred to the chemistry lab for

{ sample analysis.

l Once in the lab, the drill personnel procedurally demonstrated

removing the sample. The sample assembly was disassembled while in l a shielded, ventilated hood. Then the charcoal cartridge and filter j

were removed using special handling tools, t

i The applicant successfully demonstrated their ability to obtain and ,

analyze necessary samples in accordance with their procedures. The +

l inspector reviewed the accident range monitor exhaust flow path and I found that a return path existed for uncollected samples to return

} to the sample lines. Based on the inspector's observations and review of drawings, this item is closed. l l .  !

e. (Closed) Open Item (461/85039-11): Demonstrate the ability to safely  :

J collect and transport high activity level samples from the HVAC and l Standby Gas Treatment System (SGTS) grab sample ports.

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On July 24, 1986, the applicant initiated a drill which required a particulate iodine sample to be drawn from the SGTS exhaust transfer port. The drill sequence was for personnel to dress in anti-contami-nation clothing and self-contained breathing apparatus and proceed to the sample site. Drill personnel carried a SA-16 shielded sample assembly (on a carrying rod), a copy of the procedure, necessary equipment for obtaining the sample and radiation monitoring equipment.

At the sample site, drill personnel demonstrated that it was possible to safely obtain a sample following CPS Procedure No. 1890.36, Stack Effluent Sampling (EP), Revision 2 (a draft procedure). Once the sample was taken, it was demonstrated that the ssmple could be transported safely to the Chemistry Lab. Transportation of the sample was made by two personnel carrying the SA-16 sample assembly on a rod specially designed for the task. Once the sample reached the chemistry lab, the sample assembly was transferred to a shielded, ventilated hood. The sample assembly was disassembled and the filter and cartridge sample analysis performed.

The inspector did not witness samples being taken from the accident i range monitor exhaust (AXM) and SGTS. However, the AXM installation was inspected and found to be sufficiently unobstructed to allow sampling following the same procedure. Based on the demonstration and inspection, the inspector concluded that sampling ability had been adequately demonstrated. This item is closed.

f. (Closed) Open Item (461/85039-24): All emergency alarms must be

• completely installed and operational prior to fuel load.

The applicant presented this item to the inspector for closure. l The inspector reviewed preoperational test procedure, PTP-CQ-01, Communications System, Revision 0. This procedure was a completed, approved copy of the preoperational test procedure for the communications system at Clinton Power Station. The test procedure adequately demonstrated the operability of the emergency alarm system. To verify operation, an alarm test is performed weekly.

On Tuesday, July 22, 1986, the test was witnessed. There was an NRC inspector located in containment, on the turbine deck, and in  ;

the control room. The inspector in the control room clearly heard the test. The inspector inside containment clearly heard the test ,

but identified an inoperable speaker. The inspector on the turbine '

deck did not hear the test at all.

The applicant researched and identified that, during conduct of the test, Division II clectrical power had been deenergized for other L maintenance activities. The inspector noted that the announcing i syste1 on the turbine deck receives Division II power which l explained the inoperability. The applicant wrote a MWR for the inoperable speaker in containment. Based on this knowledge, the appropriate preoperational testing (PTP-CQ-01) had been completed, and the energized portions of the emergency alarm system worked per design. This item is closed.

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g. (Closed) Open Item (461/85061-04): Failure of bolts on cell connections of division III battery. During a previous inspection, review of a completed maintenance work report (MWR) identified that bolts for cell number 1 on the safety-related Division III battery had been stretched and stripped during replacement. The nonconformance had not been properly dispositioned prior to closure of the MWR.

The applicant presented this item to the inspector for closure.

The' applicant researched this item and determined that three inconsistencies existed: (1) the MWR identified that torquing had been recorded as 75 foot pounds when it should have been to 75 inch pounds, (2) the procedure did not identify a torque value that was spplicable to the type of bolting material used, and (1) inadequate maintenance supervision review of MWRs.

Concerning the issues of the torque value recorded and inadequate supervisory reviews, the applicant found that the torque wrench used had a range of 0-200 inch pounds, which would not allow 75 foot pounds to be reached. Therefore, the applicant concluded that the 75 foot pound entry on the MWR was a clerical error. The associated QC inspection report identified the torque wrench and support 9d the applicant's finding. To prevent recurrence, the applicant required training for electrical maintenance technicians and supervision; they were instructed on paying attention to detail, providing complete and accurate work documentation, supervision responsibilities, and proper review of documents.

To resolve the question concerning an appropriate torque value for the t,attery bolts, the applicant identified that the bolts should be tightened to " snug-tight." The applicant defined " snug-tight" to be when the associated lock washer was flat. To verify that the ter:a " snug-tight" was understood by the electricians, the inspector Interviewed seven Stone & Webster and one IP electrician. The IP electrician and two Stone & Webster electricians demonstrated their knowledge of the definition; the other electricians interviewed did

, not, have a clear understanding. The applicant subsequently conducted training for all electricians and training records were provided to the inspector for review.

The inspector questioned the applicant as to whether or not the snug-tight criteria not being understood by all personnel could have resulted in bolts being over-torqued. The applicant stated that if the bolts were over-torqued and the torque valt.e vent above the yield strength of the bolt, the failure would be identified during installation. If the torque did not cause failure, it would constitute an individual severe load tast and meet the design intent. There were no additional loads applicable to these bolted electrical connections. This item is closed,

h. (Closed) Open Item (461/85005-44): Verify the loose parts. monitoring systems are operational prior to fuel load.

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• e The applicant presented this item to the inspet. tor for closure.

The inspector reviewed procedures CPS No. 9000.01, " Control Room Surve111ar.ce Log," Revision 20, dated July 7, 1986; CPS No. 9037.20,

" Loose Parts Monitoring System Functional Test," Revision 20 dated June 13, 1986; and CPS No. 9437.20, " Loose Part Detection. System Channel Calibration," Revision 20, dated May 17, 1986. These procedures appeared to be adequate to control calibration and surveillance requirements for this system. The inspector also observed a control room operator perform applicable steps of CPS No.'9000.01 on the loose parts monitoring system. The system appeared to work properly. This item is closed,

i. (Closed) Open Item (461/85065-01): Non-Licensed Operator Training.

During a previous report period, the inspector noted that a number of training requirements for non-licensed operators had not been performed due to the construction status of the Clinton Power Station.

The Director - Plant Operations identified via memorandum DMA-0082-86, dated May 29, 1986, those qualification requirements for non-licensed training that were to be deferred until after fuel load. This memorandum identified eight qualification requirements for system operation and/or practical factors sign-offs that would nct be completed until commercial operation. The inspector noted that the tight deferred qualification requirements were on nonsafety-related systems that were not required to be oparating to support fuel load activities.

The inspector reviewed the Qualification Log (CPS No. 1402.04F003) and the Qualification Record (CPS No. 1402.04F004) being maintained in the Shift Supervisor's office in accordance with procedure CPS No. 1402.04, Operations Departmut Watchstanding Organization and Qualifications. The inspector noted that these logs were being maintained for all operations department shift personnel, both licensed and non-licensed.

The inspector selected a nunber of qualification requirements that had previously been waived during the construction phase of Clinton Power Station. The inspector confirmed that a Qualification Requirement form was assigned and that completion of the required training was documented on selected individuals' Qualification Records.

Tne inspector confirmed that non-licensed training requirements were being maintained in accordance with applicable procedures and training which had been waived due to plant construction was completed (except for the eight qualification requirements identified above). This item is closed.

j. (Closed) Open Item (461/86028-05): Public address system and sound powered phone system operation. During a previous inspection, the inspector identified that a number of public address system (gaitronics) and sound powered phone system components were incperable.

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This item was presented to the inspector for closure. The applicant presented signed off preoperational test results approval sheets for PTP-CQ-01, Communication System. The inspector reviewed the completed test procedure results and noted that the test results appeared to be adequate. However, since test completion, numerous deficiencies have been identified in the Gaitronics communications system. A similar open item (461/85039-23) identified that the public address system must be operational prior to fuel load. To reduce duplication of open items, this concern is closed. Problems identified in the Gaitronics system will be monitored under open item 461/85039-23 (see Paragraph 2.u. below).

k. (Closed) Open Item (461/86023-06A): CPS Remote Shutdown Division II Equipment Testing and Training. IP letter U-600533 dated April 21, 1986, repeated a previous commitment to provide operator training on the procedures for remote shutdown using ESS Division II controls and equipment prior to exceeding 5*4 power.

The inspector confirmed that Remote Shutdown classroom training with Division II Equipment was provided to 30 of the 33 licensed operators currently assigned shift duties. In addition, a number of supervisory and technical staff personnel were provided this training. The three licensed operators that had yet to receive the committed training included one Assistant Shift Supervisor (SRO) and two Control Room Operators (R0s). All three of these individuals were scheduled to receive Remote Shutdown training during their next Licensed Operator Requalification training effort.

As documented previously (reference Inspection Report No. 50-461/86037), the inspector observed " hands-on" training provided to a number of plant operators during the conduct of a confirmatory test. The confirmatory test was performed to demonstrate that Division II Residual Heat Removal (RHR) and Shutdown Cooling (SX) systems could be operated from outside the main control room.

Based on the observed " hands-on" training and the documented classroom training provided to licensed operators on the procedures for remote shutdown using ESS Division II controls and equipment, this item is closed.

1. (Closed) Open Item (461/86026-01D): Post Maintenance Testing.

During a previous report period, the inspector questioned the status of Post Maintenance Test (PMT) requirements identified in the body of maintenance procedures since PMT requirements were addrcssed separately in administrative procedure CPS No.-1029.01,

" Preparation and Routing of Maintenance Work Requests." A related concern regarding the adequacy of the PMT program was identified as an unresolved item (461/86023-05). This unresolved item was initiated to follow the IP Operations Department response to an IPQA audit finding (IPQA Audit finding Q38-86-10) that identified a breakdown in the administrative controls.

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During this report period, the inspector coriducted an extensive review of the current program established by the applicant to identify, monitor, and perform post maintenance testing. The inspector reviewed administrative procedures CPS No. 1401.01, Conduct of Operations, Revision 7 and CPS No. 1029.01, Preparation and Routing of Maintenance Work Requests, Revision 10.

In response to the inspector identified concerns and the applicant's own audit findings, the applicant revised the programmatic /

administrative controls over the PMT process. CPS No. 1029.01 identified in Section 3.5 that the Director - Plant Operations was responsible for . . . the identification and performance of PMT in accordance with CPS No. 1401.01, CONDUCT OF OPERATIONS." The flowpath detailed in CPS No. 1029.01, Figure 1, showed the completed maintenance work request (MWR) t.opy being routed to the Shif t Supervisor to " Perform PMT."

CPS No.1401.01, " Conduct of Operation," was revised to include direction for post maintenance testing evaluation and tracking.

Section 8.5.7 of CPS No. 1401.01, Revision 7, detailed the process for determining the need to perform a PMT evaluation. Appendix A to CPS No. 1401.01 provided criteria to be used by the Shift Supervisor and/or Assistant Shift Supervisor in determining requirements for PMT.

In response to NRC questions regarding the applicant's commitment to their augmented-D Quality Assurance program, the applicant revised Appendix A to CPS 1401.01 to include a PMT review for augmented-D 1

(Quality Group E) systems. As a minimum, a review for PMT was required for all safety-related MWRs, fire protection MWRs, augmented-D MWRs, IEEE Class IE MWRs, and MWRs requiring ISI reviews.

In addition to the controls established by the change to CPS l

No. 1401.01, " Conduct of Operations," the applicant performed a review of all MWRs completed on Phase Il released (turned over to plant staff) systems between May 16, 1985 and the issuance of Revision 7 to CPS No. 1401.01 (May 28, 1986). The purpose of this review was to "Backfit" the current post maintenance test program reviews onto MWRs that had not had the recuired PMT performed under the previous program.

The applicant stated that some PMT requirements were included in maintenance procedures. The applicant stated that those requirements were identified in order to determine the adequacy of the work performed under the procedure. The inspector noted that Section 8.5.7.1.2 of CPS No. 1401.01, Revision 7, detailed the PMT requirement review performed by the Shift / Assistant Shift Supervisor. PMT requirements determined from the above review were to be documented on CPS No. 1401.01F008 PMT EVALUATION.

In addition, the program provided that maintenance personnel  ;

may recommend the performance of additional PMT. '

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The inspector verified by direct observation and interviews of cognizant applicant personnel that the programmatic controls described above were in place. Implementation of the PMT review program is discussed further in Paragraph 2.y. below. This item is closed.

m. (Closed) Open Item (461/86030-01): Post maintenance testing following modifications performed on emergency diesel generator lubricating oil system. During a previous inspection, the inspector identified post maintenance test documents included in modification packages TDG-58 and TDG-59 that had the post maintenance test requirements marked not applicable (N/A) without required signatures and dates.

The applicant presented this item to the inspector for closure. The inspector reviewed final document packages and determined that the applicant had re-reviewed and obtained appropriate signatures.

Necessary PMT had been performed but the PMT evaluation had not been documented. To prevent future occurrences of post maintenance testing being completed, the applicant provided Technical Department personnel with training in post-maintenance testing review techniques.

The applicable training records were reviewed by the inspector. .

This item is closed,

n. (Closed) Open Item (461/86040-02): Process Grab Sample Lines.

Durin) a previous inspection, it was identified that five of 116 radwaste system grab sample lines were plugged.

The applicant presented this item to the inspector for closure.

Closecut documentation demonstrated that the sample lines in question have been unplugged. Also presented were the results of an evaluation made by the CPS Chemistry Supervisor which determined that the line plugging was the result of abnormal valve lineups required to support startup test activities, higher than normal amounts of solid matters from initial plant flushing activities (resins, particulates, dirt and debris), and operator inexperience.

The Chemistry Supervisor felt that once startup activities are completed and plant operators gain necessary experience, the problem would be resolved. Based on the sample lines being unplugged and the Chemistry Supervisor's evaluation results, this item is closed.

o. (0 pen) Open Item (461/84025-01): CPS descriptions not maintained up to date. During a review of the Clinton training department's license review course, the inspector identified that CPS system descriptions were not being maintained up to date.

The applicant's Nuclear Station Engineering Department performed a review of all system training lesson plans to ensure that information in the training material was correct and accurate.

With this review as the baseline, the applicant had established 11

proceduralized controls for the Nuclear Training Department to maintain lesson plans current with respect to system design, operating procedures, and industry experience.

The applicant has stated that the use of system descriptions is not needed since lesson plans provided to each candidate were very detailed. The inspector noted that 39 of 44 candidates received their SRO license and 14 of 16 candidates received their R0 license based on training provided using the detailed lesson plans.

The appli: ant awarded a contract for development of up-to-date system descriptions. This contract was scheduled for completion in December 1987. This item will remain open pending review of completed system descriptions.

p. (0 pen) Open Item (461/85005-32): Verify that procedures to ensure independent verification of system lineups are completed before fuel load (TMI Item II.K.1.10).

The applicant presented this item to the inspector for closure.

The inspector reviewed portions of the following procedures:

CPS No. 1401.01, " Conduct of Operations," Revisions 6 and 8, CPS No. 3312.01, " Residual Heat Removal (RHR) System Operations,"

Revision 3, and CPS No. 3313.01, " Low Pressure Core Spray (LPCS)

System Operations," Revision 3. CPS No. 1401.01 was reviewed to determine if a communications link existed that ensured control room operators were notified when system lineups were changed.

Both revisions of the applicable procedure delineated the sequence for shift communications flow. The inspector observed performance of a tagout of the division 2 battery (Tagout No. 86-4639) to verify the communications sequence was being followed. The communications were in accordance with CPS No. 1401.01 and appeared to be adequate.

Valve lineups in procedures CPS No. 3312.01 and 3313.01 were compared to requirements identified in FSAR Sections 6.3.7.8.,

13.5.2.1.1, and Appendix 0. The inspector found that the valve lineup sheets in the referenced procedures did not provide an independent verification for all valves in the safety-related systems / components as committed in the FSAR sections. Numerous locked valves (as required by the FSAR) as well as system vent and drain valves were not independently verified. In particular, independent position verification was provided for only 19 of approximately 53 valves in the LPCS system. In addition, discrepancies existed between system valve lineups such that valves of similar function required independent verification in one ECCS system and not in the other. This was a deviation from FSAR commitments (461/86048-01). This item remains open pending resolution of the above deviation and additional inspection,

q. (0 pen) Open Item (461/85005-41): $$ER2, Paragraph 7.4.3.2 - Verify installation of loss of voltage alarms prior to fuel load.

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This item was previously reviewed for closure in Inspection Report No. 50-461/86023. That inspection identified that two of the five loss of voltage alarms had been identified as deficient on Startup Test Authorization Form (STAF)85-102. The STAF referenced an MWR that was intended to correct the two deficient alarms. The MWR referenced on the STAF did not address either of the alarms involved; a separate MWR contained in the closure package did address one of the deficient alarms. However, the MWR was closed without completion of a required functional test; this was identified as a violation (461/86023-01A). At the time the closure package was returned to the applicant, the inspector had reviewed no information concerning the other deficient alarm. j The applicant again presented this item to the inspector for 1 closure. Review of the information presented indicated that the alarm which was the subject of the previous violation had been '

adequately tested and demonstrated to be operational. However, the information provided did not clearly demonstrate that the second alarm was operational.

Due to the lack of clarity in the documentation, the inspector requested and the applicant performed an operational test of the two alarms which had been in question. The alarm that was the subject of the previous violation functioned properly; the second alarm failed to function as required.

A prompt review by the applicant revealed that the maintenance technician assigned to correct deficiencies identified on STAF 85-102 had not completed MWR C06466 in accordance with the job steps. This was a violation of CPS No. 1029.01, Revision 10, Preparation and Routing Of Maintenance Work Requests, Paragraph 8.2.21 which required that the maintenance group supervisor evaluates the MWR for adequacy of corrective action taken and work completion (461/86048-02). This violation appeared to be a repeat of the previous violation.

This item remains open pending demonstration by the applicant that  !

all five loss of voltage alarms will function as required.

r. (0 pen) Open Item (461/85012-02A): CPS procedures had not received  !

an independent technical review. Several adtr.inistrative procedures reviewed by the inspector did not reflect the applicable requirements of ANSI N18.7-1976, the cps technical specifications, and other regulatory requirements.

This item was previously reviewed in Inspection Reports i No. 50-461/85045, 85053, and 85065. As a result of the inspection i documented in Inspection Report No. 50-461/85065, Paragraph 8.6., '

the applicant was requested to respond to the unresolved item in  !

writing. The applicant's response, documented in IP letter U-600544 i dated April 30, 1986, identified the corrective actions taken and indicated that all corrective actions would be complete by May 15, l 1966.  ;

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4 Subsequent to that date, an NRC inspector identified another apparent example of this unresolved item (unresolved item 461/86017-04f, followup inspection documented in Inspection Report No. 50-461/86049, Paragraph 2.b). In addition, followup inspection on unresolved item 461/85012-03 (documented in Paragraph 2.s. below) indicated a continuing failure of CPS administrative procedures to meet the requirements of the applicable CPS technical specification and 10 CFR 50.59. These recent inspection results indicated that the corrective actions taken by IP to date may not have been effective in resolving this item.

The applicant presented this item to the inspector for closure.

The management corrective actions taken, as documented in IP letter U-600544, were as follows:

(1) CPS Procedure 2003.01 has been revised to include applicable requirements.

(2) A program to train and qualify independent technical reviewers for procedure review has been implemented.

(3) Trained reviewers (corrective action No. 2) have completed a review of all plant safety-related administrative control procedures.

(4) Procedure revisions to incorporate items identified during the above review (corrective action #3) will be completed by May 15, 1986.

The inspector asked IP management if they had prepared the source document index required by ANSI N18.7-1976, Paragraph 5.1, and if that index had been used during the conduct of independent technical reviews. The index had been prepared but was not used during the reviews. The inspector suggested that IP management consider reviewing their program against the applicable requirements prior to NRC review of this item for closure. This item remains unresolved.

s. (0 pen) Open Item (461/85012-03): Plant staff procedures for document control were improperly classified and had not received an appropriate level of review.

The applicant presented this item to the inspector for closure.

The inspector reviewed the results of a detailed QA audit conducted by the applicant in response to this concern. In addition, the inspector verified that the specific procedures that had been of concern had been reclassified and had received the required level of review and approval. However, review of the applicant's Operating Manual Status Report (OMSR) indicated that a significant number of plant administrative procedures remained that were classified as nonsafety-related, no Facility Review Group (FRG) review required.

The following issues were identified as remaining unresolved:

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(1) Technical Specification (TS) 6.5.1.6.a required that the FRG,.the onsite independent review committee for CPS, s

shall be responsible for review of all administrative procedures and changes thereto. CPUrocedures implementing the TS requirement included the following:

(a) CPS No. 1001.03, Facility Review Group (b) CPS No. 2001.04, Facility Review Group Review Of Assigned Documents (c) CPS No. 1005.03, Operating Manual Status Report CPS No. 2001.03, Revision 5 dated March 12, 1986, Paragraph 3.3.1 reflected the TS requirement (verbatim).

CPS No. 2001.04, Revision 2 dated April 12, 1986, Paragraph 8.1 provided the administrative controls for implementation of the TS required reviews. In accordance with Paragraphs 8.1.1, 8.1.2, and 8.2, the FRG reviewed only.those plant procedures with a class code of SXXX .

Procedure classification codes were assigned in accordance with CPS No. 1005.03, Operating Manual Status Report (OMSR). The purpose of this procedure was to provide guidelines to personnel preparing computer input sheets for the OMSR which in turn controls the initiation and revision of the OMSR and tracking of all station procedures (including plant administrative procedures).

The procedure also provided guidelines to personnel concerning determination as to whether a procedure should be classified as safety-related (SXXX class code) or nonsafety-related (NXXX class code). The guidelines explicitly addressed plant administrative procedures in Appendix A but did not require review of all plant administrative procedures; the determination as to whether or not a plant administrative procedure required FRG

, review was thereby left to the judgement of each plant department.

Procedure CPS No. 1005.02, Organization Of The Station Operating Manual, Revision 8 dated March 21, 1986, '

identified the plant administrative procedures as being those procedures designated as CPS No.1XXX.XX. NRC review of the CPS operatin0 manual on July 18, 1986, identified that approximately 150 of 250 total 1XXX.XX CPS procedures had a class code of SXXX. This indicated that about 40'. of the CPS administrative procedures were not being reviewed by the FRG. Procedures not receiving FRG review ranged from CPS No. 1005.02, Organization Of The Station Operating Manual and CPS No. 1038.01, Control Of Technical Specifications to CPS No. 1101.99, Control i

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7 l , ,

O The IP Recreational Area. 'This11nspection result

! indicated that the applicant's corrective actions under the unresolved item had not been adequate to assure that the letter'of the TS requirement had been met.

! (2) In addition, the inspection identified that the plant  ;

L administrative controls for downgrading the safety classification of station procedures contained in CPS i No. 1005.03, Paragraph 8.4.4, allowed the individual

" department head to downgrade a procedure from safety to nonsafety-related without FRG review and plant manager i approval, even though the procedure originally required a  !

10 CFR 50.59 safety evaluation, FRG review and approval by the Manager - CPS. This matter appeared to be contrary to the intent of CPS TS 6.5.1.6, 6.5.3, and 10 CFR 50.59. <

The above matters were discussed with the applicant in a meetin'g

between the NRC Senior Resident inspector, an NRC contractor  !

l inspector, the Manager - Licensing & Safety, the Manager - Clinton -

Power Station, and the Assistant Manager - Clinton Power Station i v on July 19, 1986. The applicant took the position that the '

administrative controls described and/or referenced above were..

adequate to meet the intent of the technical specifications and-regulatory requirements. The inspector was not in agreement. After reconsideration, the applicant committed to reclassifying all of  ;

their administrative procedures to a safety classification and" r performing a 10 CFR 50.59 review on procedures that had been or will be downgraded.

l I This item remains open pending demonstration that'. technical I specification requirements are met.

t. (Open) Open Item (461/85039-12): Emergency Samplirg and Analysis  !

Procedures. During a previous inspection, it was toentified that j neither the " normal" nor the " emergency" procedure for sampling and

• l analysis had been completed. , ,

The applicant presented this item to the inspector for closure. To resolve the item, the applicant was requested to perform a drill  ;

i simulation to demonstrate that their procedures were adequate to obtain and analyze samples., During the drill briefing, the  !

applicant presented the inspector with copies of CPS procedures RA-11, Stack Analysis and Sampling, Revision 2 CPS No. 1890.35, i Stack Effluent Analysis (EP), Revision 2, and CPS No. 1890.36, Stack l Effluent Sampling, Revision 2. These three procedures were used for obtaining and simulating sample analysis. All three procedures i appeared to work as intended. However, all three procedures were i draft procedures and were not approved by the appropriate personnel. i The appitcant stated that there were approved procedures in place r and that the drafts were implementing improvements. l l

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, f i h ce the drill simulation was demonstrated through draft procedures, the inspector was provided assurance that the. revised procedure would perform as intended. However, the assurance that the in place procedures would provide adequate guidance was not demonstrated.

Therefore, this item remains open pending issuance of the revised procedures. .

u. (0 pen) Opan Item (46 D85039-23): Ihepublicaddresssystemmust be , completely installed and operational prior to fuel load.

The m'pplicant presentedithis item to the inspector for closure.

The inspector reviewed a preoperational test procedure, PTP-CQ-01, Communications System, Revision 0. This procedure was a signed off copy of the preoperational test procedure for the communications

+

system at Citnton Power Station. The test procedure adequately demonstrated that the public address system had bun installed and tested. However, during a plant tour by the(resident inspector on June 21, 1986, a number of Gaitronics telephone units were determined to be inoperable. To evaluate the extent of the problem, operations persbnnel performed a walkdown of the Gaitronics communications system. MWR C-21339 wks generated to repair inoperable equipmentidentified during the walkdown. This item remains open pending completion of the MWR and demonstration of equipment oeprability, j '

v. (Open)OpenItem(461/86016-04): Standby Liquid Control System operability verification. During the witnessing of a surveillance test conducted by the applicant to verify standby liquid control operability, it was identified that the surveillance procedure l (CPS No. 9015.01) could not be performed.

The applicant presented this item to the inspector fhr closure.

The inspector reviewed CPS No. 9015.01, " Standby Liquid Control System Operability," Revision 22, as well as two marked up copies of Revision 20. To permit initial procedure performance, temporary changes were made to Revision 20. Once the procedure

, was performed, permanent changes were made which resulted in Revision 22. Revisiun 22 was reviewed and found to be adequate for test performance. This procedure was not required to be performed again until October 1986. A hold point was established so that the resident inspector would be notified prior to I i performance. This item remains bpen pending the inspector i

witnessing performsace of the procedure. /

w. (0 pen) Open Item (461/86037-04A): Review cf applicable procedures l indicated that the procedure for declaring systems tecnnical

. specification operable did r.ot reflect minimum requirements needed prior to the declaration of operability. The applicant stated that the procedure, CPS No. 14C1.01, Conduct of Operations, Revision 7, ,

would be revised to impose minimum requirements for the initial '

declaration of technical specification operability. <

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, The inspector reviewe'd CPS No. 1401.01, revision 8, and found

.several discrepancies which were discusssd in detail with the applicant. Those discrepancies related to the following:

-(1) Providing for a final system / area walkdown to assure no

conditions existed which woUld restrain system operability and to assure that the operational status of the system was documented correctly by plant administrative controls.

Y (2) Providing a clear!y defined and .auditable trail for each system operability declaration.

(3) Defining the prerequisites to be met for system operability.

Some minor clerical errors were also discussed. As a result of this 1 discussion, revision 9 do CPS No. 1401.01 was issued on

, j h July 24,1986. In addition, Operations Standing Order No. 49,

' \ < System Walkdown For Initial Operability, Revision 0, was issued the same date. Those revisions crovided a basis for declaration of Anitial system operability that appeared adequate to assure that ,

s leach system required for operatioT was operable and that any ~

, 3/ inoperable items were adequately identified and tracked. Two e questions reuir.ed open at the conclusion of this inspection, as follows: '

\

, (1) IP was to provide a listing of plant systems required to support plant operation, by milestone, for NRC review.

(2) CPS No. 1401.01, Paragraph 8.5.10.1.2. required "The Fuel Load Milestone Coordinator (FLMC) shall coordinate a: review of the lists in Appendix B by the appropriate departments. The depart"ents shall ensure that the review verifies that open items associat.ed with the lists are correctly coded as non fuel load restraints." -

TheEinspector requested that the FLMC identify the appropriate departments for each item listed in Appendix B and identify the criteria to be used to make the ' required determination.

si

't This' item remains open pendir.g review of the responses to each question above.

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x. '(Closedy thresclved Item (461/85072-028). Misclassifict*. ion of Procedures. Duping a previous inspectio'n, it was identified that some procedures had been misclassified as "N" (nonsafety-related) orsl' F" (non-safety-related, FRG review riquired) and therefore did not, receive all required reviews.  ;

i -

This' item was reviewed as part t' unresolved item (461/85012-03; see

_' Paragraph 2. s. above). The issue of misclassification of procedures was addressed in two active concerns; therefore, to reduce duplication,

, this item is closed.

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.. 1 18 a . -_ . - . - ---- . . - . - . --

g.

_y. (0 pen) Unresolved Item (461/86023-05): Post Maintenance Testing Implementation Deficiencies. An IPQA audit finding identified 4

deficiencies in the applicant's program for the PMT. As described in Paragraph 2.1. above (open item 461/86026-01D), the applicant revised the procedures'that were in place for control of post maintenance testing.

-The applicant performed a " limited scope" audit of the implementa-tion effectiveness of the new PMT program during this report period. ,

This limited scope audit indicated that some implementation deficiencies still existed in the PMT program. This item will remain open pending review of the applicant's final response to.the

, identified deficiencies.

t z. (Closed) Violation (461/85061-05): Procedure for jurisdictional

[ control of plant systems was changed by verbal directive rather than

, through the required review and approval process. During a previous inspection, the inspector identified that the Manager - CPS had provided verbal directives-to remove requirements for hanging plant staff jurisdictional tags.

The applicant presented this item to the inspector for closure. The inspector reviewed the applicable procedures (CPS No. 1440.01,

" System Turnover and Release" and CPS No. 1040.01, " System Release Review and Acceptance") and verified the requirements for

, jurisdictional tag hanging had been changed. The appitcant also

'f held training for plant managers and operators. Training records T were reviewed. The actions taken appeared to be adequate. This

item is closed.

' aa. (0 pen) Violation (461/86017-03): A temporary procedure change (procedure deviation for revision or PDR) No.86-094 was issued against CPS No. 1029.01, Revision 7, Preparation and Routing of l .

Maintenance Work Requests, in violation of procedure CPS No. 1005.07, Temporary Changes To Station Procedures. The violation resulted in CPS No. 1029.01 being inadequate to control the documentation of nonconforming conditions on a maintenance work request within the requirements of the IPQA program.

The applicant presented this item to the inspector for closure. The I

closure package indicated that POR 86-094 was disapproved for use and that CPS No. 1029.01 was revised in accordance with site i procedures. In addition, the applicant had reviewed 959 MWRs that i '

had been generated during the period PDR 86-094 was in effect.

, e Their review was to ensure that there was no inadequate reporting i and documentation of nonconformances in MWRs. No deficiencies were j identified by the applicant's review.

i The applicant's response to the notice of violation stated that all plant staff members authorized to approve PDRs would be required to i

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read the notice of violation prior to June 30, 1986 to prevent recurrence of this violation.

This inspection identified that only about 50*4 of the CPS personnel authorized to approve a PDR had read the notice of violation. This matter was discussed with CPS management and with the Vice President

- Nuclear at the exit meeting in order to assure that future corrective actions are carried out as committed in a timely fashion.

This item remains open pending completion of the required training.

bb. (0 pen) Violation (461/86023-01): Maintenance work requests not performed in accordance with written instructions, procedures, and drawings. An inspection of maintenance activities being performed by the plant staff maintenance department and the maintenance contractor, Stone and Webster (S&W) identified a number of examples where written instructions were not adhered to.

During this report period, the applicant formally responded to the violation and stated that full compliance would be achieved by July 30, 1986.

Item "a." of the notice of violation (NOV) identified a Maintenance Work Request (MWR) performed by plant staff that had work done that did not address the problem described. In addition, the post maintenance functional testing required by the MWR job steps was l' not documented as having been performed. The applicant initiated MWR-C20749 to perform a functional test of the item described above.

In addition, the applicant provided letters from the Supervisor -

Control and Instrumentation (C&I) to the technician and Assistant (C&I) Supervisor involved with the original MWR stressing the importance of completing MWR job steps, paying attention to detail, and reviewing work documents to ensure all work is complete. The above comments were also stressed at C&I group meetings. Based on the above corrective action and the inspector having witnessed a satisfactory functional test on the equipment involved in the original MWR, the inspector concluded the applicant's specific corrective action in response to item "a." was adequate. The violation identified in Paragraph 2.q. above will require an additional response concerning generic corrective action on this item. This matter will be followed under that violation.

Item "b." of the NOV identified that maintenance work requests (MWRs) requiring a review by Quality Assurance after completion of work (identified as QMWRs) had not been routed to QA prior to transmittal to the CPS records storage vault. The applicant initiated a Condition Report (CR No. 1-86-05-004) and identified i all QMdRs processed by their maintenance contractor S&W. The applicant determined that 12 MWRs had been classified as QMdRs and that ten of those had not received the requisite QA review. All 20

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12 QMWRs were resubmitted to IPQA for final review, and no adverse conditions were identified by the applicant. The applicant. revised the governing procedure (CPS No. 1029.01), revised tracking forms used by the maintenance contractor, and provided training to S&W Maintenance Engineers. Based on the above corrective action and a recent related inspection performed during the last. inspection period (reference Inspection Report No. 50-461/86037, Paragraph 8),

the inspector concluded that the applicant's response to item "b" was adequate.

Item "d." of the NOV identified a number of MWRs that did not receive the required ISI Repair Coordinator review prior to their being vaulted. The applicant initiated a Condition Report (CR No. 1-86-05-008) and identified all MWRs that had been processed by S&W without receiving the required ISI review. A total of 42 MWRs were found to need review and of that total, two MWRs required Post Maintenance Testing. The applicant provided training to the S&W Maintenance Supervisors, Planners, and Engineers who had responsibility for assuring that MWRs were properly processed for ISI review. Based on the above corrective action and a recent related inspection performed during the last inspection period (reference Inspection Report No. 50-461/86037, Paragraph 8), the inspector concluded that the applicant's response to item "d." was adequate.

Item "c." of the NOV identified a MWR where work was performed without routing the MWR back to planning when a change in scope was required. At the conclusion of the report period, the inspector was still reviewing the applicant's response. The inspector requested additional information concerning the applicant's corrective action to avoid further violation. Pending the inspector's review of the requested information, this item will remain open.

One violation and one deviation was identified.

3. Generic Letter Followup (92703)

(Closed) Generic Letter 85-07(461/85007-HH): Implementation of integrated schedules for plant modifications. This generic letter distributed a survey form to collect views, intentions, and concerns regarding an integrated schedule for plant modifications.

The applicant responded to this generic letter via IP letter U-600207, dated August 5, 1985. In their response, the applicant provided the staff its decisions and methodologies concerning integrated schedules.

The applicant stated in the referenced response that a prioritization methodology for plant modifications would be selected prior to fuel load.

This generic letter was reviewed in Inspection Report No. 50-461/86037.

At the time of that inspection, the applicant's files did not identify the prioritization methodology which IP had committed to provide prior to fuel load.

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During this report period, the applicant provided via IP memorandum Y-202760 dated July 15, 1986,'a description of the intended prioritiza-tion methodology as follows:

a. The originator of the Plant Modification normally suggests a priority of the modification at the time of origination in accordance with Clinton Power Station Procedure 2003.01 " Design Control and Modification."

b. In accordance with Corporate Nuclear Procedure (CNP) 4.08 " Plant Modification System," Sections 2.3 and 2.6, the Manager of Nuclear Station Engineering and the Manager of Clinton Power Station review and recommend a priority for plant modifications,

c. In accordance with CNP 4.08, Section 2.1, the Vice President is responsible for approving the priority and the schedule for Plant Modifications. Modification priorities are defined in Attachment 2 to CNP 4.08 as follows:

Emergency - Modifications which must be made immediately to avert or correct situations that could lead to the imminent loss of operating capability, damage to equipment, or endangerment of the health or safety of employees or.the public.

Urgent - Modifications for which installation is required to maintain safe, reliable, and efficient operation.

Priority - Modifications which providb improvement in the safe, reliable, and efficient operation of the plant or result in significant cost savings and are constrained by time and/or event.

Routine - Modifications which provide improvements in the safe, reliable, and efficient operation of the plant or result in cost savings.

d. Although not specifically required by procedures, the Director of Configuration Management monitors the scheduling and tracks the completion of Plant Modifications by Milestone designators.

The applicant had selected a prioritization methodology as described above. This item is closed.

4. Review of 10 CFR 21 Report (92700)

(Closed) 10 CFR 21 Report (461/80001-PP): General Electric (GE) Nuclear System Protection System (NSPS) power distribution panel C71-P011 deviates from separation requirements of Regulatory Guide 1.75 in that' four divisions of power plus nonessential power are used within the panel without isolation or proper isolation.

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4 Correction of 'the deviation was accomplished by GE redesigning the power distribution panels as well as modifying the NSPS panels to accept the new power distribution design. Power distribution panel C71-P011 was replaced by two panels C71-P011A and C71-P011B. Records contained in the IP file for this matter,=21-80-01, showed that IP had completed the installation of the two distribution panels, and GE had completed revisions.to the NSPS panels to make them compatible with the revised power distribution scheme. These changes were accomplished to satisfy concern identified in Item 8.4.7 of the Clinton Supplementary Safety Evaluation. Report Supplement. Ccnstruction and preoperational testing of the NSPS has been completed by IP. This matter is closed.

5. Employee Concerns (99014)

The inspectors reviewed concerns expressed by site personnel from time to time throughout the inspection period. Those concerns related to i regulated activities were documented by the inspectors and submitted to .

Region III. Two concerns were transmitted to the regional effice during-this report period.

6. Functional or Program Areas Inspected ,

a. Site Surveillance Tours (71302/60501)

Surveillance tours of selected areas of the site were-performed at periodic intervals throughout the report period. Those surveillances were intended to assess: cleanliness of the site; storage and maintenance conditions of plant equipment and material; potential for fire or other hazards which might have a deleterious effect on personnel or equipment; storage conditions of new fuel; and to witness maintenance and preoperational testing activities in  !

progress.

, (1) New Fuel Storage Several tours of the new fuel storage area identified no '

deviations from the special nuclear materials license requirements for security, fire protection, and environmental controls for new fuel storage.

(2) Housekeeping and Cleanliness Control

! Early in the report period, the inspectors observed that i improvements in the cleanliness of the drywell had not kept

! pace with improvements observed in general plant cleanliness.

i In addition, the cleanliness of the suppression pool and, in

! particular, the drywell weir area of the suppression pool, had

degraded over past observations. This matter was discussed i

between NRC and IP management representatives on July 3,1986.

IP stated that prompt action would be taken to address the current cleanliness condition and to prevent recurrence.

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t The next day, the resident inspectors observed that action had been taken to prevent further accumulation of dirt, debris, and other materials in the suppression pool weir area. Additional

. plastic had also been placed over access grating to prevent dirt and debris from falling through the containment building and into the suppression pool. A large crew of laborers were assigned to upgrade the cleanliness and housekeeping condition of the drywell and plans were prepared for cleaning the suppression pool using divers and a special underwater vacuum system.

The applicant made progress on this activity throughout the report period. At the conclusion of the inspection, the inspectors noted the following:

(a) Diving operations had substantially improved the cleanliness of the suppression pool. The diving operations were still in progress on July 27, 1986.

The drywell weir area was not available for visual inspection due to the installation of barriers to maintain cleanliness. The applicant stated that the weir area had been returned to the required level of cleanliness.

(b) Cleaning / housekeeping operations had improved the level of cleanliness in the drywell. The work was still in progress on July 27, 1986. Additional cleaning / house-keeping was needed to achieve a satisfactory level of

, housekeeping .in the drywell.

(c) Continued attention to housekeeping and cleanliness control was needed and apparent.

The resident inspectors will continue to monitor the applicant's activities in this area.

. (3) Floodproofing Of Shutdown Service Water pump (SSW) Cubicles On July 25, 1986, during a routine tour of the SSW portion of the CPS screenhouse, the inspector noted that a security vital area boundary had been posted inside the Division II SSW pump cubicle. Since the SSW pump cubicles were designed to be a floodproof vital area, the inspector reviewed the matter and noted the following.

According to the CPS FSAR, Paragraph 9.2.1.2.3, the'SSW pump cubicles and all system piping are protected from tornado generated missiles and floods. According to FSAR Paragraph 3.4.1.1, measures adopted for seismic category I systems and components located below the probable maximum flood (PMF) level (defined as elevation 708.9 feet for CPS) include:

24

(a) water stops in all construction joints up to the maximum flood level; (b) water seal rings for all penetrations in exterior walls below the maximum flood level; (c) watertight doors designed to withstand the hydrostatic head of the PMF level on exterior walls below the maximum flood level; and (d) a hatch on the roof of the essential service water pump structure for access during PMF.

The inspector observed that the floor of the SSW pump cubicles

• was located at elevation 699.0 feet. The SSW pipe tunnel (at elevation 657.0 feet) was located below the SSW pump cubicles and connected directly to the division II SSW pump cubicle through a manway that had no watertight barrier. The pipe tunnel, which contained piping from all three divisions of SSW, ran across the entire eastern end of the screenhouse structure.

It had been designed to allow direct access from Unit I to Unit II (the cancelled unit) SSW equipment without leaving the vital area of the plant. Another manway from the pipe tunnel to the Unit II Division II SSW cubicle floor (the cubicle was never constructed) provided the access pathway; this exterior wall (floor) was not flood protected. Because Unit II was never completed, incomplete construction openings at the 699.0 foot elevation (which would have been on the floor of the Unit II SSW pump rooms) provided additional access to the SSW pipe tunnel; this exterior wall (floor) was also not flood protected. This finding indicated that the construction of the SSW portion of the CPS screenhouse had not been completed in conformance with the requirements of 10 CFR 50 Appendix A, General Design Criterion II and the CPS FSAR in that the Unit I SSW cubicles and system piping were not protected from the effects of flooding. Discussion with the applicant indicated that the screenhcuse had been completed by the constructor, Baldwin Associates, and had been accepted by the applicant's operating organization on December 11, 1985.

Implementation of the CPS Quality Assurance Program for turnover and acceptance of plant areas and commodities did not identify the above deficiency. The failure of IP to assure that the screenhouse SSW system pump cubicles and piping tunnel were completed in compliance with the CPS FSAR prior to final acceptance is a violation of 10 CFR 50, Appendix B, Criterion II and the IP Operational QA Manual, Chapter 2, which states in part that the IP Nuclear Power Operational QA Program. . . is implemented to assure that necessary inspection and testing on the transferred system, structure, or component are performed and properly evaluated and to confirm that the system, structure, or component will perform satisfactorily (461/86048-03).

One violation was identified.

25

a

• e

b. Operating Procedures Review (42450)

This inspection completed a review of procedures to be used in the plant operations phase (reference Inspection Reports No. 50-461/86017 86023, and 86037).' The purpose of this inspection was to confirm that the plant operating procedures are prepared to adequately .

control safety-related operations within applicable regulatory requirements. This inspection is complete with the exception of resolution of open/ unresolved items identified during the inspection.

(1) Completed Review The operating procedures listed below have been reviewed and appeared to be technically adequate to guide the accomplishment of the purpose stated in the scope of the procedures. Questions and comments discussed with the applicant were either already addressed in the applicant's procedure review program or responses to the inspector's question resolved the comment.

Procedure Revision Title (a) 3001.01 3 Approach to Critical (b) 3002.01 4 Heatup and Pressurization (c) 3203.01 3 Component Cooling Water (2) Discussion The inspector questioned the 6pplicant concerning the availability of BWR-6 operating experience for feedback into the CPS integrated plant operating procedures. The inspector noted that ANSI N18.7-1976, Paragraph 5.2.15 considered the feedback of operating experience an important factor in the ongoing development and improvement of all plant procedures.

The inspector suggested the applicant obtain copies of the integrated plant operating procedures from an operating BWR-6 to determine if CPS may benefit from the cperating experience

- already gained on this model boiling water reactor. The applicant acknowledged the suggestion.

(3) Results No violations or deviations were identified. The procedures reviewed appeared adequate to control safety-related plant operations within applicable regulatory requirements.

The feedback of operating experience, consistent with ANSI N18.7-1976, should result in improved procedures.

\ 26 i

y,..-y_ ,y-._. . . - , _ _ . , . - - . _ . , , _ , _ _ _ - - - _ _ - . - _ .

_ _ , - _ - ~.,,..____m.,-_,,m.-,,__.__..--...y-y_, r ,. ,-.______,.--__%, , -

r

c. Emergency Procedures Review (42452)

This inspection commenced a review of procedures to be used in the plant operations phase to confirm that the plant emergency procedures are prepared to adequately control safety-related functions when a system or component malfunction is indicated.

(1) Applicable Requirements, Applicant Commitments, and Guidance Documents (a) 10 CFR 50 (b) Regulatory Guide 1.33, Revision 2, " Quality Assurance Program Requirements" (c) ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" (d) ANSI N45.2-1977, " Quality Assurance Program Roquirements for Nuclear Fac111 tie;"

(e) CPS No. 2005.01, Revision 16, " Preparation, Review and Approval of Station Procedures" (f) Various System Annunciator Panel Drawings (2) Procedures Reviewed The procedures reviewed were for annunciator panels that include all alarms located on the Display Control System, the 680 panel.

(a) CPS No. 5000, Revision 20, " Alarm Panel Annunciators 5000.01 through 5000.30" (b) CPS No. 5001, Revision 20, " Alarm Panel Annunciators 5001.01 through 5000.40" (c) CPS No. 5002, Revision 20, " Alarm Panel Annunciators 5002.01 through 5002.75" (d) CPS No. 5003, Revision 20, " Alarm Panel Annunciators 5003.01 through 5003.60" (e) CPS No. 5004, Revision 20, " Alarm Panel Annunciators 5004.01 through 5004.33" (f) CPS No. 5005, Revision 20, " Alarm Panel Annunciators 5005.01 through 5005.33" (g) CPS No. 5006, Revision 20, " Alarm Panel Annunciators 5006.01 through 5006.60" (h) CPS No. 5007, Revision 20, " Alarm Panel Annunciators 5007.01 through 5007.60" (1) CPS No. 5008, Revision 20, " Alarm Panel Annunciators 5008.01 through 5008.55" (j) CPS No. 5009, Revision 20, " Alarm Panel Annunciators 5009.01 through 5009.45" (3) Discussion The inspector verified that each procedure was in the format specified ir. CPS No. 2005.01. The inspector verified that each procedure was technically adequate to accomplish its 27

9

^

stated purpose, that is, the procedures were clear, concise, and easily readable; the titles were descriptive of the emergency, and the procedure contained the alarm set point, other indications, possible causes, nutomatic actions, and operator actions.

The inspector observed the annunciator windows at the operator's console and compared the window engravings with the nomenclature used in the procedures and associated drawings. The inspector determined that there were minor differences between all three references including the use of multi-colored annunciator lenses which were not mentioned in the procedures. The inspector was mainly concerned with how changes made to the annunciator panels would ultimately be reflected in the procedures utilized by the operators in the control room, and how the window engravings, procedures, and drawings would all be made identical.

Based upon discussions with cognizant IP personnel, the inspector determined the following:

The meaning of the multicolored annunciator lenses, while, amber, red, red / blue, and blue, is included in the " Control Room Operator's Handbook" and part of routine operator training sessions. Therefore, the meaning of the colored lenses was not needed to be part of the annunciator procedures.

Systems final released to Plant Staff have design changes controlled by procedures CPS No. 1003.01, " Design Control and Modification," and CPS No. 2003.04, " Design Change Transition." Both procedures include the requirement for determining the impact of the modification on procedures.

Control room annunciator panels were being " walked down" independently of system turnover. The walkdowns were being performed on a panel basis according to Operations Standing Order (050) 047 which ensures that all alarms and panel engravings are properly identified, and annunciator response procedures properly address all alarms per design drawings. The walkdowns will ensure that all changes made to annunciators, including those made prior to final system release to Plant Staff, comply with 050 047.

The inspector reviewed results of walkdowns made in reference to annunciator panels 5000 and 5001. The walkdowns were in compliance with 050 047, and the activity was being tracked on the IP Commitment Tracking Syi. tem as number 042803. The commitment was to complete a wa16down of all control room annunciators before fuel load, and all remaining annunciators prior to exceeding 5'. power.

28

3 4

Results c Annunciator response instructions were adequate to aid operator's responses to alarm conditions; minor procedural discrepancies identified by the inspector were being corrected by the applicant in accordance with approved written instructions and commitments to correct annunciator discrepancies were appropriately tracked. Inspection of Off-Normal procedures will be documented in a subsequent inspection report.

No violations or deviations were identified.

d. Plant Procedures Review (42400)

This inspection continued a review of procedures to be used in the plant operations phase (reference Inspection Reports No. 50-461/85005, 85012, and 85063) to confirm that the scope of the plant procedures system is adequate to control safety-related operations within applicable regulatory requirements, and to verify the adequacy of management controls in implementing and maintaining a viable procedure system.

(1) Applicable Regulatory Requirements and Applicant Commitments (a) 10 CFR 50 (b) Regulatory Guide 1.33, Revision 2, Quality Assurance Program Requirements (Operation)

(c) ANSI N18.7-1976, Administrative Controls and Quality Assurance For The Operational Phase Of Nuclear Power Plants (d) ANSI N45.2-1977, Quality Assurance Program Requirements For Nuclear Facilities

. (e) CPS Final Safety Analysis Report (FSAR), Chapter 13.5 through amendment 33 (f) CPS Draft Technical Specifications (2) Procedures Reviewed (a) CPS No. 3001.01, Approach To Critical, Revision 3 (b) CPS No. 3002.01, Heatup And Pressurization, Revision 4 (c) CPS No. 3003.01, Heatup And Pressurization, Condenser Isolated And Condenser Recovery, Revision 4 29

(d) CP5 No. 3004.01 Turbine Startup And Generator Synchronization, Revision 3 (e) CP5 No. 3005.01, Unit Power Changes. Revision 3 (f) CPS No. 3006.01, Unit Shutdown, Revision 4 (g) CP5 No. 3007.01, Preparation For And Recovery From Refueling Operations, Revision 1 (h) CPS No. 1041.01, Post Trip Review, Revision 1 (3) Discussion The inspector reviewed the purpose of the CPS integrated plant operatingprocedures(identifiedin(2)above)againstthelist of procedures identified in Appendix A to Regulator Quality Assurance Program Requirements (0peration).y The Guide 1.33, inspector noted that the approved procedures available in the CPS Operating Manual included all integrated plant operating p(F5AR) Chapter 13.5.rocedures The procedureslisted in the purpose CPSwere sections Final Safety Analysis required by CPS No. 1005.01, Preparation. Review, and Approval Of Station Procedures And Documents, to clearl purpose for which the procedure was intended. y identify the The inspector found, on the basis of a review of the procedure purpose alone, that the operations covered by Regulatory Guide 1.33 Appendix A. Paragraph 2.c. 2.d. and 2.g were not procedurally addressed. Discussion with the applicant indicated that the operations in question were covered by the integrated plant operating procedures but were not explicitly included in the procedure purpose section. Due to a lack of available inspection time and considering the nature of the operationsinquestion(i.e.,RecoveryFromReactorTrip, Operation At Hot Standby, and Power Operation and Process Monitoring)(, this matter remains open pending a future inspection 461/86048-04).

(4) Results One open item was identified for followup inspection after fuel load.

7. Region !!! Requests (92701)

a. 5tfeteam Status The inspector selected a sample of Safeteam concerns for followup inspection by a Region !!! specialist inspector (reference Inspection Report No. 50-461/86004, open item 461/86004-01).

30

n 3

The fo110 win 9 concerns were selected and copies of records related

to Safeteam investigation of each concern were transmitted to Region III

20028-A* 12023-C*

10270-A 12099-A

l. 10490-A 12704-A l 11676-A

• Previously reviewed in Inspection Report No. 50-461/86004.

l The inspector also reviewed the current status of Safeteam activities to update information contained in the previous report.

The following information was obtained concerning the status of Safeteam concerns as of July 18, 1986:

DATA TYPE NUM8ER Number of Individuals Processed Through the SAFETEAM Appreciation Center. . . . . . 9391 Number of Exit Interviews . . . . . . . . . . . . . 897 Number of Scheduled Interviews .......... 1628 Number of Drop-Ins ................ 243 Telephone Calls Received ............. 95 i

Letters Received ................. 241 Total Number of Interviews Conducted ....... 3104 Total Number of Quality Concerns Received . . . . . 1909 Total Number of Quality Concerns Open . . . . . . . 29 Total Number of Non-Quality Concerns Received . . . 929 Total Number of Non-Quality Concerns Open . . . . . J5 l Total Number of Concerns Closed ......... 2794 Total Number of Concerns Open . . . . . . . . . . . 44 Total Number of SAFETEAM Substantiated Concerns Requiring SAFETEAM Initiated Corrective Action . . 106 The above status indicates that the SAFETEAM has processed a substan-tial number of employees; that a significant number of quality related concerns were received and investigated by the SAFETEAM; and that l

31

C only a minimal number of concerns were open at the time of this inspection. The SAFETEAM director indicated that there was essentially no backlog of concerns at the time of this inspection (i.e., each open concern was currently under investigation).

b. Diesel Generator Event Followup On July 1,1986, the applicant informed the NRC that on June 29, 1986, the Clinton Power Station's division I Emergency Diesel Generator (EDG) was inadvertently started when the generator became motorized. At the time of occurrence, the diesel engine was

" mechanically" tagged out-of-service in preparation for a plant modification to the diesel engine lubrication system.

The EDG apparently became motorized when the associated 4160 volt bus IA1 for Division 1 wts energized after a maintenance outage.

Upon energization of the 1A1 bus from the emergency reserve auxiliary transformer (ERAT), the EDG-1 output breaker closed automatically and caused the EDG-1 generator to act as a motor.

This motoring action was sufficient to start the diesel engine.

The 1A1 reserve feed breaker (ERAT supply) tripped soon after the diesel engine had started. The third source of power to the 1A1 bus was the reserve auxiliary transformer (RAT) which had been tagged out for maintenance and did not reenergize the IA1 bus.

Since the EDG-1 output switch was positioned in " maintenance" and control circuits were deenergized and tagged, plant operators were unable to use normal methods to stop the diesel engine. The diesel engine continued to run for about five minutes until an operator was able to close the fuel racks and shut down the machine.

The applicant wrote a condition report and performed an investiga-tion. Immediate action taken included additional tagouts for the EDG-1 output breaker to be in the " racked-out" position. The applicant's investigation revealed that the Division ! EDG had operated as designed and that the event was caused by an inadequate tagout(personnelerror).

As a result of the above incident, Region III requested that the inspector observe a portion of the applicant's actions taken to assure that no damage had been caused to the EDG. The applicant provided chemical analysis results of lube oil samples taken from the Division ! EDG sumps. The applicant stated that the analytical results indicated normal lube oil (like new) with no damage to the machine apparent through the lube oil analysis.

The applicant's investigation of the above incident determined that a number of inspections should be performed prior to operating the EDG, as follows:

(1) Perform a crankshaft thrust check.

(2) Check piston to head clearances.

32

~,

(3) Check connecting rod snap rin (4) Check for bearing damage at (gs.1) the turbocharger, (2) the lower main bearings.

(5) Perform chemical analysis of lube oil samples.

Generator i Vendor perform visual inspection of generator internals.

Vendor check clearances, as required.

Perform vibrational analysis the first time the generator is run.

The above actions had not been completed at the conclusion of the inspection period. The inspector reviewed chemical analysis results for lube oil samples taken from the Division ! EDG lube oil sumps and discussed the results with a Region !!! specialist inspector.

The specialist inspector agreed with the applicant's conclusion regarding damage but identified that, according to the EDG manufacturer's maintenance instruction (MI) No. 1762 Revision E, there was indication of possible contaminants in the fuel oil and a potential for silicon contamination of the combustion air intake.

l The inspector brought these indications to the applicant's attention.  :

Fuel oil samples were obtained and sent offsite for analysis. The '

app 1tcant completed their review of these indications and concluded t1at the fuel oil was not' contaminated. New lobe oil analysis indicated that aluminum was a normal constituent of the oil. The  !

silicon problems came from sand blasting of the air intake pipes prior to installation.

y On July 3, 1986, the inspector observed the applicant's mechanical  !

1 maintenance department perform a visual inspection of a sample of ,

I' the lower main bearings and the turbocharger bearing for the '

Division I EDG. The applicant's personnel were ascisted by an EDG

{ specialist from Morrison Knudson Company. The inspector reviewed  :

i tie results of lead wire readings taken on Division ! EDG and the

visual inspection results with a Region !!! specialist inspector. '

There was no indication of damage to any portica of the machine. ,

j One stuck fuel injector was identified by the applicant and was ,

replaced. The inspector requested the results of the applicant's

! comparison of the lead wire reading results with the original

! factory (" Birth")recordsforthemachine. This comparison had

! not been completed at the conclusion of the inspection. '

The applicant concluded that the Division ! EDG engines had not been i damaged by the event. Actions to complete the modifications to the ,

lube oil system were completed during the report period. However,  ;

i (a)theEDGhadnotbeenrun;(b)vibrationreadingsonthegenerator hadnotbeentaken;and(c)thecomparisonoflead-wirereadingswith leted at the conclusion of the l

thebirthrecordshadnotbeencomp(461/86048-05).

inspection. This is an open item l

4 33

]

c. Operational Readiness Assessment The inspector reviewed the licensee's administrative controls for the identification, tracking, scheduling, and accomplishment of remaining facility work items requiring completion prior to fuel load as well as subsequent operating milestones. This review was conducted to assure that these administrative controls were comprehensive in scope and addressed remaining work items associated wit 1 all aspects of facility design, construction, testing, licensing, and operation. The review was also conducted to assess the decisional process by which work items were ,cheduled for completion. The following Clinton Power Station (CPS) Procedures andStartupAdministrativeProcedures(SAPS)wereincludedinthe inspector's review and assessment:

Procedure Number T1t1e SAP-03 " Field Problem Reporting" 5AP-06 " Phase 2 Release" CPS No. 1040.01 " System Release, Review, and Acceptance" CPS No. 1042.01

" Area Release" CPS No. 1014.02 " Designating Systems Ready For Fuel Load" CPS No. 1002.04 " Maintaining, Modifying, and Operating Systems" CP$ No. 1401.01 " Conduct of Operations" At the time of this inspection, jurisdictional control of all plent systems had been transferred from the construction organization to tne startup and operating organizations. All safety-related plant areas were under the jurlsdictional control of the operating

, organization. The licensee's program for plant completion employed a computer-based date management system called the Site Wide Statusing System. This system tracked the status of items from a large number of data bases pertaining to plant design issues and documents, construction, preoperational testing, maintenance, modifications, operation, surveillance testing, licensing issues, quality assurance organization findings, NRC inspection and

' enforcement items, p ant procedures, and personnel training. The sitewide statusing system provided licensee management with an overview of remaining work and a consolidated list of things to be accomplished in support of fuel load and subsequent operating milestones. Items contained on the Sitewide Status System had been subjected to preliminary reviews by the licensee's engineering and licensing staffs and completion milestones had been assigned to each item. At the time of this inspection, the licensee indicated that further reviews would be conducted and refinements to the assigned completion milestones would be forthcoming.

34

The licensee's programs and procedures for plant completion broke down the remaining work items on a system and area basis.

Work items which were not specific to any given system, but instead pertained to plant structures were sorted and managed by the areas of the plant to which they pertained.

Items pertaining to specific systems were evaluated for significance prior to release of a system to the startup organization and again prior to the time the system was released from the startup organization to the plant staff. When jurisdictional control was released to the plant staff, remaining preoperational testing, system configuration control, maintenance, surveillance testing, equipment lineups, and operations were controlled by the licensee's operating quality assurance program and plant procedures.

Outstanding items which remained at the time of system turnover to the plant staff, were subsequently reevaluated by cognizant engineering, licensing, technical, quality assurance, and operating personnel to determine impact on system operability. Based upon these evaluations and technical specification equipment operability requirements, the items were scheduled for completion. Following completion of significant work items required for fuel load and performance of system unique surveillance tests, systems were declared " ready for fuel load." Remaining work items against a system declared " ready for fuel load" were tracked either as exceptions (i.e., items which must be completed prior to fuel load) ordeferreditems(i.e.,itemswhichmaybecompletedsubsequent tofuelload).

Following completion of integrated system surveillance tests, verification that supporting systems and equipment are operable or in service, and completion of remaining work items detennined to have an impact on system operability, systems will be declared operable for the purposes satisfying technical specification requirements. System operability will be statused and maintained in accordance with the licensee's operating administrative controls which utilize checklists for verifying that required systems and equipment are operable prior to entering the applicable Operational Condition. In addition to the foregoing, the licensee has established a comprehensive set of prerequisites as part of startup test procedure STP-03, " Fuel Load" to provide additional assurances that required systems and equipment are operable or in service, as applicable, prior to initial entry into Operational Condition 5.

As previously discussed, when systems were declared " ready for fuel load," remaining work items which impacted system operability were to be tracked as exc(ptions or deferred items. The inspector determined by review of documentation pertaining to declaration of the Low Pressure Core Spray system (LPCS) " ready for fuel load " by discussions with the Senior Resident Inspector, and by visual examination of portions of the LPCS system during plant tours, that .

35

1 a number of conditions existed which potentially impacted LPC$ l system operability and which had not been identified, documented,  ;

evaluated, and scheduled for correction prior to declaration of LPCS i operable per technical specifications. These conditions should have 1 been identified during system walkdowns conducted prior to release i of the LPC5 system to the plant staff. These and other deficiencies i

concerning the adequacy of prior system walkdowns were previously  ;

identifiedasopenitem(461/86037-04A). Licensee actions to assure i that such conditions are properly identified, documented, and i resolved in a timely manner are discussed in Paragraph 2 of this report, l t

The inspector reviewed documented inter-disciplinary evaluations of t the Division 1 diesel generator and the component cooling water i system conducted in accordance with Clinton Power Station number 1014.02 " Designating Systems Ready for Fuel Load."The procedure t i

documented evaluations were conducted by the licensee's engineering,  ;

startup, quality assurance, licensing and safety, project management,  !

technical, and operating organizations and included determinations  !

of the impact of identified work items on system operability, provided a schedule for resolution of each item, and provided  ;

documented bases for the schedule. The evaluations were assembled i by the Plant Technical Department System Engineers and submitted for approval by the Director of the Plant Techn< cal Department, Director, {

Plant Operations, and the Plant Manager. The inspector's review determined that identified items were appropriately scheduled based .

upon adequately detailtd and documented evaluations. l t

The licensee's mananoment approach to assuring facility readiness was found to be sim'lar to that employed by a number of other recently licensed facilities. The remaining work items, while ,

varying considerably in scope and complexity, were enumerated in a manner quite comparable to that employed at the other facilities.  !

Continued attention to detail and conscientious implementation of the established administrative controls should provide the requisite  :

assurance of operational readiness to support issuance of the '

operating license. -

No violations or deviations were identified.

8. Site Activities of Interest  ;

a. Fuel Load Schedule (94300)  !

On June 17, 1986, the applicant notified the NRC by letter that {

CPS would be ready for issuance of a low power license on or about >

July)15,1986. Attheconclusionoftheinspectionperiod(July 28,  !

1986 , there were no plant systems declared operable under the CPS l final draft technical specifications to support fuel load. That l activity was in progress. The applicant believed that CPS would be ready to load fuel by August 7, 1986.

{

36  !

( __

o

b. Readiness For Fuel load Meeting (30702) 1986 On July 10,(NRR),and Region !!! met with IP management at th Regulation Visitor's Center to discuss the current state of readiness of CPS to load fuel. This was the sixth of a series of such meetings to be held with IP management on a routine (monthly) basis. Key personnel attending the meeting are identified by (+) in Paragraph 1 of this report.

The meeting, which lasted about three hours, included the following:

1 (1) A short introductory statement by the NRC Director - 8WR Licensing, Office of NRR, concerning the purpose and scope of the meeting.

(2) Opening remarks by the President - IP.

(3) An introduction and briefing by the IP Vice President - Nuclear concerning the current status of CPS.

(4) A detailed discussion by key IP managers of areas significant to the licensing process.

(5) A summary discussion by the IP Vice President - Nuclear concerning mana l and challenges.gement philosophy, policy, organization.

l (6) Closing remarks by the NRR Director - BWR Licensing.

(7) An opportunity for questions / comments from members of the public and news media representative.

There was no schedule detennined for a follow on meeting,

c. IP Management Change (71302)

On July 8, 1986, the a Quality Assurance (QA)pplicant announced that the IP Manager -

was taking a lateral transfer to replace the Manager-NuclearPlanninqandSupport(NP&S). The fonner Mana NP&S was a contractor to 'P whose contract was to expire soon. ger On -

July 17, 1986, the applicant named the IP Director - Quality Systems and Audits as the new Manager - QA.

d. _IP Labor Negotiations (92709) l On July 16, 1986, the applicant notified the NRC Senior Resident

{

InspectorthatthefourunionsrepresentingIllinoisPower(IP)

Company workers, including those workers at Clinton Power Station.

l voted not to accept the conditions of IP's recent contract proposal.

The vote also gave the bargaining comittee for the four unions l

l concurrence to authorize a strike, if warranted. The unions have 37

,. a U. S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-461/86054(DRP)

Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street '

Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Conducted: July 28 through September 8,1986 Inspectors: T. P. Gwynn P. L. Hiland

8. H. Little S. M. Hare

8. L. Siegel J. F. Schapker W. Liu Approved By:

RrldA R. C. Knop, Chief

& f/ft/F4 Projects Section IB , (Tate Inspection Summary ,

Inspection on July 28 through September 8.1986 (Report No. 50-461/86054(ORP))

Areas Inspected: Routine safety inspection by three resident inspectors, three regional based inspectors, and the licensing project manager of ,

preoperational testing and operational preparedness activities including '

applicant action on previous inspection findings; applicant action on 50.55(e) item; employee concerns; functional or program areas (including site surveillance tours and emergency procedure review); independent inspection ,

(including review of electrical penetration status; ESF system walkdown; control room observations; and onsite review committee activity); safety evaluation report review and followup; inspection of Title 10 requirements; and site activities of interest.

Results Of the twelve areas inspected, no violations or deviations were identified in eleven of the areas. One violation was identified in the area of ESF system walkdown (failure to write a condition report - paragraph 6.b).

The specific violation by itself was not highly significant; however, the licensee has been requested to determine generic implications.

-Q &ODl1-

.o 9.

DETAILS

1. Personnel Contacted Illinois Power Company (IP)

$ D. Antonelli, Director, Operations 8 *K Baker, Supervisor - 1&E Interf ace, Licensing and Safety

• G. Bell, Assistant to Manager, Scheduling and OM

$ +*R. Campbell, Manager - QA

$ *W. Connell, Manager - Nuclear Planning & Support 5 J. Cook Ass

$ E.CorrIgan,istantPlantManagerDirector, Quality Engineering and Verification

$ H.Daniels,ProjectManager

$ J. Dodson, Supervisor, Nuclear Communications

$ L. Ferguson, Utility Engineer, ICC

$ 5. Fisher, Manager, Nuclear Planning & Support

$#+*W. Gerstner, Executive Vice President

$ K. Graf, Director - Operations Monitoring

$ + J. Greene, Manager - Nuclear Station Engineering Department (NSED)

$ R. Greer, Director - Dutage Maintenance Programs

$#+*D. Hall, Vica President, Nuclear

$ T. Helton, Supervisor, Visitor Center

$' O. Hillyer, Director, Radiation Protection 8 'D. Holtzsher, Director - Nuclear Safety

$ R. Hubbard, Consultant (Vice President of MHB), Illinois Atty. Gen'1.

$ J. Jenkins, Accounts & Finance, ICC

$ 5. Johnson, Attorney (Schiff Hardin)

$ *E. Kant, Assistant Manager, Nuclear Station Engineering Department

$ W. Kelley, President &' Chairman of the Board

$ R. Kerester, Director - Field Engineering

$ P. Lancaster, Supervisor - Labor Relations

$ B. Lillyman, Public Affairs

$ J. Marshall, Accounts & Finance, ICC

$ G. Miller, Director - Fiscal Management 4 J. Miller, Assistant Manager - Startup

$ R. Morgenstern, Director, Technical

$ D. Morris, Director - Nuclear Program Scheduling 5 J. Palchak, Supervisor - Plant Support Services a . $ J. Palmer, Director, Configuration Management

$ K. Patterson, Director, Materials Management

$# 'J. Perry, Manager - Project Control Center

$ Assistant Director - N$[D P. Richey, R. Raysircarl D rector, Plant Maintenance

$ T. Riley, Supervisor Licensing Operations

$ A. Ruwe, Director, Design Engineering N$[0

$ *R. Schaller, Director - Nuclear Training  ;

$ F. Schwarz, Director, Dutage Maintenance & Support

$#+*F. Spangenberg, Manager - L&S *

$ [. Till, Supervisor, Emergency Response

$ E. Vaughan, Director, Reliability Engineering 2

,o r 9, 8 *J. Weaver, Director - Licensing .

6 N. Williams, Director - Support Services

$# *J. Wilson, Manager - Clinton Power Station (CPS)

$# R. Wyatt, Director - Muclear Program Assessment 6 + 5. Zabel, Attorney for Illinois Power Sarnent and Lundy

+R. Heider, Project Manager, Sargent & Lundy

+M. Showski, Mechanical Project Engineer, largent & Lundy i i +P. Wattelet, Project Director, largent & Lundy r loylandNicco ,

$8J. Greenwood, Manager, Power Supply U. 5. NRC

$8+*T. Gwynn, Senior Resident Inspector - Operations ,

$P. Hiland, Resident Inspector l

1. +C. Norelius, Director, Division of Reactor Projects, Region III

$+8 Davis, Deputy Regional Administrator, Region !!!

$#+R Warnick, Chief, Reactor Projects Branch 1. Region !!!  !

5+R Knop, Section Chief, Projects Section IB  ;

+M. Ring, Chief. Test Programs, Region !!!  !

1. C: Paperiello, Director, Division of Reactor Safety, Region !!!  ;

+J. Grobe, Director of Enforcement, Region !!! 1

+3, Stapleton, Enforcement Specialist, Reginn !!!  !

+B. torson,. Region Counse), Region !!! l t

i

• Denotes those attending the monthly exit meeting on September 8, 1986.  !

l + Denotes those attendin<1 tie Enforcement Conference on August 29, 1986.  !

$ Denotes those attending tiie monthly management meeting on August 7, ,

1986. .

l # Denotes those attending the monthly management meeting on September 8, j , 1986.'

The inspectors also contacted and interviewed other staff and contractor personnel.  ;

2. Applicant Action On Previous Inspection Findinns (92701) (92702) [

a. (closed) Open Item (461/85005 41): 55ER2, paragraph 7.4.3.2 -  ;

Verify installation of loss of voltage alarms prior to fuel load.  ;

This item was previously reviewed for closure in Inspection Reports l 50 461/86023, paragraph 2.c., and 50 461/86048, paragraph 2.q. ,

1 Each of those inspections identified violations related to the i adequacy of maintenance department actions taken to make the five  !

loss of voltage alarms operational. The corrective actions taken l by the applicant for those violations will be reviewed separately. l At the conclusion of the previous inspection, one of the five t loss of voltage alares was not fully operational, i

3 j

l,'

c, l During this inspection, the inspector observed the performance of an operational test performed by the plant operating staff to .

! demonstrate that each of the five less of voltage alems would l l result in activation of an annunciator in the control room. That t test was successful. This item is closed. ,

. b. (Closed) Open Item (461/85039-12): Emergency Sampling and Analysis Procedures. Duringapreviousinspection,itwasidentifiedthat

! neither the " norma " nor the " emergency" procedure for sampling and analysis had been completed.

l The applicant presented this item to the inspector for closure.

l Refer to inspection Report 50 461/86048, paragraph 2.t. That report indicated that this item remained open pending approval of draft procedures used to demonstrate stack offluent sampling and analysis procedures. The appilcant provided evidence that the draf t  :

procedures used during the demonstration had been approved. This r item is closed,

c. (0 pen)OpenItem(461/8603704A): Review of applicable procedures indicated that the procedure for declaring systems technical specification operable did not reflect minimum requirements needed  !

I prior to the declaration of operability. The applicant stated that t l the procedure, CPS No. 1401.01 Conduct of Operations, revision 7, l

. wouldberevisedtoimposeminImumrequirementsfortheinitial

. declaration of technical specification operability.

This item was previously reviewed in Inspection Report 50 461/86048, paragraph 2.w. At the conclusion of that inspection, two questions remained open as follows:

(1) IP was to provide a listing of plant systems required to support plant operation, by milestone, for NRC review, i

(2) CPS No. 1401.01 paragraph 8.5.10.1.2. required "The Fuel Load Milestone Coordinator (FLMC) shall coordinate a review of the lists in Appendix B by the appropriate departments. The l

departments shall ensure that the review verifies that open i items associated with the lists are correctly coded as non fuel load restraints". 7 The inspector requested that the FLMC identify the appropriate >

departments for each item listed in Appendix B and identify the  !

l l criteria to be used to make the required determination.

Ouring this inspection, IP provided a comprehensive list of plant  !

l systems required to support plant operation (by milestone) in i response to (1) above. This list, dated July 28, 1986, identified  :

l each plant system, categorized by operating mode / milestone, and identified if it had to meet technical specification requirements ,

for the applicable mode / milestone or if it had to be operational to  !

support a technical specification system requirement. The inspector  ;

l  !

4

_ _ ~ .

F' o.

6 reviewed the list with respect to the applicant's preoperational test deferral request (which was accepted by the NRC in Supplement 6 l to the CPS Safety Evaluation Report) and with respect to the final l draft CPS technical specifications. The inspector found that the l systemlist,inconjunctionwiththeprovisionsofCPSNo. 1401.01, Conduct of Operations, and other CPS procedures provided a viable

! approach to achieving system operability to support the applicable l milestones. This portion of the open item is closed.

At the conclusion of the inspection, the applicant had not provided i

the information requested in (2) above. This item remains open l pending receipt and review of the requested information and additional inspection.

l d. (Closed)OpenItem(461/86004-01): Safeteam weaknesses. The

! following employee concerns were reviewed by the Safeteam as described in NRC Inspection Report 50-461/86004, paragraph 6.

l The inspectors observed a program weakness in the investigative l procedures questioning the adequacy of these reviews. The inspectors acknowledged that the Safeteam investigation records were not intended to meet regulatory requirements for records or to provide evidence of quality. The actual impact of the

, weaknesses on plant hardware, if any, was not determined during

! the course of that inspection. Because the investigation record did not adequately address the identified concern, there was some potential that hardware could be affected. This was identified as an open item 461/86004 01.

The appitcant responded to the concerns addressed in Inspection i

Report 50-461/86004. The applicant has prepared and implemented l

a corrective action plan to resolve these concerns. To assure l

these corrective measures were adequate the inspector selected a i representative sample of hardware-related quality concerns.

l including the two examples addressed in the 461/86004 report.

This inspection included review of the Safeteam investigative report numbers 10028A, 12023C, 10270A, 10490A, 11676A, 12099A, 12704A. Three of the Safeteam reports were chosen which dated from before the 86004 inspection as a measure of adequacy of the Safeteam backfit program, and two reviews from after the NRC inspection as a evaluation of the current Safeteam program.

l Based on the sample reviewed the inspector concluded that the Safeteam had satisfactorily addressed the concerns expressed, and evaluated their safety significance. The inspector reviewed the appropriate Safeteam files, reviewed backup documentation on file in the licensee's QA Vault and performed fleid verifications where appropriate. No hardware deficiencies were apparent. This item is closed,

e. (0 pen) Unresolved Item (461/86023 05): Post maintenance testing (PMT) program / implementation deficiencies. An IPQA audit identified deficiencies in the applicant's program for PMi, 5

s

?

This unresolved item was previously inspected as documented in Inspection Reports 50-461/86023, paragraph 9.e. and 50-461/86048, paragraphs 2.1. and 2.v. During the last inspection, this item remained open pending NRC review of the resolution of additional IPQA audit findings in the PMT program implementation.

The inspector attempted to verify that PMT evaluations had been completed for a random sample of 23 maintenance work requests (MWRs) initiated between March and July, 1986. Of the 23 MWRs selected, PMT evaluations were available in the CPS central file for only 4. Those 4 PMT evaluations had been processed in accordance with the applicable procedure.

The inspector requested that the applicant locate 5 of the 19 PMT evaluations which were not in the central file. Those PMT evaluations were applicable to systems that had been declared operable under the CPS Final Draft Technical Specifications. The applicant was able to determine the location of three of those evaluations; they were still being processed in accordance with the approved procedure. The other two PMT evaluations could not be located by the applicant.

This review was still in progress at the conclusion of the

, inspection period. This item remains unresolved pending

, demonstration by the applicant that the program for PMT activities is being accomplished in accordance with the approved procedure,

f. (Closed) Violation (461/86013-02): Cleaning and preservation of safety-related station batteries. An inspection of the general

. maintenance condition of the station's safety-related batteries identified numerous examples of an inadequate battery maintenance program.

The applicant responded to the violation in a timely manner.

Two related items (open item 461/86013-06 and unresolved item 461/86013 07) concerning the applicant's battery maintenance procedures and the batteries preoperational test data were previously reviewed and closed in Inspection Report 50-461/86041.

The applicant performed an inspection of the station batteries and battery rooms. As a result of that inspection, numerous maintenance work requests were initiated to correct identified deficiencies.

In addition, the applicant provided training to their electrical maintenance personnel and contracted an outside consultant (Brand Industrial Products) to evaluate the battery maintenance practices.

During this report period, the inspector conducted an unannounced inspection of the safety-related station batteries (IDC01E, IDC02E, 10C03E, and IDC04E). The inspector observed the general cleanliness of the battery rooms was being properly maintained; that electrolyte level was being maintained within acceptable band; no spilled electrolyte was observed; all terminals were free of corrosion 6

(

products; and access to the battery rooms was controlled. The inspector reviewed the applicant's preventive maintenance (PM) schedule with the cognizant electrical maintenance supervisor and noted required PMs were completed and being maintained up to date.

The inspector confirmed the applicant's corrective action was adequate. This item is closed.

g. (Closed) Violation (461/86023-01): Maintenance work requests not performed in accordance with written instructions, procedures, and drawings. An inspection of maintenance activities being performed by the plant staff maintenance department and the maintsnance contractor, Stone and Webster (S&W), identified a number of examples '

where written instructions were not adhered to.

During the last report period (reference Inspectiot. Report 50-461/86048), the applicant formally responded to the violation '

and stated that full compliance would be achieved by July 30, 1986.

At the conclusion of the last report period, the insp'ector was still reviewing the applicant's response to item "c. cf the Notire of Violation (NOV). The applicant's response to items "a.", "b ",

and "d." of the NOV were previously found to be adequate as documented in paragraph 2.b. of Inspection Report 50 461/86048.

Item "c." of the NOV identified a MWR where work was performed without routing the MWR back to planninD when a change in scope was required. The applicant initiated a condition report (CR No.1-85 05 006) to address the specific example identified in the NOV of failure to follow MWR job steps. In addition, the applicant issued a memorandum to the job supervisor and craf tsman involved reiterating requirements to follow MWR job steps. -

Since the applicant's response indicated that they considered this an' isolated event, the inspector requested additional information to support the applicant's conclusion. The applicant reviewed thair Corrective Action Tracking System for the period Jannry 1 throcch June 30, 1986, and searched for trend codes that identIf fed a FA notfollowed(code 686 040), MWR signature out of sequence ' hold point by passed (code 686 055), and a MWR with unauthorized work (code 686 510). The applicant identified two additional instances where the scope of a MWR was exceeded.

The inspector reviewed the Nuclear Training Department's lesson plan, MWR Training For Craft Personnel 1985, and revision I Lesson Plan 10106datedJune18,198 The 0datedJuly31,iewedprovidedclearInstructionsonadherenceto lesson plans rev HWRdob steps. The inspector noted that all crafL person, were provided the above MWR training. In addition, the inspector reviewed " Gang Box Training" lesson plans 008, 009, 010, and 011 which provided supplementary training on adherence to procedures.

The inspector noted, through review of attendance records, that the gang box training had been provided to essentially fl1 craft personnel.

7

4e

/

/ -

i s t -

..O h , j

^# .9ased on the corrective action taken by the applicant'for t'he '

. o! 't,pecific eaample identified, the applicant's review which indicated

" 4his item to be en isolated example, the initial IWR training d provided to all craft, persons, and the continued " Gang Box Training" i '; provided to the craf t, the inspector concluded that the applicant's response to item "c." wat adequate. This item is closed.

h ." (Closed) Open Item (461/84030-03): Final reports submitted by the applicant ur. der 10 CFR 50.55(e) did not indicate that all corrective actions were complete. The inspector was concerned that the applicent had provided no docketed basis for assurance that safety y significant thficiencies reported under 10 CFR 50.55(e) had been

, corrected. '

' This matter wns revlemed further by the inspector as documented in Inspection Report 50 4G1/86023, paragraph 2.d. That report j identified an IP audit that had found the corrective actions to construction Aeficiency report 55 40 10 (461/80010-EE) incomplete after that report had been closed by the applicant and the NRC.

In this inspection, the inspector reviewed the results of a

( statistical sampling plan completed by IPQA concerning completion j of corrective 1ctions to previously closed construction deficiency

- reports. The sampling plan was based on 37 reportable deficiencies .

- identified during the construction of Clinton Power Station and

- focused specifically en those construction deficiencies which had I the largest' Wential hardware Spect. Ter. of the 37 total items

were reviewev and corrective actions reverified on a sampling basis 4 .to provide a Ingh degree of confidence that all reportable i deficiencies hed been adequately corrected. T.w reverification

! results identified no case where the corre.:tive actions to a i previously closta anetruction deficiency report had not been adequately compi tted. These results indicated that the IPQA audit I

finding documented in Inspection Repett 50 461/86023 did not have l generic applicability to the applicant's ccretctive action program

^

for repo? table construction deficiencies.

Jn addition to the reverification documented above, the applicant i m(de some changes in 1984 to the information included in their

toports urider 10 CFR 50.55(e) to address the inspector's concern.

I, ,

In particular, information concerning the comletioP or the schedule for coepletto.1 of corrective actions has been included in each of

< > their repoch since that time.

, The inspector reviewed the applicant's licensing procedure for

)

handling renstruction deficiency reports, 10 Crr. 21 reports, and i '

similar eatters, the procedure provided that ore of three methods were to be employed to assure that corrective actions were complete l

prior to submittal of the report to Region !!! inspectors for closure. Those procedural controls should provide an added measure l

i of assurance t'est the condition identified in th? IPQA audit will ~

i not ricur.

E _ _

b .' l tT g 3

i n s ,

'4 s (

When construction is completed and after CPS receives an operating .

license, IP will no longer be required to report under 10 CFR 50.55(e).

This item is closed.

1. - (Closed) Deviation (461/85060-03(DRS)): The applicant used a test methodology for the preoperational Type A test that was not consistent and was_ contrary to the test methodology that had been committed to in the Clinton Final Safety Analysis Report (FSAR),

y The app 1'icant presented this item to the inspector for closure. .

9 Tht: resolution to the Deviation was to incorporate the test methodology (Bechtel Topical Report, BNTOP-1, revision 1) use'd in the Preoperational Type A test into the FSAR. Specifically, FSAR section 6.2.6.1 was revised in Amendment 36 to include a reference to the Bechtel Corporation Topical Report BNTOP-1, revision 1.

The issue and the applicant's resolution were discussed between

- - the Region' III inspector, the Clinton Senior Resident Inspecter and the Licensing Project Manager prior, to the performance of the-Preoperational Type A_ test. There was agreement that the applicant's use of the test methodology was acceptable and their resolution to this' issue was satisfactory. This deviation is closed.

u

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J. (0 pen) Violation (461/86048-03): The CPS screenhouse was not floodproof as required. The applicant's quality assurance program i implementation had not identified this violation.

4 0 Additional inspection was undertaken during the report period to

,better determine the extent and potential consequences of the above violation. The inspection included a review of the status of-watertight doors (see paragraph 6.b.), a review of the status of containment electrical penetrations (see paragraph 6.a.), review of the CPS f k oding procedure (see paragraph 5.b.), additional observation of the CPS screenhouse installation, and verification of the applicant's review and evaluation of this violation.

The inspector observed the installed condition of the CPS screenhouse accompanied by applicant personnel. That observation

! indicated that six penetrations through the 699.0' elevation of the cancelled unit 11 portion of the screenhouse had not been adequately protected from the effects of flood. Those penetrations included j

l the construction opening and manway discussed in Inspection Report 50-461/86048, paragraph 6.a.(3), and four piping penetrations that had not been properly sealed. The safety-related equipment that would have been directly affected in the event of a flood included two shutdown service water (SX) system valves located in the piping tunnel (ISX011A and ISX0118, the division I & II header cross-connect valves which are normally shut) and SX division II equipment located in the SX pump ' cubicle. That cubicle was physically separated from SX divisions I and III by watertight doors. '

Assuming the watertight doors were shut and operational at the time of a postulated flood, only division II equipment and the division I cross-connect valve would have been directly affected.

9

s On August 5, 1986, the inspector requested that the applicant provide a copy of the condition report (CR) generated to document the above violation and to provide for appropriate corrective action. The applicant provided CR 1-86-08-020 dated August 5, 1986 i (that same day). The violation had been identified by the inspector l to the applicant on July 25, 1986 and had been the subject of an exit meeting held with IP management on July 28, 1986. The documentation identified that the violation was referred to the Nuclear Station Engineering Department for evaluation for reportability under 10 CFR EG.55(e)/10 CFR 21. j The inspector reviewed the applicant's safety-significance evaluation, 86RE32 dated August 14, 1986. That evaluation did not consider the possibility that a single failure could occur concurrent with the postulated flood. The inspector suggested that the applicant reconsider their safety significance evaluation to include the possibility of a concurrent single failure in the division I SX system. The applicant stated that they did not believe it was appropriate to postulate a single failure in L addition to the identified deficiency in evaluating its safety significance. However, on August 28, 1986, the applicant notified Region III by telephone of a potentially reportable deficiency (55-86-06) pending further investigation and evaluation of the deficiency.

This violation was the subject of an enforcement conference held in the Region III office on August 29, 1986. Attendees at the enforcement conference are designated by (+) in paragraph 1 of this report.

This violation will be reviewed further in a subsequent inspection report.

k. (0 pen) Open Item (461/86037-04C): Out of service (faulty or defeated) annunciators were not being controlled in accordance with CPS No. 1401.01, Conduct of Operations.

Thc inspector observed that faulty or defeated annunciators were being administratively controlled in accordance with CPS No.

1401.01, paragraph 8.5.4.4 and that plant operators were generally aware of the :ause of alarmed, faulty, or defeated annunciators.

The applicant stated that the administrative controls in place were difficult to use and that alternate methods were being considered for control of out of service annunciators. This matter will be

~

reviewed further in a future inspection.

No violations or deviations were identified.

10

+

l l

3. Applicant Action on 10 CFR 50.55(e) Item (92700)

(Closed) 50.55(e) (461/82009-EE): Small bore / instrumentation pipe support design calculations. The final report for this item was submitted to Region III dated June 15, 1984. This item was identified by the applicant as a potential reportable item dated September 2, 1982. The design calculations were performed by Sargent & Lundy (S&L)

Engineers. A review by Illinois Power Nuclear Station Engineering

~ Department (NSED) of these design calculations revealed many discrepancies contained in the design calculations. A hold was placed by S&L on the release of small bore pipe support design documents until corrective actions were implemented. The corrective actions  ;

listed below have been established and implemented by the applicant '

and S&L.

4

a. S&L procedures for small bore / instrumentation support design were corrected, expanded, and clarified. These included instituting a checklist to be used by the independent reviewer of calculations to assure an adequate review, locating analysts on site to review and concur with procedural interpretations, and locating piping stress reports at the site for reference.

b. S&L personnel responsible for preparing and reviewing small bore pipe support calculations were given training in the requirements of the revised procedures.

c. Calculations which contain non-conservative errors or legibility problems were being reconciled or revised. Affected design documents and hardware were being revised and corrected as necessary to ast se that affected piping systems meet the requirements of the -

procedures and the ASME code.

--d . Technical reviews by NSED were being performed on an on going sampling basis to monitor technical adequacy of design calculations performed by S&L.

< e. The licensee's NSED and QA were expanding their technical review /

audit activities to monitor S&L's design.

The inspector reviewed the final report and the supporting documentation with respect to the above concerns. The inspector noted that the actions 4 taken by the applicant were found to be acceptable. This item is closed.

No violations or deviations were identified.

4. Eirployee Concerns (99014)

The inspectors reviewed concerns expressed by site personnel from time to time throughout the inspection period. Those concerns related to regulated activities were documented by the inspectors and submitted to Region III. One concern was transmitted to the regional office during this report period.

a l

11

.w Allegat-lon 86-0135 (Closed)

In addition, on August 5, 1986, the inspector received an unmarked envelope in the plant mail which contained a copy of Condition Report (CR) No. 1-86-07-056. The CR identified that a former IP Startup Lead Test Engineer had unverifiable education included in his resume which was a part of the basis for his certification. The unverifiable education consisted of a Bachelors degree from one college in Texas and a Masters degree from a Texas University.

The inspector reviewed the CR with the Assistant Power Plant Manager -

Startup and interviewed additional Startup employees. The results of

, this review indicated that IPSV had adequately addressed both the specific and generic significance of the CR for Clinton Power Station.

However, there was some concern that the individual in question may still be using the same resume to support his certification at other '

nuclear facilities. In particular, personnel interviewed stated that the individual in question had worked at the Waterford plant in Louisiana and was currently known to be working at the Nine Mile Point plant in New York. The inspector notified the Region III Office Allegation Coordinator who subsequently notified the affected Regional offices of this matter. This item is closed.

No violations or deviations were identified.

5. Functional or Program Areas Inspected

a. Site Surveillance Tours (71302/60501)

Surveillance tours of selected areas of the site were performed at periodic intervals throughout the report period. Those surveillances were intended to assess: cleanliness of the site; storage and maintenance conditions of plant equipment and material; potential for fire or other hazards which might have a deleterious effect,on personnel or equipment; storage conditions of new fuel; and to Witness maintenance and preoperational activities in progress.

(1) New Fuel Storage During this report period, the applicant identified a r

violation of their security plan for the storage of Special l Nuclear Materials (SNM). On August 16, 1986, at approximately i 11:00 a.m. , a posted security guard was observed sleeping on the fuel handling floor of the fuel building. The guard was providing a compensatory measure for an open equipment hatch onto the fuel handling floor in accordance with the applicant's SNM security plan. New fuel was stored in the immediate vicinity of the open equipment hatch.

12

. l The applicant notified the resident inspector of the event and notified the NRC Operations Center in accordance with 10 CFR 73. The applicant relieved the sleeping security guard and conducted a security sweep of the fuel floor elevations. No unauthorized personnel were identified as being present. The inspector toured the new fuel storage area immediately following notification of this violation and noted the required number of security personnel were on duty and alert. The inspector noted that at least three additional security guards were posted on the fuel handling.

floor at the time in accordance with the applicant's security plan.

Several additional random tours of the new fuel storage area identified no additional deviations from the special nuclear materials license requirements for security, fire protection, and environmental controls for new fuel storage.

(2) Polar Crane Maintenance The inspector observed maintenance activities being performed on the polar crane by the Clinton Power Station's maintenance contractor Stone and Webster (S&W). The containment polar crane's main cable was being replaced in accordance with Maintenance Work Request (MWR) B-31446.

The inspector noted the MWR package was present at the jobsite along with necessary reference material to perform the replacement activity. However, the inspector requested additional information from the applicant concerning their compliance to ANSI B30.2.0-1976, Overhead and Gantry Crane's.

Specifically, it was not apparent to the inspector that

' paragraph 2-1.11.2.c of ANSI B30.2.0 was incorporated in the j- MWR job steps or the referenced procedure, CPS No. 8106.03, Crane Inspection, Maintenance and Testing. Paragraph 2-1.11.2.c of ANSI B30.2.0-1976 requires that "1) No less than two wraps of rope shall remain on each anchorage of the hoisting drum..." and "2) The rope clamps shall be tightened to the manufacturer's recommended torque".

h The applicant responded to the inspector's questions by stating a procedure change would be implemented to address the minimum number of wraps required. The applicant further stated that in the absence of vendor recommended torque values for the hold down clamp,-a " snug tight" value was appropriately applied.

Prior to the applicant's response, the inspector had noted by direct observation that more than two wraps of rope remained on each anchorage of the hoisting drum when the hook was in its extreme lower position. In addition, the inspector noted through discussions with the maintenance crew foreman

! that a " snug tight" value had been applied to the hcid down i

l l

13

clamps. Thus no hardware problems resulted from the apparently inadequate procedure. The applicant's corrective actions were sufficient to correct the procedure.

(3) Control and Instrumentation Maintenance The. inspector observed the performance of a loop calibration check performed by plant staff Control and Instrumentation (C&I) personnel. The calibration check was conducted under Maintenance Work Request (MWR) C-11384 on a Residual Heat Removal injection valve pressure transmitter (1E12-N058B).

The inspector noted the assigned C&I technicians had the MWR package at the job site. The referenced procedure in use, CPS No. 8634.02, revision 6, RHR Injection Valve Pressure Channel Calibration, was current. The Heise Gage being used at the local instrument rack was within its calibration due date.

The inspector observed the C&I technicians established communications between the local instrument rack and the control room. In accordance with the procedure in use, the C&I technician received permission from the Shift Supervisor to start the activity. The inspector noted that sufficient information was provided to the Shift Supervisor by the C&I technician. At the conclusion of the calibration check, the inspector reviewed the results and observed the C&I technician's discussion of those results with his supervisor.

The inspector concluded that the activity observed was conducted in accordance with approved procedures.

(4) Housekeeping and Cleanliness Control' l The inspectors noted that the applicant's actions to upgrade the cleanliness of the CPS suppression pool (see Inspection l Report 50-461/86048, paragraph 6.a.(3)) were completed and appeared effective. The applicant has been generally successful in maintaining the improved level of cleanliness both in the suppression pool and in the drywell weir area.

The inspectors will continue to monitor the applicant's activities in this area.

l (5) Containment Isolation For 36" Ventilation Valves The NRC closed TMI action plan item II.E.4.2, Containment Isolation Dependability, in Inspection Report 50-461/86049, paragraph 3.b. On August 8, 1986, IP provided a letter, U-600672 to the NRC Office of Nuclear Reactor Regulation concerning containment isolation for 36" ventilation valves in the containment purge system. Their letter identified that (4) 36" containment ventilation isolation valves did not 14

seet the TMI action plan requirements. To compensate for this deficiency until plant modification #VQ-02 is completed to correct it, the applicant committed to lock the valves closed. The inspector will verify that the affected valves are locked closed prior to fuel load and that administrative controls require they remain locked until the modification is completed. This is an open item for fuel load (461/86054-01).

b. Emergency Procedures Review (42452)

This inspection continued a review (reference Inspection Report 50-461/86048, paragraph 6.c) of procedures to be used in the plant operations phase to confirm that the plant emergency procedures are prepared to adequately control safety related functions when a system or component malfunction is indicated.

(1) Applicable Requirements, Applicant Commitments, and Guidance Documents (a) 10 CFR 50 (b) R qulatory Guide 1.33, revision 2, " Quality Assurance Pr, gram Requirements" (c) ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power

. Plants" (d) ANSI N45.2-1977, " Quality Assurance Program Requirements for Nuclear Facilities" (e) CPS No. 1005.01, revision 16, " Preparation, Review and Approval of Station Procedures" (f) CPS Final Safety Analysis Report (FSAR), Chapter 13.5.

(g) CPS Final Draft Technical Specifications (h) NUREG-0853, Safety Evaluation Report, and Supplements (2) Procedures Reviewed (a) CPS No. 4001.01', Reactor Coolant Leakage, revision 4 dated February 2, 1986.

(b) CPS No. 4004.01, Instrument Air Loss, revision 3, dated February 6, 1986.

(c) CPS No. 4100.01, Reactor Scram, revision 3, dated February 6, 1986.

(d) CPS No. 4301.01, Earthquake, revision 3, dated March 3, 1986. )

(e) CPS No. 4303.02, Abnormal Lake Level, revision 0, dated l March 3, 1986. l l

(3) Discussion I This inspection was to verify that the applicant had prepared the required procedures, that each of the procedures had been prepared in the appropriate format, and that the procedure was technically adequate to accomplish its stated purpose.

. , . . , _.m__7,,. , _ ._.,,_,,,, _ __ _ . _ _ , .,_ ,

Concerning CPS No. 4303.02, Abnormal Lake Level, the inspector found that the portion of the procedure related to a high lake level (flood) was not technically adequate to accomplish its stated purpose. In particular, the inspector noted that the procedure writer assumed that the plant could be operated at full power up to a lake level of 713.5 feet MSL. The CPS

. screenhouse is designed to protect the Shutdown Service Water system pumps and related equipment from the effects of floods up to that elevation. However, the circulating water pumps, which provide the condenser cooling water for CPS, will fail when the lake level exceeds approximately 699.0 feet MSL.

Circulating Water pump failure will result in a plant trip on loss of condenser vacuum. This procedure was discussed in detail with the Director - Plant Operations who stated that the procedure would be revised to provide an adequate approach for coping with floods.

Review of the procedures scope and technical review of the additional procedures identified in paragraph (2) above was still in progress at the conclusion of the inspection period.

(4) Results

- Results will be reported in a subsequent inspection report.

One minor security violation was identified by the applicant.

6. Independent Inspection Effort

a. Review of Electrical Penetration Status (92701)

The inspector conducted an independent inspection to determine the current status of containment electrical penetrations. During a previous inspection (reference Inspection Report 50-461/86037, paragraph 6.c), the insp,ector noted that a number of maintenance work requests were in progress to correct deficiencies identified by the applicant.

At the inspector's request, the applicant's cognizant engineer j accompanied the inspector on a tour of containment to answer the I inspector's questions concerning the observed conditions of I

electrical penetrations. The cognizant system engineer provided the inspector adequate responses to questions on installation techniques referenced in the applicable design drawings reviewed by the inspector (E27-1310, revision D and E05-1006, sheet 6, revision E). However, during the plant tour it was apparent that minor installation work had not been completed. The remaining work noted included installation of penetration covers, assuring that the penetrations were pressurized and that low pressure alarms were functional, assuring breather caps and drains were open, and at least one penetration (nonsafety-related) had a grounding cable 16

4 0

that was not connected outside the penetration. Additional questions were developed late in the report period concerning the portion of the electrical penetrations extending between the gas control boundary and the outer containment building wall. The observed conditions which appeared to be temporary modifications and construction debris, were discussed with cognizant IP personnel.

The applicant was not able to provide the inspector an adequate response concerning the program used to assure the installation of these "non-system" related commodities would be complete at the time of fuel load. "Non-system" related equipment and the method used by the applicant to assure readiness of these types of equipment to support plant operation is the subject of violation ,

(461/86048-03). The applicant's resolution of these specific work 4

I items will be reviewed in a subsequent inspection (461/86054-02).

Z

b. ESF System Walkdown (71710)

(1) Introduction An NRC inspection team conducted an independent inspection of the applicant's system walkdown program for initial declaration of system operability. The applicant began the process of establishing proper valve and electrical lineups necessary to declare systems in service and operable per the requirements of the Clinton Power Station Technical Specifications in late July, 1986. The objective of this inspection was to evaluate the effectiveness of the applicant's walkdown program in identifying operability restraints. The following paragraphs provide the details of this inspection.

(2) Details The applicant had defined the reviews necessary for declaring a system " Tech. Spec. Operable" ir. procedure ' CPS No. 1401.01, Conduct of Operations, revision 9 dated July 24, 1986. Section

- 8.5.10 of CFS No. 1401.01 detailed the specific steps to be performed by the Clinton Power Station Operations Department in determining when a plant system was ready to be declared

" Tech. Spec. Operable". Implementation of those requirements along with the requisite management review was the basis for the applicant's determination that a system was " Tech. Spec.

Operable". The following systems were selected as a representative sample of the applicant's program implementation.

(a) High Pressure Core Spray (HP)

, (b) Low Pressure Core Spray (LP)

(c) Shutdown Service Water - Division 2 (SX-2)

(d) Screen House HVAC - Division 1, 2, & 3 (VH-1,2,3)

(e) Essential Switchgear Heat Removal - Division 1 (VX-1)

(f) Diesel Generator Air Start - Division 1 (DG-1)

(g) Diesel Generator Fuel Oil - Division 1 (00-1)

(h) Diesel Generator Ventilation - Division 1 (VD-1) 17

s s

A detailed walkdown of each of the above systems was performed by five NRC personnel; the SRI-Operations, the RI-Operations, the SRI-Construction, one Regional based inspector, and the NRC Licensing Project Manager. For the systems inspected, the following attributes were observed:

(a) System configuration matched the applicable control room drawing.

(b) Valve and electrical switch / breaker positioning agreed with the current lineup in the Operation's Department system configuration file.

(c) Valves were locked when required. -

(d) Equipment conditions appeared correct with no evidence of damage.

(e) Equipment and components were properly identified.

(f) Interiors of electrical and instrumentation cabinets were free of debris, loose material, uncontrolled jumpers, with no evidence of rodents.

(g) Instrumentation was properly installed and functioning.

(h) Lubrication was provided, where observable.

(i) Temporary modifications were properly controlled.-

(j) Plant areas were observed during the walkdown process to identify any area / commodity items which could impact

- system operability.

. (k) Deficiencies identified by the applicant (tags observed) were annotated and subsequently verified to be properly controlled.

In conjunction with the above, the inspectors reviewed the applicant's completed walkdown packages to verify the applicant's implementation of their established program (i.e.,

CPS No. 1401.01). In addition, the inspectors reviewed outstanding maintenance work requests-(MWRs) for the High Pressure Core Spray system to evaluate the categorization of outstanding work documents by plant operating mode / milestone.

The system walkdowns resulted in a number of questions which were referred to the applicant for resolution. In general, the questions resulted from observed discrepant conditions with minor significance to system operability.

Examples of identified discrepancies included missing vent / drain caps; missing identification labels for minor valves and major equipment; local pressure indicator not functioning properly; and minor drawing discrepancies. Each discrepant condition was reviewed with Operation's Department personnel who provided information to indicate that the discrepancies either had been or were being addressed.

The following items identified during the system walkdowns appeared to be of more than minor significance:

18

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I (a) A Barton differential pressure gage used to measure the j discharge pressure of ISX01PB (the division II Shutdown l Service Water pump) was installed with the low side vent '

I capped. The installation of the cap could have resulted in inaccurate readings that varied with environmental conditions and system pressure. The applicant reviewed other similar applications and identified additional similar examples. Condition report 1-86-08-171 was initiated on August 29, 1986 to document the condition and provide for appropriate corrective action. This condition report will be reviewed further in a subsequent inspection. This is an unresolved item (461/86054-03).

(b) A steel plate was installed as a security barrier for new fuel storage around the body of valve IE21-F005, the Low Pressure Core Spray (LPCS) outboard containment isolation valve. The plate was not shown on the applicable design drawings and was not identified as a temporary modifica-tion in accordance with the applicable CPS procedure.

This item had been identified by the applicant in their management walkdown of the system. A maintenance request was initiated by the applicant to remove the steel plate.

However, no action had been taken to determine the cause of the condition and to preclude recurrence.

The inspector was concerned that the steel plate, which was installed very close to the valve body, had not been considered in the seismic design of the LPCS system. The matter was identified to the Operation's Department for review but.the installed hardware had been removed before Operations could investigate the identified condition.

On August 29, 1986, the inspector requested that the applicant determine (1) how the plate had been installed and under what controls, and (2) how and why the plate was removed. The applicant responded that the plate had been removed under the maintenance request initiated as a result of the management walkdown. However, no installation documentation was available. .

Procedure CPS No. 1014.03, Temporary Modifications, paragraph 8.1.1 requires that a Temporary Modification Permit be used to initiate a temporary modification.

CPS No. 1029.01, Preparation and Routing of Maintenance Work Requests, paragraph 3.4 requires the use of a maintenance request to identify work to be performed by the maintenance department. Paragraph 4.1 prohibits the installation of any temporary or permanent modification without approved design documentation. The installation of a steel plate around the body of the low pressure core spray outboard containment isolation valve was a violation 19

s of the above requirements. The applicant failed to write a condition report upon identification of the installed condition, as required by CPS No. 1016.01, Condition Reports, to provide for evaluation and appropriate corrective action. This is a violation of 10 CFR 50, Appendix B, Criterion XVI, and CPS No. 1016.01, paragraph 3.4 which requires that a condition report be initiated for conditions that are known to be in violation of safety-related procedures. Initiation of a maintenance request provided for correction of the specific deficiency but did not address the cause of the condition or determine the need for generic corrective action.

(461/86054-04).

(c) Watertight door 1-12 separating the division I and II Shutdown Service Water pump cubicles appeared to have loose and missing hardware; the locking mechanism did not engage; a paper test of the door seal indicated that the seal was not watertight; and the door appeared to have incomplete installation of a limit switch assembly.

Observation of other similar watertight doors had indicated similar deficiencies.

Preliminary discussion with the Operation's Department indicated that the watertight doors were scoped under the HC (Hoists and Cranes) system; that the HC system was not yet operable; and that testing and maintenance programs were being developed for these doors. The inspector observed that the Shutdown Service Water system was 'not declared technical specification operable pending resolution of the above deficiencies. This is open pending receipt of additional information from the applicant. Open Item (461/86054-05).

Upon completion of the system walkdowns, the inspectors reviewed a computer printout of open change documents for the High Pressure Core Spray (HPCS) system. The list included 2 condition reports, 56 maintenance work requests (MWRs), and 4 l nonconforming material reports. Each document had been

. reviewed by the applicant and had been determined not to impact i HPCS system operability. The purpose of the NRC review was to i

verify the adequacy of the applicant's categorization. Each of the documents listed were discussed with operation's department personnel and were determined to be properly categorized. One open question concerning the calibration of a HPCS system flow transmitter remained open at the conclusion of the inspection.

j Open item (461/86054-06).

l I

20

(3) Results This inspection involved an extensive effort by the NRC. Two ESF systems and eight ESF support systems were reviewed in detail and.the results compared with the results of similar reviews performed by the applicant's Operation's Department.

The inspection found that the applicant's program for determining system status in preparation for declaration of system operability was being performed in accordance with approved _ procedures and that the procedures were generally effective in establishing the system status.

One violation was identified.

c. Control Room Observations (71715)

An inspection in this area was performed by the NRC Senior Resident Inspector (Callaway Nuclear Plant) to assess the applicant's conduct of operations. The inspection was performed during off shift periods and focused on overall control room discipline, adherence to administrative and plant proceduras, and operator attentiveness to plant parameters and conditions. This' inspection also included interviews with shift crew personnel and observations of portions of the following plant activities:

Procedure No. Activities RHIE12F011A MOVATS Testing CPS No. 3408.01 Containment Building /Drywell HVAC Flow Balance Test PTP-VG-02 ,

Secondary Containment Leak Test l CPS No. 3506.'01 Operation of Diesel Generator IA

(Troubleshooting and subsequent post maintenance test)

CPS No. 9080.1 Diesel Generator IB Operability Test CPS No. 9431.14 Intermediate Range Monitor Channel Calibration CPS No. 9431.12 Average Power Range Monitor Channel Calibration.

(1) Control Room Conduct The applicant recently implemented a twelve-hour shift rotation. This action was taken to enhance control / continuity of work activities and to provide additional on-shift personnel. Although the control room "at the controls" traffic I

21 1

s appeared heavy, personnel entry into this area was in response to ongoing plant testing and surveillance activities. The

" work' process" window in the shift supervisor's (SS) office was '

effective in reducing control room traffic for the processing  :

of work requests. The work processing activity levels were very high in both the SS office and control room. While the activities in both areas were performed in a businesslike manner, the work processing kept the SS, assistant SS, and the "A" reactor operator at their desks for considerable periods during their shifts which detracted from supervision / operator oversight functions.

In Supplement 6 to NUREG-0853, Safety Evaluation related to the Operation of.Clinton Power Station, Appendix N, the NRC has withheld final approval of the applicant's preoperational test deferral requests pending the applicant's demonstration of their capability to satisfactorily control activities associated with deferred testing. The applicant, in letter U-600583 dated June 3,1986, detailed specific actions they planned to take to manage activities deferred past fuel load-to assure that those activities do not place an undue burden on startup personnel and the plant operators. This matter is open pending the applicant's demonstration that the management controls discussed in letter U-600583 are in place and are effective in controlling deferred activities such that the plant operators may properly carry out their safety-related activities. Open item _(461/86054-07).

A businesslike atmosphere was maintained in the control room.

Except for two occasions, SS/ operator permission was obtained prior to personnel entry into the "at the controls" area. The inspector noted the appropriate absence of non plant discussions and materials.

Applicable plant operating and test procedures were utilized and

, adhered to for the activities being controlled from the control room. Operational control / communication within the control room and communications between station operators and control room operators were businesslike. The SS and assistant SS provided direct supervision of operation of the 1A and IB emergency diesel generators.

Shift turnover and relief was thorough and businesslike. Crew supervisors, in addition to their own turnover, conducted detailed briefings with the oncoming crew. Control room station turnovers included the appropriate plant discussions, panel walkdowns, log reviews, and annunciator checks prior to turnover.

Control room operators were attentive / responsive to plant parameters and conditions. The inspector observed that approximately 310 control room annunciators were in an alarmed condition. The frequent recurrence of several nuisance alarms was distracting to 22

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

I i

t ,

s 1

86-090 86-092 through 86-099

86-100 through 86-109 86-110 through 86-119 86-120 through 86-125 86-127 through 86-128 86-130 through 86-140 86-150 86-152 through 86-153.

These reviews included verification of FRG membership availability of meeting quorum, and verification that the ' was meeting its  :

charter. The inspector noted that the timeliness of FRG meeting minutes preparation and distribution had improved substantially over

past practice. FRG meeting frequency was relatively high but consistent with the workload. One condition report from meeting No.86-115 (No. 1-86-07-009), related to performance of work without approved procedures, was. referred to an NRC contractor inspector for detailed review. The results of that review will be included in Inspection Report 50-461/86059.

i No violations or deviations were identified.

7. Safety Evaluation Report Review and Followup (92719)

The following items from NUREG-0853, Safety Evaluation Report related to the Operation of Clinton Power Station, Supplement 6 (SSER 6) were ,

referred by the Office of Nuclear Reactor Regulation, Division of l Licensing, to Region III for confirmation of applicant actions.

a. SSER 6, paragraph 6.2.7, verify that any equipment enhancements to s

'

• meet the requirements of the final rule on hydrogen control are implemented before startup following the first refueling outage.

Open item (461/86054-08).

b. 'SSER 6, paragraph 7.2.3.3, verify that the design modifications to correct the STS design so that upon detection of a fault the correct NSPS division will be annunciated as containing the fault are

implemented before startup after the first refueling outage. Open item (461/86054-09).

, c. SSER 6, paragraph 7.4.3.1, verify that design modifications to eliminate the need for using jumpers, rewiring, or disconnecting circuits when effecting shutdown from outside the control room using Division II equipment are implemented before startup after the first refueling outage. Open item (461/86054-10).

, d. SSER 6, paragraph 7.5.3.2, verify that changes to the main control i

room isolation valve group annunciator display tiles and primary i

containment isolation valve regrouping into 13 valve groups, which include 47 additional valves, is completed before exceeding 5% of rated power. Open item (461/86054-11).

[

24

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i

b. 10 CFR 21.6 Posting Requirements 10 CFR 21.6 requires, in part, that ,

"(a) Each entity subject to the regulations in this part, shall post '

current copies of the following documents in a conspicuous position on any premises (1) the regulations in this part, (2) section 206 of the Energy Reorganization Act of 1974, and (3) procedures adopted pursuant to the regulations in this part.

(b) If posting of the regulations in this part or the procedures j adopted pursuant to the regulations in this part is not practicable, the licensee or firm subject to the regulations in this part may, in addition to posting section 206, post a notice which describes the regulations / procedures, including the name of the individual to whom reports may be made, and states where they may be examined."

The inspector observed that the applicant had posted section 206 1 of the Energy Reorganization Act and a notice, in accordance with 21.6(b). The inspector observed that the posted notice contained i outdated information and did not state where the regulations and procedures adopted could be examined. This matter was discussed with the applicant's Licensing staff. The licensing representative acknowledged the out of date information and stated that a revision

• to the notice had been initiated by IP several weeks earlier. The licensing representative stated that the notice would be revised to state where the regulations and procedures could be examined.

c. 10 CFR 19.11 Posting Requirements 10 CFR 19.11 requires, in part, that i

"(a) Each licensee shall post current copies of the following

- documents: (1) The regulations in this part and in Part 20 of this chapter; (2) the license, license conditions, or documents incorporated into a license by reference, and amendments i

thereto; (3) the operating procedures applicable to licensed

! activities; (4) any notice of violation involving radiological working conditions, proposed imposition of civil penalty, or

. order issued pursuant to Subpart B of Part 2 of this chapter,

! and any response from the licensee.

(b) If posting of a document specified in paragraphs (a) (1), (2) or (3) of this section is not practicable, the licensee may post a notice which describes the document and states where it may be examined.

i (d) Documents, notices, or forms posted pursuant to this section shall appear in a sufficient number of places to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed activity location to

' which the document applies, shall be conspicuous, and shall be

! replaced if defaced or altered."

26

t The inspector could find no evidence that the applicant had posted or planned to post the documents specified in 10 CFR 19.11(a).

This matter was discussed with the IP Director - Licensing who stated that the matter would be reviewed and appropriately corrected. This is an unresolved item (461/86054-15).

d. 10 CFR 21 Reportina Procedures The inspector briefly. reviewed the applicant's procedure for reporting under 10 CFR 21 and noted that the procedures did not interface with the applicant's procedures for reporting under 10 CFR 50.73, Licensee Event Reporting (LER). The inspector observed that it is cor. mon practice for utilities to report under 10 CFR 21 using the LER as an "other" report referencing 10 CFR 21.

The applicant acknowledged this observation.

In addition to the above reviews, the inspector discussed the Licensing Department's involvement in the LER process and in making changes to the technical specifications. The inspector noted that the Licensing Department had no procedures for controlling LERs although CPS No.

1016.04, CPS Licensee Event Reports, revision 1 identified that IP Licensing had responsibility for processing the reports. The Director -

Licensing acknowledged this observation. The inspector also noted that the Licensing Department procedures for processing changes to the CPS technical specifications did not provide for making prompt changes in a nonroutine situation (i.e., emergency changes). The Director - Licensing also acknowledged this observation.

No violations or deviations were identified.

9. Site Activities of Interest

.a. Fuel Load Schedule (94300)

On June 17, l'986, the applicant notified the NRC by letter that CPS would be ready for issuance of a low power license on or about July 15, 1986. At the conclusion of the inspection period (September 8, 1986), there were 32 of 62 required plant subsystems declared operable under the CPS final draft technical specifications to support fuel load. That activity was in progress. The applicant believed that CPS would be ready to load fuel on or about September 23, 1986.

b. Readiness For Fuel Load Meeting (30702)

On August 7 and September 8, 1986, NRC management met with IP management at CPS to discuss the current state of readiness of CPS to load fuel. These were the seventh and eighth of a series of such meetings to be held with IP management on a routine (monthly) basis.

Key personnel attending the meetings are identified by ($ and #,

respectively) in paragraph 1 of this report.

i i

27

• f The meetings each included discussions of: the status of preoperational testing; the status of test deferrals; status of the conduct of surveillance testing for credit; status of system readiness to support operation under the CPS technical specifications; plant procedures completion status; CPS " Things" list; and the status of management actions to facilitate the transition from construction to plant operations.

c. IP Management Change (71302)

On September 8,1986, the applicant announced that a new position i had been created within the CPS plant staff management structure:

Assistant Power Plant Manager - Maintenance. That position was intended to provide additional management overview of site maintenance activities.

d. IP Labor Negotiations (92709)

On August 14, 1986, the applicant notified the resident inspector that the four unions representing IP workers voted to accept the company's contract proposal. The new two year contract was effective immediately.

10. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Two unresolved items disclosed during this inspection were discussed in paragraphs 6.b(2), and 8.c.

11. Open Items Open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which will involve some action on the part of the NRC or applicant or both. Twelve open items disclosed during the inspection were discussed in paragraphs 5.a(5), 6.a, 6.b(2), 6.c, and 7.

12. Exit Meetings (30703)

The inspector met with applicant representatives (denoted in paragraph 1) l l

throughout the inspection and at the conclusion of the inspection on September 8, 1986. The inspector summarized the scope and findings of the inspection activities. The applicant acknowledged the inspection findings and the inspector's suggestions.

The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The applicant did not identify any such documents / processes as proprietary.

The resident inspectors attended exit meetings held between Region III based inspectors and the applicant as follows:

28

Inspector (s) Date Wohld 8/14/86 Neisler 8/21/86 Pirtle 9/05/86 9

O 29

s U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-461/86053(DRS) .

Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: August 4 through October 10, 1986 Inspectors: P. R. Wohld [ /' 2 4[$4 Date S. G. DuPont / !d 'e //2//68 Date R. A. Hasse b h 2//s/

Date 1

Approved By: Monte . [hiilips, Chief //h8/f[

Operational Programs Section Date Inspection Summary

~

Inspection on August 4 through October 10, 1986 (Report No. 50-461/86053(DRS))

Areas Inspected: Special, unannounced team inspection of previously identified inspection findings, followup on 10 CFR 50.55(e) items, followup on allegations,

! maintenance program implementation, modification program implementation, and motor-operated valve control logic. A September 19, 1986, management meeting

! was also included in the inspection.

Results: Of the six areas inspected, apparent violations of four criteria in 10 CFR 50, Appendix B, were identified, each with multiple examples. The attachment to this report summarizes the violations, with examples, and cross references the associated report page numbers.

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i DETAILS

1. Persons Contacted Illinois Power Company

• W. C. Gerstner, Executive Vice President, Illinois Power

1. • D. P. Hall, Vice President, Illinois Power

• J. W. Wilson, Manager, Clinton Power Station

1. • K. A. Baker, Supervisor, I&E Interface

• R. E. Campbell, Manager, QA

1. • J. A. Fertic, Director, Quality Systems and Audits

1. • R. D. Freeman, Assistant Plant Manager, Maintenance

1. • J. H. Greene, Manager, Nuclear Station Engineering

1. • F. A. Spangenberg, III, Manager, Licensing and Safety

• S. A. Zabel, Attorney for Illinois Power

1. J. G. Cook, Assistant Plant Manager

1. E. J. Corrigan, Director, Quality Engineering and Verification

1. H. K. Lane, Manager, Scheduling and Outage Management -

1. J. S. Perry, Manager, Nuclear Program Coordination

1. J. D. Weaver, Director, Licensing

1. J. C. Wemlinger, Supervisor, Nuclear Training Department NRC

• A. B. Davis, Deputy Regional Administrator, Region III

• C. G. Norelius, Director, Division of Reactor Projects

• C. J. Paperiello, Director, Division of Reactor Safety

• C. W. Hehl, Chief, Operations Branch

• P. L. Hiland, Resident Inspector

• R. C. Knop, Project Section Chief

1. • M. P. Phillips, Chief, Operational Programs Section

• M. A. Ring, Chief, Test Programs Section

• R. F. Warnick, Branch Chief

1. T. P. Gwynn, Senior Resident Inspector

1. C. Scheibelhut, NRC Consultant State of Illinois

• M. Jason, Assistant Attorney General

1. Denotes those attending the exit meeting held September 12, 1986, at the Clinton site.

• Denotes those attending the management meeting held in the Region III office in Glen Ellyn on September 19, 1986.

Additional plant technical and administrative personnel were contacted by the inspectors during the course of the inspection.

2

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2. Overview The inspection reported herein reflects increasing inspection effort in  ;

response to increased maintenance activities in preparation for fuel loading and in response to concerns generated for the adequacy of the conduct of maintenance. It also reflects inspection effort resulting from the NRC Resident Inspector's concerns for the adequacy of the conduct of plant modifications. Apparent violations were identified in both areas that included multiple examples against four criteria of 10 CFR 50, Appendix B: (1) Design Control; (2) Instructions, Procedures, and Drawings; (3) Test Control, and (4) Corrective Action. The violations indicated a quality breakdown in the maintenance and modification programs, the root cause of which was the failure of management to implement the programs controlling these activities.

A key factor in many of the problems leading to the apparent violations was the lack of adequate corrective action. The inspectors found that the licensee's staff was already aware of many of the problems identified, knew the root cause, and the necessary corrective action; however, the problems and solutions were either not raised to the management level necessary to

• obtain action, or, when raised to that level, were not adequately addressed.

The inspectors also found that supervisors and mid-level managers failed to understand or implement some of the basic maintenance and modification program quality requirements. When problems were identified for resolution, they did not fully appreciate the extent of the need nor the necessary scope of corrective actions.

The quality breakdown in the maintenance program was reflected by:

(1) the equipment problems identified by the licensee that were caused by improperly conducted maintenance activities; (2) improper or degraded equipment conditions identified by the inspectors, and (3) documented equipment problems for which corrective actions had been inadequate. The quality breakdown in the modification program is reflected generally by poor overall administrative control of the program and was evident from the inspectors' review of vaulted modification packages. The inspectors found:

(1) a lack of adequate modification testing in a few cases; (2) test instructions, test acceptance criteria, test results evaluation, and documentation required by the plant procedures and accepted practices were generally lacking, and (3) inadequate documentation of safety evaluations.

3. Action on Previous Inspection Findings Inspection in this area was for items opened in Inspection Report No. 50-461/86045(DRS) which included motor-operated valve programs (including actions on IE Bulletin No. 85-03) and valve mechanical conditions. Two violations were identified by the inspectors that, while existing from original construction, should have been identified and corrected by valve maintenance activities conducted by the licensee.

(See Items e and f.6 below.)

a. (Closed) Open Item (461/86045-01): Limitorque valve operator geared limit switch lubrication controls. Mechanical Gang Box Training Procedure, GBTM-011. "Limitorque Limit Switch Gear Box Lubrication,"

was issued on July 1,1986; documented training was held shortly 3

s thereafter. . A precaution was added to Step No. 8.1.4.4 of Maintenance Procedure No. 8451.01, " Motor Operated Valves, Generic Procedure For,"

to assure that the geared limit switches do not lose their alignment during a regressing evolution. The above was reviewed by the inspector and was found to be adequate to close this item,

b. (Closed) Open Item (461/86045-02): RCIC Turbine Trip and Throttle Valve, IE51-C002E, safety-related strokes. A review of the electrical drawings indicated that the valve operator motor thermal overloads are normally bypassed for both the open and close valve strokes. The licensee has evaluated the valve logic and has implemented a change to Plant Technical Specification (TS), Table No. 3.8.4.2-1, to include this valve for thermal overload bypass surveillance testing. This item is considered closed.

c. (0 pen) Open Item (461/86045-03): Adequacy of valve differential pressure testing under IE Bulletin No. 85-03. The licensee submitted a supplemental response to the bulletin, dated September 10, 1986, which provides additional information on this item. This item will remain open pending evaluation of the response by the Office of -

Inspection and Enforcement.

d. (0 pen) Open Item (461/86045-04): Long term valve operability program.

The licensee is preparing testing and preventative maintenance procedures in this area per their revised response to IE Bulletin No. 85-03, Action Item d, submitted by letter to Region III on September 10, 1986. The scheduled date to complete this program is 1986.

November Closure of 20, this1986, per item is letter tothe pending Region III, dated completion of September the licensee2,s commitment and subsequent NRC review.

e. (Closed) Open Item (461/86045-05): Program for valve lubrication.

Additional walkdowns by the NRC resident inspectors since this item was first identified indicated that a significant percentage of motor-operated valve stem threads had not been lubricated. This is contrary to Step No. 7.1 in plant Procedure No. GTP-55, " Motor Operated Valves," which states: " Remove stem protection cover and check that the stem is clean and properly lubricated." Some valve stem threads (approximately 30) can not be checked for lubrication by this instructic') because the threads are buried within the operator or are lubricated through a fitting. The procedure was used to test all motor-operated valves during the plant preoperational test phase and should have been corrected to properly address all motor operated valves the first time it could not be used as intended in the field.

Further, maintenance Procedures No. 8451.01, 8451.02 and 8451.03, which were written and used at the time of this inspection to verify, test, and maintain motor-operated valve conditions did not contain provisions for assuring proper lubrication of the valve stem threads.

The failure to lubricate motor operated valves as provided in GTP-55, failure to correct the procedure when it could not be used properly, and failure to otherwise provide an adequate procedure are considered examples of a violation of Criterion V, Instructions, Procedures, and Drawings, in 10 CFR Part 50, Appendix B (461/86053-02a).

4

s Immediate corrective action by the licensee included preparing and implementing Maintenance Work Request (MWR) No. C10294 to assure that all safety-related valve stem threads were properly lubricated. The development of an adequate program for valve lubrication will be tracked by the violation. The open item is considered closed,

f. (0 pen) Unresolved Item (461/86045-06): Motor-operated valve mechanical condition. A number of mechanical equipment degradations were identified by the inspector in the sample of 10 valves described in Inspection Report No. 50-461/86045. A description of the degradations and licensee actions initiated to address them are below:

(1) Inoperable handwheel operators. Handwheel operation of safety-related valves was checked by the licensee during the performance of MWR-C10294. Approximately 25 handwheel problems were identified. The licensee indicated that these will be tracked, corrected, and corrective action documented in the MWR package.

(2) Electrical conduit hole plug missing from the valve operator

• switch compartment. The specific conduit hole plug found missing by the inspector on June 18, 1986, was on inboard containment isolation valve No. OMC010. It provided an approximately 1 1/2 inch hole in the top of the valve operator electrical switch compartment, defeating its environmental qualification. (This is further discussed as a contributor to the violation identified in (6) below.) An overall external inspection of all safety-related valves was conducted under MWR-C10294 to address this type of condition. A number of items were identified, all of which the licensee indicated will be tracked, corrected as necessary, and documented in the MWR package.

(3) Valve stems not properly lubricated. This is addressed in Paragraph 3.e of this report.

(4) Excessive handwheel force required to operate valves and

- improperly set torque switch. The high handwheel force observation was not an item of immediate concern; however, a spring scale measurement of handwheel operating force could be a valuable indicator of valve condition for: (1) long term valve operability trends and assessments; (2) cross checking values among identical valves to identify problems, and (3) to help identify changes in valve stem thrust requirements related to packing, packing replacement, and packing tightening to stop leaks.

The valve found with the improperly set torque switch, IE22-F015, was considered to be an isolated case. On further inspection by the licensee, a locking pin was found broken in the torque switch.

Corrective action to replace and reset the torque switch and perform valve operability testing was completed successfully by the licensee.

5

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't l (5) Valve operator limit switch compartment corrosion. The licensee indicated that the switch compartment has been cleaned, reworked,  !

i and returned to service.

(6) Unqualified wire found in Valve No. 1E22-F010. The unqualified wire found is discussed in detail in Paragraph 7 of Inspection Report No. 50-461/86045(DRS). The unqualified wire was missed

during two EQ walkdowns conducted by the licensee and a third check during the conduct of Maintenance Procedure No. 8451.03, Step No. 8.1.1. The missing conduit plug is another environmental qualification item, discussed in (2) above, that appears to have

been missed in the EQ walkdowns on the MOVs. These constitute a failure to follow procedures and instructions and are examples j Procedures, and i

of a violation Drawings, in 10ofCFR Criterion Part 50, V,Appendix Instructions,/86053-02b).

8 (461

( i l

The inspector determined that the corrective actions initiated or completed were adequate to address the problems identified and assure valve operability at this time; however, as discussed with the licensee, the activities needed to assure an acceptable mechanical j

condition of the valves in the long term have yet to be addressed.

In a letter to J. G. Keppler, dated September 2,1986, the licensee

committed to have a program in place by November 20, 1986, that will address long term valve operability. This item remains open pending satisfactory completion of this. commitment and subsequent NRC review.

(This item will be reviewed together with Open Item (461/86045-04) on i long term valve operability testing. See Item No. 3.d in this report.)

! g. (0 pen) Open Item (461/86045-07): Limitorque motor-operator wire qualification. The licensee presented information to the inspector l

which indicated that all of the Rockbestos Firewall III wiring insulation subgroups used in the limitorque valve operators are i acceptable. The information was transferred to an environmental qualification specialist in the regional office for further review.

Closure of this item is pending that review. ,

l l Items e and f and apparent violations noted therein for inadequate lubrication and poor valve mechanical condition reflect a failure in the valve maintenance activities, conducted since construction, to assure proper valve setup for operational conditions. Itemsathroughdand9 ,

became open items primarily because of the early stage of the licensee s programs or because additional information was needed. 1 hey do not necessarily reflect a weakness in licensee performance.

4. Followup on 10 CFR 50.55(e) Item (0 pen) 10 CFR 50.55(e) Item (461/86004-EE): Modification of Limiter Plates on Limitorque Valve Operators. During motor-operated valve testing, using MOVATS signature analysis test equipment, the licensee performed an unauthorized modification of 36 torque switch limiter plates to allow the adjustment of the torque switch settings beyond the prescribed maximum.

This was done when low stem thrust values measured by the MOVATS test 6  ;

s equipment indicated a need to increase the operator thrust output. (Thrust target values were established by the licensee at 110% of vendor calculated thrust requirements for valve operation.) However, this increase in torque switch setting invalidated the undervoltage operability qualification for the valve operators. Inadequate evaluation of the modification and inadequate post modification testing failed to reveal this initially.

After an expression of concern by Limitorque,_the licensee initiated undervoltage testing of the valves. This testing, with additional analysis, indicated that, under degraded plant voltage conditions, approximately 90%

of the modified valves would go to locked rotor conditions without tripping the torque switch on valve closure. This would result in valve motor burnout. The overall safety significance of this was that it could have adversely affected the operability of three emergency core cooling systems, the shutdown service water system, and fire protection systems.

Illinois Power Company provided a preliminary report on this item in a letter to J. G. Keppler, Regional Administrator, Region III, dated August 15, 1986. After evaluation of the response and further discussion with the licensee, it appears that corrective action has been taken to -

assure that the valves are available to perform their design function and that measures have been initiated to correct the conditions that allowed the uncontrolled modification of the valves. Twenty-nine of the 36 valves were returned to their original design condition. The remaining seven valves were tested in the modified condition and found capable of closure under degraded voltage conditions.

There are two areas of concern relating to the limiter plate modification as it was performed by Illinois Power Company:

a. Plant Design Controls Maintenance Procedure, CPS No. 8451.02, Revision 6, Step No. 8.7.3.12, was improperly approved to direct filing down the limiter plates. The plant staff failed to recognize this as a modification when approving the procedure (Revision 6 and earlier revisions) and, hence, failed to follow the provisions under Corporate Nuclear Procedure, CNP 4.08,

" Plant Modification System." This procedure specifies the appropriate design control measures, including technical review and post modification testing, that is intended to prevent the type of problem that occurred with the limiter plate changes. The failure to follow CNP 4.08 is an example of a violation of Criterion III, Design Control, in 10 CFR Part 50, Appendix B (461/86053-01a).

4 b. Corrective Action Corrective action in response to low thrust values identified early in the valve test program was inadequate, resulting in the unnecessary modification of some of the limiter plates. The twenty-nine valves i

l returned to their original configuration were done so by additional l

corrective maintenance or by reconsideration of how valve packing i loads are included in the evaluation of MOVATS test results. The licensee has not evaluated the cause for the remaining seven valves 7

s s

t failing to meet their design requirements without modification. This leaves an open question as to whether or not there is a problem with the seven valves as supplied by the vendors, or, if there is a factor that caused degradation of the valves' capabilities peculiar to the Clinton Power Station. Another indicator of inadequate corrective action is identified in Paragraph 6.b (MWR-831175) of this report. It relates to a limiter plate modification that resulted in the valve motor going to locked rotor conditions at normal volt Ne. Subsequent maintenance corrected the problem. The final torque witch setting was at the " nominal" value with operator thrust developed well above minimum. Documentation and evaluation of that activity was inadequate for a determination of why the operator originally failed to meet its design requirement. The failure to properly evaluate the cause of equipment failures is considered an example of a violation of Criterion XVI, Corrective Action, in 10 CFR Part 50, Appendix B (461/86053-04a).

1 While reviewing this 50.55(e) item, the inspector noted that no concern was expressed by the licensee for the many valves that were not able to perfor;e as designed at the recommended, nominal torque switch settings (even though i thetorqueswitchescouldbesethighenoughtoachievethedesignvalve thrust requirements). The licensee s staff subseocently indicated that they had discussed this with a Limitorque representative who stated that the " nominal" value is the lower end of the toraue switch setting range at which a valve may be expected to operate, and, that there is nothing unusual about a required torque switch setting anydere between " nominal" ,

and " maximum." The licensee explained that all safety-related valves are MOVATS tested to assure that the valve operator, with the "as left" torque switch settings, will operate as designed. Hence, the inspector.had no further question on this at the Clinton Nuclear P:wer Station.

This 50.55(e) item will remain open pending review of the final report '

(dated October 7,1986) and resolution of the violations identified with respect to the limiter plate modifications.

5. Followup on Allegations 4

i The inspector followed up on two allegations pertaining to activities at the Clinton site which involved the maintenance program. Results, discussed below, indicated problems with the conduct and review of maintenance activities and with the identification and implementation

• of corrective actions to adequately address problems.

j a. (Closed) Allegation (RIII-86-A-0027) l An individual contacted the NRC and staud that maintenance supervisors and management had ordered an employee to violate a procedure. The inspector determined from reviewing the individual's statement that the allegation consisted of three parts: (1) that maintenance supervision had ordered him to accept work on Testing of relief valves with an incomplete data sheet, CPS 8120.30 D001, " Relief Valve Test Data Sheet," (2) that he was being discriminated against under the IP Fitness for Duty Program, and (3) that there was a question on the i

8

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• 1 e j adequacy of various maintenance procedur s. Amdher item, Part (4),

.^ was identified in information received from thf Ocpartment of Labor which indicated tha't'isamed others were told t9 perform snubber.

< ' testing in violation of procedural steps. The inspector was unable'to f substantiate Parts (1), (2) or (4) of the allegation but was able to ,

7

, substantiate Part (3). Pertaining to the third portion of the

. ' allegation, one violation was identified with two examples.

NRC Review and Conclusions ,

l (1) The inspector reviewed the procedure and recorded data sheet CPS 8120.30, "Relie' valve Test." The,section of the procedure  !

that the individual had stated as beint, incomplete was Step 8.4.3 which require D ecording the relief valve's (1G33-607A) normal op6 rating tempe.rature fron'the valve's nemeplate (supplied by the

- manufacturer) or from otht.r cources, such as machinery history.

The individual had observe 3 the omission of this data during the review for closure and had reported this to the maintenance i i ' superviccr who then requested him to obtbin the information. The

• Individual believed that it was not permissiole to obtain the 4

i

~information required for Ste No. 8.4.3 out of sequence because 4 the procedure (CPS 8120.30) id not have any provision for performing steps out of sequence and, as such, the test should be.

re-performed % sequence to obtein this' data. Hence,.the individual perceived the maintenyce mpervisor's instruction as direction to violate a procedur&.

% s inspector confirmed the facts stated above through interviews with the individual and supervision; however, through a review of

the prc;edure, the inspector determined that recording the. data out of sequence did not invalidate the test. This portion of the

allegation is not substantiated and is the result of supervision not clearly comunicating the requirements of the test to the individual and the individual not clearly understanding the objectives of the test being performed. Additionally, the inspector interviewed 13 other individuals at random and found no other individual who had been ordered by supervision to violate any procedural requirements.

l (2) The inspector interviewed eight individt.als to determina if management or supervision had discriminated against the under the IP Fitness for Duty program because of raising safety concerns. Nor,e of those interviewed indicated that they were discriminated against because of raising safety concerns or j ider.iifying discrepancies. In addition, the individual was e interviewed and stated that the discrimination had' ceased. The individual believed this was due to changes in supervision. The inspector was unable to verify that discrimination was currently being e.oplied. Furthermore, the individual filed an employment i <

4 a

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I I

9

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(

s discrimination complaint with the U.S. Department of Labor. By letter, dated August 1,1986, the Labor Department concluded

". . . your allegations are unprovable . . . . The disciplinary suspensions that have been levied . . . were for actions that were not protected activities." This portion of the allegation could not be substantiated. -

(3)~ The individual identified that procedure CPS 8106.01, " Handling of Heavy Loads," Section 8.6.2 requires hand signals to be conspicuously posted and that these signs were not posted as required during heavy load handling. The individual had raised (

a concern on this item and received an unsatisfactory response g from the Administrative Assistant. Also, the individual's '

supervisor had requested a resolution on June 7,1986; however, ,

on August 28, 1986, the inspector found that IP was .still not f ri compliance with the procedure in that no hand signals were posted.

The failure to correct the missing hand signal ~ posting originally, when the procedure was first used, or to respond to the condition later in a timely manner is an example of a violation of Criterion XVI, Corrective Action, in 10 CFR Part 50, Appendix B .

(461/86053-04b).

On another occasion, the > individual had identified that the Procedure CFh No. 8227.01', " Standby Liquid Control Pump Maintenance,'* required to be'used by Maintenance Work Requ'est

! (MWR) No. B-15099 to change lubrication in the Standby Liquid 1 Control (StC) pump's crankcase, was not appropriate for the task.

The inspector reviewed the procedure and determined that it did

~

not provide instructions for adding the lub'ricant, the quantity, or specifications for type of lubricant. This is'a failure to provide procedures appropriate to the circumstances. In addition, the inspector found that a Condition Report (1-86-02-089) had b been issued on February 6,1986, identifying the above  !

) discrepancies and that the mainten6nce supervisor had also documented the discrepancies on the MWR; however, on August 28, f 1986, the inspector found that the~ procedure had not bcen revised to provide adequate instructions. The failure to promptly correct the inadequate procedure is an example of a violation of Criterion XVI, Corrective Action, in 10 CFR Part 50, Appendix B (461/86053-04c). This portion of the allegation was substantiated.

(4) The fourth portion of the allegation was not substantiated since, l as noted in (1), personnel interviewed did not indicate any instance where they had been ordered by supervision to violate a procedure.

b. (Closed) Allegation (RIII-86-A-0126)

In July 1986, an individual alleged problems with the conduct of motor-operated valve testing and maintenance, and with the adequacy of corrective actions for problems identified during the conduct of these activities. The key elements of the allegation were that:

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l

.a r l (1) condition reports were not written for MOV problems; (2) actions taken by Illinois Power to correct MOV failures did not correct the root cause of the problems, and (3) Field Engineering Change Notice l (FECN) 12329 contributed to the cause of some MOV failures. l NRC Review The inspector reviewed information provided by the individual and interviewed a number of maintenance mechanics, supervisors, and managers' involved in activities related to the allegation.

Documentation was reviewed including Maintenance Work Requests,

Condition Reports, memoranda, drawings, FECN 12329, and special problem evaluations that were conducted and documented by the licensee.

Findings with respect to the specific allegation items are identified below:

(1) Condition reports not written. The inspector confirmed this .

allegation and found that, while some problems were addressed by Condition Reports, others were handled within the Maintenance Work Requests, sometimes inadequately. Two examples of this and an associated violation are identified in Paragraph 6.b (MWRs No. B31175 and B24239) of this report.

(2) Inadequate corrective action. The inspector confirmed this allegation. It is related to 5.b.(1) above, because the Condition Reports are a critical part of the corrective action process. Inadequate corrective actions for maintenance problems are violations of Criterion XVI in Appendix B of 10 CFR Part 50 and are identified in Paragraphs 4.b, 5.a, 6.a, and 6.b of this report. Inadequate corrective action was also a contributor, in some instances, to other violations identified in this report.

(3) FECN 12329 contributed to MOV motor failures. This was verified.

i The licensee had also documented problems with the FECN and developed corrective action recommendations; however, the corrective actions were inadequate. Related violations are identified in Paragraph 6.a of this report.

Conclusions Based on the findings of this inspection the inspector concluded that all of the individual's concerns were valid and that problems did exist that were not properly handled. These are specifically discussed l in the referenced paragraphs. However, there were a number of actions

!. by the licensee to address the problems, some of which the individual l was not fully aware of or which had been initiated subsequent to the allegation. Most importantly, the licensee had initiated a program for post maintenance testing of all MOVs that appeared comprehensive in scope and adequate to detect the types of problems that had been occurring. Controls were initiated to assure that each safety-related 11

t MOV would receive this testing prior to deciaring it operable as required by the Plant Technical Specifications. The licensee had documented investigations and reports showing management's concern with the problems; however, the inspector concluded that licensee actions had not been sufficiently timely or adequate to address all problems identified.

6. Maintenance Program Implementation Maintenance inspection activities included: (a) interviews with maintenance mechanics and staff and review of maintenance problems identified with respect to the allegation noted in Paragraph 5.b of this report; (b) a review of completed maintenance work request packages, and (c) observations of mechanical, electrical, and Control and Instrumentation (C&I) maintenance activities. The inspection findings indicated a problem with the management control of maintenance activities. Inadequate training resulted in maintenance personnel errors (evident from equipment failures);

while inadequate provisions for the identification and correction of adverse conditions allowed such conditions to continue affecting plant equipment. From discussions with QA/QC, it was apparent that some problems' were being identified but there was inadequate support for their prompt and effective resolution. Also, it was evident from the mishandling of some of the technical problems encountered that better engineering support of maintenance was needed,

a. Maintenance Interviews and Review of Identified Maintenance Problems Maintenance personnel were interviewed with respect to allegations made about valve testing and modifications under maintenance work request packages. These packages involved the use of Maintenance Procedures No. 8451.01, 8451.02, and 8451.03 which, together, were issued for setup, testing, and maintenance of motor-operated valves.

The procedures involved the use of MOVATS Incorporated signature analysis test equipment.

Personnel interviewed identified problems that occurred early in the year, primarily due to inadequate training of the valve mechanics and an emphasis on plant schedules. A number of problems identified had been investigated by the licensee and corrective actions recommended.

Overall, the valve mechanics had a positive attitude about their i current involvement in maintenance activities and their qualifications in performing valve maintenance.

Further review of the identified problems indicated that the implementation of recommended corrective actions was not always adequate to correct the problem. Also, the underlying issue of inadequate maintenance program control was not properly addressed as evident from the violations identified during the inspection.

12

1 4

(1) Field Engineering Change Notice (FECN) No. 12329, issued on September 28, 1985, changed the configuration of three phase power wiring to valve motors from that specified on the drawings (to obtain proper motor rotation). New drawing copies issued did not reference the change because the FECN was not written against the drawings. This led to at least three valve motors being rewired according to the drawings such that they would experience burnout on the first valve stroke. (Motor rotation was opposite to that intended and motor damage occurred on at least one valve.) Failure to incorporate design changes into controlled design output documents is an example of a violation of Criterion III, Design Control, in 10 CFR Part 50, Appendix B (461/86053-01b).

The problem noted above was identified by the licensee at least by October 17, 1985, according to Condition Report No. 1-85-10-091. It was recognized as a deficiency against Corporate Nuclear Procedure, CNP 2.06, which directs plant configuration control measures. However, licensee corrective ,

action was inadequate to prevent subsequent miswirings (again as noted above). On discussing the matter in August 1986, the licensee's staff indicated to the inspector that FECN No. 12329 was attached or referenced on valve schematic drawings to assure proper control of the wiring. However, on requesting a wiring schematic from the drawing issue room, FECN No. 12329 was not referenced on the drawing and the drawing clerk was not aware of its existence. Hence, the drawing still failed to reflect the design change, the same problem identified in October 1985. The licensee issued the appropriate Engineering Change Notices against the drawings when the problem was pointed out by the inspector. Failure to take the necessary corrective action when the problem was identified by the licensee's staff in 1985 is considered an example of a violation of Criterion XVI, Corrective Action, in 10 CFR Part 50, Appendix B (461/86053-04d).

(2) During MOV modification and testing approximately 17 valves were modified with improperly set limit switches. Valve closure torque switch bypass limit switches, assigned to Limitorque valve operator switch rotor No. 4 contacts 15/15c, were reassigned under maintenance work requests to rotor No. 3 contacts 9/9c.

Rotor No. 3 was then reset to change position towards the closed valve position to retain the original intent of the bypass contacts. In the process, rotor No. 3 was incorrectly set 90 degrees off on approximately 17 valves. This had no affect on valve operation when the valves were exercised with an associated TEST / NORMAL switch in the test position; however, in the normal position, the erroneously set bypass that is brought into the circuit on valve closure causes the valve motor to stay energized at the end of valve travel. This results in locked rotor current and in physical damage to the motor until the windings open, or short out and the valve circuit breaker opens, or the thermal overload heaters fail open.

13

The problem was inadvertently discovered by the licensee during 1 a valve lineup on March 6, 1986, when main steam system containment isolation valves No. IB21-F0678 and 1B21-F067D were found closed so tightly that they could not be opened by the handwheel and would not work electrically. Prior to the time of discovery there was no QC inspection requirement for the orientation of the No. 3 rotors during or after their resetting; MOVATS switch signatures and switch signature analyses were insensitive to the. rotor orientation; post maintenance or modification testing was inadequate to discover the problem (as it was done with the TEST / NORMAL switch in the test position);

.and, operational surveillance testing, also done in the test mode, would not detect the faulty switch setting.

The licensee indicated that there was no review done originally.

for reportability under 10 CFR 50.55(e) for the erroneously set valves. Only 12 valves can now be identified out of the original 17; hence, it is impossible to determine the potential safety safety significance of the original missettings. It is known that they came from a set of 23 that includes residual heat

. removal, high pressure core spray, reactor core isolation cooling,

- main steam, drywell cooling, fuel pool cooling, and fire protection systems. If the problem had gone undetected until the valves were needed, any or all of these systems could have been rendered inoperable. There appear to be 4 factors contributing to the above: (1) inadequate design change verification (specification for post modification testing); (2) failure to follow procedures and drawings that led to the missettings; (3) inadequate quality control inspection to discover the problem; and (4) inadequate post maintenance test or surveillance test specification. The failure to conduct adequate testing appears to be the most.significant factor that led to allowing 17

. miswiring errors prior to the first discovery. This failure is considered an example of a violation of Criterion XI, Test Control, in 10 CFR Part 50, Appendix B (461/86053-03a).

The licensee had responded adequately to the switch setting

. problem at the time of the inspection, including the ongoing implementation of a comprehensive post maintenance test requirement that should detect the type of problem noted above before a valve is declared operable. On October 7, 1986, the licensee issued Attachment B to 10 CFR 50.55(e) Deficiency Report i No. 55-86-04. This is an addendum to the original report and addresses the cumulative problems identified during MOV testing.

It satisfies the reportability requirements for the 17 valve miswirings.

(3) Other items identified during interviews with the maintenance mechanics and supervisors included a potential problem with lubrication controls and a lack of effective shift turnovers.

Some mechanics and one supervisor were unaware of recently 4

14

implemented lubricant usage controls. Shift crews did not converse with the next shift to effect a smooth transition in the middle of a work activity. This was discussed with licensee management, who indicated that improvements would be considered, as appropriate.

b. Maintenance Work Request (WR) Package Review Approximately 20 recently completed WR packages were reviewed for adequacy of maintenance performed,- identification of equipment failure causes and appropriate corrective action, and general implementation of maintenance program requirements. Problems-identified during this review indicated inadequate program implementation in the areas of planning, mechanic qualification, adherence to procedures, package

review, problem identification, corrective action, and engineering support. Most significantly, improvements are needed in the

. licensee's own processes to identify and correct problems, both with the maintenance program and with the physical plant equipment. The following are specific findings related to the MWR package reviews. .

(1) WR No. B31175 This MWR was written to perform motor-operated valve testing, including the use of MOVATS test equipment, on Valve

, No. 1E32-F002J. When the valve failed to reach its target thrust value on April 2, 1986, the first response was to shave the torque switch limitor plate and increase the torque switch setting. This was apparently done without evaluating the problem

for cause and resulted in the valve motor going to locked rotor j conditions on valve closure.

An April 16, 1986, entry in the MWR log reporting reinstallation of the valve operator motor states "the wire coming from the motor to the heaters was made up with scotch locks. Two wires were loose and just end-capped while two more were jointed. We did not correct this because QA was not sure if . . . arrangements were already made." There is no other entry in the package to indicate that this condition was accepted as is or otherwise addressed and appears to be a failure to take corrective action for a condition adverse to quality.

An April 25 entry in the log indicates that with the valve vendor representative onsite, a high handwheel torque condition necessary to operate the valve led to the discovery of " extensive rust deposits" in the stem area inside the valve stem cover.

There is no indication in the package that the rust was removed or the stem lubricated.

A May 4 entry in the log indicates, " Repacked valve." A May 5 entry states, " Day shift supposedly had valve repaired but on further inspection the fitters had tightened packing so tight

valve would not turn by hand." On May 17 the log indicates that j the packing was again replaced and overtightened. A review of 15

. . ~_ __ .

.O I

the procedure specified in the WR for repacking instructions, CPS No. 8120.09, provided no guidance to prevent overtightening or test instructions to assure that this had not happened. Even though three sets of packing had been overtightened, one original and two replacements, no corrective action was addressed to prevent recurrence (which is particularly important if packing is reworked when a MOVATS test is not subsequently performed).

Troubleshooting and repairs were attempted and several MOVATS tests attempted from May 5 through May 13 without success in achieving the desired valve thrust. Finally, after the packing was replaced the second time, the yoke was repinned to the bonnet to repair looseness, and the operator was " reinstalled." The final test was successful with the torque switch settings at the minimum recc=cnded value. The data sheets indicate more than doubling of the thrust developed for a given torque and a load reduction from stem packing friction of approximately 3,000 pounds. The root cause of the original low thrust condition was apparently corrected but never identified.

The premature modification of the torque switch limiter plate, without addressing the cause of the low thrust problem, and the failure to document and evaluate the maintenance activities such that the cause could be determined are already included as a violation in Paragraph No. 4.b. In addition, other adverse conditions unrelated to the original intent of the MWR were identified including the wiring problems noted, i.e. , a loose yoke, a broken declutch lever pin, and three valve packing sets excessively tightened. The maintenance supervisor and QA both signed the MWR package as complete without addressing the cause of any of the above, and, the MWR, block No. 56, "cause code" was entered as "no failure." This is in violation of Administrative Procedure, CPS No. 1029.01, which states, " Evaluate the MWR for determination of root cause and adequacy of corrective action taken. Ensure block No. 56 is correctly filled out." These additional failures to address conditions identified after the MWR was issued are examples of a violation of Criterion XVI, Corrective Action, in 10 CFR Part 50, Appendix B (461/86053-04e).

(2) MWR No. B24239 This MWR was issued for testing valve No. 2SX076B which has a rotating stem. Page 6 of the MWR log indicates, " Stem wobble noted throughout entire stroke," then, on Page 18, an entry indicated "0K" in reference to the noted wobble. There is no indication that the wobble noted was ever evaluated, corrected, or accepted as is. On questioning from the inspector, the licensee indicated that the "OK" referred to an evaluation passed on verbally by the maintenance mechanic. Because the mechanic was not oualified to make that determination, and because of uncertainty of the nature of the wobble, the licensee reperformed a valve stroke for evaluation. They reported that the valve operated acceptably but that the stem was bent approximately 1/8 16 ,

t 3- inch off center. Engineering had not evaluated the acceptability of the bend at the time of the inspection (in terms of the affect on packing, strength of the stem, etc.). The failure to properly address the wobble is another example of failure to take adequate corrective action and is an example of a violation of Criterion XVI, Corrective Action, in 10 CFR Part 50, Appendix B i (461/86053-04f).

(3) WR No. C15673

. Documentation indicated as " attached" (a Nonconforming Material Report) was not attached. The missing documentation was located i and added to the package during the inspection.

l (4) WRs No. C05813, C18057 C06655, and C22713 During the review of these maintenance packages, the inspector noted that not all of the supporting documentation was attached, and as such, did not provide for an adequate assessment of the maintenance actually performed. In WR No. C22713, torque values' were not provided for bolting replaced after a relief valve gasket replacement. MWRs No. C05813 and C18057 required specific '

torque values to be applied; however, the documented work

description stated only that the components had been torqued and '

that the quality control inspector had accepted the maintenance.

i This did not provide assurance that the correct torque values

were applied or that the approval review of the maintenance activity could verify the adequacy of the maintenance performed.

3 MWR No. C06655 required replacement of two missing washers and bolts on a diesel generator repair activity. However, the review of the material receipts attached to the MWR documented that 101 i bolts and 10 washers had been received for installation per MWR No. C06655 and that 98 bolts and 10 washers had been returned i after completion of maintenance activities per MWR No. C06655.

The conclusion from the receipt documents would be that three l

bolts and no washers had been installed. However, the work description per MWR No. C06655 documented that two washers and

bolts had been installed. This problem was actually attributed i to the accounting method used by Clinton's purchasing where the

! actual counting of material was done upon return to purchasing l and not when issuing the material for use. This could lead to l the loss of accountability of safety-related or non safety-related i ' material resulting in an extensive search to determine the effect

. on the quality of the Clinton Power Station.

Both of these examples, failure to document the actual torque values applied and the lack of material accountability are i examples of violations of 10 CFR Part 50, Appendix B, Criterion V i (461/86053-02c) in that Administrative Procedure CPS No. 1029.01,

! " Preparation and Routing of Maintenance Work Requests,"

l Section 8.2.19, requires that all materials and parts be listed

&nd that all supporting data and documentation, such as receipts and torque values, be attached to the MWR.

l l

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t t

ct.

c. Observation of Maintenance Inspection in this area was limited to a small number of activities; 4 however. it was enough to indicate a need for better control of l mechanical maintenance. No problems were identified in the electrical l or C&I areas. '

In an attempt to observe mechanical maintenance, the inspector

! selected a second shift, valve repair activity that continued from

! work started on the previous shift. No maintenance was accomplished i

or observed because a lack of turnover between shifts caused confusion i 4

for the second shift mechanics about the status of previous electrical

!- work. As it turned out, a QC inspector had failed to sign off for

, this work prior to ending the first shift, and QA, on reviewing the

lack cf QC sign-off, found that QC was using an inspection sheet

written to Revision 6 of the maintenance procedure while work was actually being performed to Revision 7. On arriving to observe the l_ next available activity, the inspector found the work stopped because i

the mechanic did not have the drawing he needed and did not seem to understand where to start (in the middle of work already begun by .

others). When the supervisor went to the job location to assist the i mechanic, the supervisor discovered that the material already in place for the job was not as specified by the drawings. Hence, this work was stopped pending resolution of the material problems. The next activity observed involved the adjustment of fire and secondary containment door closure mechanisms. No problem was identified with

the maintenance work activity; however, the inspector noted that a l problem report had been written involving difficulties encountered t when the doors were closing against a small, confined space. It did '

not appear that closure mechanism adjustment was going to resolve the i problem because of the air pressure resistance at the end of door

closure.

! These maintenance problems observed were noted to licensee management for consideration. No violations were identified since the licensee identified the problems noted and acted appropriately to take corrective action. However, the problems noted are definitely not indicative of a well controlled process and indicate the need for improvement of the licensee's control of maintenance activities.

7. Motor-Operated Valve Control Logic ,

The motor-operated valve control logic adopted by Illinois Power appears unnecessarily complex and has contributed to valve problems identified in this report. The design appears to be the result of combining the following: (1) common practice in the use of small motor, motor overload relays; (2) Illinois Power's, General Electric's, and Sargent and Lundy's philosophy for application of Limitorque geared limit switches and torque switches; and (3) NRC concerns suggesting bypassing motor overload relays per Regulatory Guide 1.106. The resulting design failed to consider potential problems with unnecessary complications in the final design.

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The circuit design (also discussed in Inspection Report No. 50-461/86045(DRS), Paragraph 3.a) incorporates motor overload relays and bypass switches in the main control room which not only bypass the overloads but also change the torque switch bypass logic. Per Surveillance Procedure CPS No. 9381.01, Revision 20, MOV Thermal Overload Bypass Device Verification, there are 111 bypass switches for 312 valves. Wires are disconnected and then relanded in the energized condition in order to.

verify that each valves associated bypass contacts open. (The bypass function itself is not fully verified by this test.) The inspector stated that the goals of safe and reliable valve operation might be better served by a simplified design that could eliminate this requirement. This could also simplify programmatic evolutions in the areas of setup, maintenance, testina, operating, and surveillance. The licensee noted the inspector's comments on this item and agreed that some simple changes in the circuit design appeared beneficial.

8. Modification Program Implementation

a. Scope of Inspection ,

Completed modification packages were inspected to determine the adequacy of the modification program implementation. This included a review of safety evaluations and post modification test procedures, criteria, results, and acceptance. The inspection indicated that program implementation was generally inadequate. Violations were identified in the areas of safety evaluations, post modification testing, procedure adherence, test control, and corrective action.

Because of problems identified, the licensee proposed immediate

! measures to complete necessary testing and to assure that design modifications and applicat,le testing were adequate. The packages were j reviewed to assure that none of the completed preoperational test

! results were invalidated. This was done to assure plant readiness for i the low power license. During the period of September 22-29, 1986, l the inspectors reviewed a random sample of the licensee's rework on the packages and found the documentation to be adequate to support the i

acceptability of the licensee's activities and that there was no reason to restrain plant licensing because of this issue.

b. Modification Packages Reviewed The inspectors reviewed the following modification packages:

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• HP-06, Added a pipe support to the High Pressure Core Spray (HPCS) minimum flow line as corrective action for vibration discrerencies identified during transient testing.

• AZ-10, Incorporated power supply separation to meet the requirements of 10 CFR Part 50, Appendix R.

• IA-10, Incorporated filtration for secondary instrument air to the Main Steam Isolation Valves (MSIV) and Safety Relief Valves (SRV).

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• PR-11, incorporated authorization to use larger pump motors for fixed and portable Containment Atmosphere Monitoring (CAM) units.

• AP-12, Incorporated revised relay and breaker settings to provide coordination of Division 1 and 2 Motor Control Centers (MCC) to meet the requirements of 10 CFR Part 50, Appendix R.

• MS-13, Incorporated the use of butt welds instead of socket welds on the air supply lines to the SRVs.

• SX-12, Replaced three foot pound motors on operators for valves No. ISX063A and ISX063B with five foot pound motors. These valves are the discharge valves from the safe shutdown cooling system to the DG heat exchangers.

• SX-15, Incorporated a multi-hole orifice in the Fuel Pool .

Cooling (FPC) Heat Exchanger piping to reduce unsatisfactory system vibrations identified during testing.

• HP-17, Incorporated authorization to fabricate Limitorque motor pinion keys and corrective action for an identified condition on Limitorque motor-operator models No. SMB-3, 4, and 5.

• RH-17, Incorporated design change of Valve No. 1E12-F023 motor-operator (Residual Heat Removal (RHR) system test return line) as corrective actions for a previous failure of the motor-operator and to support MOVATS testing.

• DG-24, Incorporated changes to the start system logic in the Division III emergency diesel generator (dedicated to the HPCS system).

• DG-35, Incorporated de-energizing the Division III Air Start Air Compressor (ASAC) and the generator space heater during a Loss Of Coolant Accident (LOCA) since these devices are not qualified or isolated from the safety-related bus as required by Illinois Power FSAR commitments.

• DG-36, Incorporated recalculation of the HPCS MCC loads due to various changes in overload heater size, breaker size, and trip settings.

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• DG-39, Incorporated installation of heavier springs in the existing Divisions 1 and 2 emergency diesel generator air start solenoids. The actual installation was completed under Temporary Modification No.86-057.

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These 14 plant modifications were a random selection from those for which applicable preoperational testing had been completed, reviewed, and approved by the Test Result Review Group (TRRG) and the Joint Test Group (JTG).

c. Inspection Results (1) Safety Evaluations Since the licensee had not yet obtained an NRC operating license, the provisions of 10 CFR 50.59 did not directly apply to the modifications reviewed. However, since the FSAR had been

" frozen," the licensee had implemented the provisions of 10 CFR 50.59 through procedure CPS No. 1005.06. " Conduct of 10 CFR 50.59 Reviews," as a means of assuring that the plant configuration remained consistent with the plant safety analysis.

Two of the safety evaluations reviewed were found to be deficient.

(a) Modification No. DG-24 .

The Division III Diesel Generator (DG) is dedicated to the HPCS system. The start circuitry for this DG contains a seal-in feature for the start signal. Prior to this modification, a start signal would seal-in if the DG were in the " emergency stop" mode or " operate" mode. Further, if a start signal were received while the DG was in the " emergency stop" mode, or if the emergency stop were used to terminate a DG start from a spurious start signal, the DG would start if subsequently placed in the " maintenance" or " operate" modes due to the sealed-in signal. Modification No. DG-24 modified the circuit for the Division III DG by de-energizing the seal-in relay when the DG was in the " emergency stop"

! mode. This cleared any previously sealed-in start signal and prevented any new start signal from sealing-in when placed in the " emergency stop" mode. The reason stated for performing the modification was that Technical Specification No. 4.8.1.1.2.e.14 requires that the " maintenance" mode prevent the DG from starting.

I Procedure CPS No. 1005.06, " Conduct of 10 CFR 50.59 Reviews,"

l requires that the basis for concluding that no unreviewed i safety question exists be documented. The documented safety evaluation did not address the function of the start signal seal-in or what impact the modification had on the previous safety evaluation. Therefore, there was no documented basis for concluding that modifying the seal-in feature presented no unreviewed safety question.

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t (b) Modification No. SX-12 The safety evaluation performed for Modification No. SX-12 in accordance with CPS No. 1005.06 also failed to provide a basis for concluding that no unreviewed safety question existed. This included a failure to assess the potential impact of added power requirements for the larger motors on the emergency power sources.

These examples of the failure to document the bases for concluding that no unreviewed safety question existed as required by CPS No. 1005.06 are examples of a violation of 10 CFR Part 50, Appendix B, Criterion V, (461/86053-02d).

(2) Post Modification Testino Seven of the modifications reviewed contained inadequate post modification testing. This resulted largely from the lack of adequate acceptance criteria on which to base a test.

(a) Modification No. HP-06 Modification Package No. HP-06 contained no test acceptance criteria.

(b) Modification No. PR-11 Modification No. PR-11 test acceptance criteria prescribed on form No. 1011.01F001 stated, "after pump / motor installation, functionally test (the) pump operation." This is not acceptance criteria as defined by CPS Station Operating Manual Administrative Procedure CPS No. 1005.01,

" Preparation, Review, Approval, and Implementation of Station Procedures and Documents" which requires the specification of design or operation limits "against which the test results shall be judged for approval / disapproval."

(c) Modification No. AP-12 Modification No. AP-12 prescribed, on Form CPS No. 1011.01F001, a surveillance test and drawing " CPS No. 8504.01 and E02-1AP04" as acceptance criteria. Design and operating limits were not clearly stated; hence, judgement could not be clearly made for approval / disapproval or evaluation of the adequacy of the design modification.

(d) Modification No. SX-12 Modification No. SX-12 contained no acceptance criteria to verify the adequacy of using larger, modified valve motors.

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(e) Modification No. SX-15 Modification'No. SX-15 did not provide acceptance criteria for evaluating the vibration data other than "per NSED 1 Detailed Impact Assessment, required testing has alread been performed under Temporary" Modification No.86-164.y The"testingalreadyperformed contained no design or operating limits for acceptance, only data that was collected, reviewed and approved by NSED. ,

(f) Modifications No. R-17. DG-35, and DG-39 Modifications No. RH-17, DG-35, and DG-39 prescribed either a specific surveillance test or just " functionally test" as acceptance criteria which do not meet the requirements for criteria.

(g) Modification No. DG-24 Modification No. DG-24 provided no acceptance criteria nor was any post modification test performed.

t In general, test evaluations and documented test acceptances for the design and installation adequacy of the above modifications were inadequate in that appropriate test acceptance criteria were not identified. . Criterion III, Design Control, in 10 CFR Part 50, Appendix B, requires verifying the adequacy of design by suitable testing and that design changes be subject to the same control measures as those applied to the original design. CPS Procedure No. 1005.01, Appendix A, implements this, in part, by requiring post modification testing and that " specific acceptance criteria, against which the test results shall be judged for approval / disapproval, shall be clearly stated." The failures to specify post modification test criteria are examples of a violation of 10 CFR Part 50, Appendix B, Criterion III (461/86053-01c). l (3) Test Documentation Clinton Power Station administrative Procedure No. CPS 1003.01,

" Design Control and Modification" which implements the .

requirements of Corporate Nuclear Procedures No. 4.05," Plant Modification Control Procedure" and 4.08, " Plant Modification System" requires in Section 8.1.13 for major modifications and 8.2.11 for minor modifications that all testing documentation shall be attached to the Plant Modification Package by the Plant Technical System Engineer. However, the inspectors found that seven modification packages (PR-11, AP-12, SX-12, HP-17 RH-17, DG-24 and DG-39) did not contain test data or test procedures.

The inspector did find that the data may be included in ,

maintenance work tequest or surveillance test documentation but would not be included in the modification package for review or approval. The failure to follow Procedure No. CPS 1003.01 is an example of a violation of 10 CFR Part 50, Appendix B, Criterion V (461/86053-02e). ,

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l During the reviews of modification packages for HP-06 and SX-15, the inspectors noted that the post-modification testing directions were not prepared in accordance with CPS 1011.01 in that precautions, responsibilities, prerequisites, limitations, test equipment, acceptance criteria, system restoration, etc., were not properly addressed. Procedure No. CPS 1011.01 implements the requirements of 10 CFR Part 50, Appendix B, Criterion XI, Test Control. The two examples noted above, in failing to properly control testing, are examples of a violation of Criterion XI (461/86053-03b).

(4) Corrective Actions During the review of the PR-11 modification package, the inspector found that the modification of increasing the size of the air pump motors and modifying the installation mounting of the compressor assemblies on the Containment Atmosphere

, Monitoring (CAM) units were, in part, corrective actions for Condition Report No. 1-86-06-001. The condition report was originated on May 29, 1986, because Stone and Webster Engineering-Corporation (Contractor) maintenance personnel had replaced a 1/3 horse power (H.P.) motor with a 1/2 H.P. motor from the same manufacturer (Thomas Industries) without initiating a modification.

As a result of a Facility Review Group (FRG) meeting on June 27, 1986, a Clinton Power Station Comment Control Form was initiated on July 1, 1986, requiring NSED to " address the potential hole (or breakdown) in configuration management in that a different size motor was bought, approved by NSED and (IP) Quality, and installed without a plant modification review." The FRG comment also identified a safet configuration control."y concern because of the " lack ofThe NSED's re actions was that " Plant Modification No. PR-11 has been issued to

! cover installation of the replacement compressor assemblies" and that "NSED is revising some internal procedures and conducting training to better define configuration control on vendor designed and supplied equipment." The inspector found these corrective actions to be inadequate in that they did not provide measures to prevent maintenance contractors, such as SWEC, from repeating unauthorized modifications, since revising procedures and conducting training on configuration control is internal to NSED.

The failure to identify and correct the root cause of a condition adverse to quality is an example of a violation of 10 CFR Part 50, Similar violations Appendix B, Criterion XVIaredocumentedinInspectIon(461/86053-04g)

Report No. 50-461/86052 and others where Illinois Power has failed to take corrective actions to preclude repetition of identified conditions adverse to quality.

Another example of an unauthorized modification is given in Paragraph 3.a of this report.

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c.

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d. Conclusions During the review of the modification packages, various problems were identified. In general the inspectors found that the requirements of the licensee's program w,ere not properly implemented at any level, 1

including Nuclear Station Engineering Department (NSED), Plant Staff-Technical and the responsible supervision and management of these organizations. The ins because the engineers,supervisors pectors concluded that this condition and the Director-Plant Technicalexisted y

were not fully aware of the requirements of the Corporate Program, procedures (Corporate and Station), and their responsibilities under

these programs and procedures. i 4 9. Management Meetino

a. Exit Interview on September 12, 1986

The inspector met with licensee representatives (denoted in Paragraph 1) on Se of the inspection.ptember 12, 1986, The licensee to discussthe acknowledged thestatements scope and madefindings by

• the inspector with respect to items discussed in the report. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietary.

b. Management Meeting on September 19, 1986 During the inspection, it was apparent that there were significant problems with management control of the plant maintenance and j modification programs. Problem areas within these programs are related to the quality assurance criteria in Appendix B of 10.CFR 50.

They include Design Control - Criterion III; Instructions, Procedures

and Drawings - Criterion V; Test Control - Criterion XI; and Corrective i

Action - Criterion XVI. Together, the problems identified represent a programmatic breakdown in the maintenance and modifications areas, i due to inadequate management control, and represent a failure to comply with Criterion II, Quality Assurance Program, which requires

the suitable control of activities affecting quality.

4 During a management meeting in the Region III office on September 19, 1986, the licensee presented their understanding of the cause of the problems identified and a program of corrective action. A proposal was made and agreement was reached with the Region III staff on items to be satisfactorily completed prior to low power licensing. The i proposals for long term corrective action appeared adequate and j responsive to all the issues identified.

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Attachment:

j Cross

Reference:

Violation Examples to Report Details 25

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Clinton Report No. 50-461/86053 CROSS

REFERENCE:

VIOLATION EXAMPLES TO REPORT DETAILS 4

Tracking Page Appendix B Number Number Paragraph Criterion Violation 02a 4 3.e V Failure to lubricate valves per GTP-55, failure to correct procedure, and failure to provide an adequate procedure.

02b 6 3.f.6 V Failure to identify unqualified conditions during implementation of 8451.03.

Ola 7 4.a III Improper handling of a -

modification regarding the filing down of torque switch limiter plates.

04a 8 4.b XVI Failure to properly evaluate the cause of equipment failure during torque switch adjustments.

04b 10 5.a.(3) XVI Failure to implement corrective actions regarding procedural violations of 8106.01.

04c 10 5.a.(3) XVI Failure to implement corrective actions regarding

. inadequate procedure 8227.01.

Olb 13 6.a.(1) III Failure to incorporate design changes into controlled design i output documents.

04d 13 6.a.(1) XVI Failure to take corrective action regarding Condition

Report No. 1-85-10-091.

03a 14 6.a.(2) XI Failure to conduct adequate I testing which allowed miswiring of 17 torque switch bypass limit switches.1 t

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T .

y 04e 16 6.b.(1) XVI Failure to evaluate root cause and take corrective .

actions regarding problems l identified in MWR No. 831175.2 '

04f 17 6.b.(2) XVI Failure to evaluate root cause and take corrective action regarding wobble of valve in MWR No. B24239.

02c 17 6.b.(4) V Failure to document torque values for MWRS No. C22713, C05813, and C18057; and lack of material accountability for MWR No. C06655.

02d 22 8.c.(1)(a) V Failure to document bases for 8.c.(1)(b) concluding no unreviewed safety question existed per Procedure CPS No. 1005.06 -

Olc 23 8.c.(2)(a) III Failure to specify post 8.c.(2)(b) modification test criteria.

8.c.(2)(c) 8.c.(2)(d) 8.c.(2)(e) 8.c.(2)(f) 8.c.(2)(g) 02e 23 8.c.(3) V Failure to include test data or test procedure with vaulted modification packages as specified in Procedure No. CPS 1003.01.

03b 24 8.c.(3) XI Failure to properly control testing for modifications No. HP-06 and SX-15.

04g 24 8.c.(4) XVI Failure to identify and correct the root cause of '

unauthorized plant modification by SWEC.

2Although identified against Criterion XI, this violation also involved failure to follow procedures (Criterion V) and inadequate design change verification (Criterion III).

2Although identified against Criterion XVI, this violation also involved failure to follow procedures (Criterion V).

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