ML20215A238

Initial OL Readiness Assessment for Clinton Power Station

ML20215A238
Person / Time
Site:	Clinton
Issue date:	09/29/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215A233	List: ML20215A230 ML20215A238
References
NUDOCS 8610030549
Download: ML20215A238 (28)

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INITIAL OPERATING LICENSE READINESS ASSESSMENT FOR CLINTON NUCLEAR POWER STATION PREPARED BY UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III l

l 8610030549 860929 PDR ADOCK 0500 1

4 CLINTON NUCLEAR POWER STATION INITIAL OPERATING LICENSE READINESS ASSESSMENT

1. Introduction

2. Summary of SALP Reports

3. Region III Inspection Program 3.1 Construction and Preoperational Inspection Programs 3.1.1 Construction 3.1.2 Preoperational Testing 3.1.3 Independent Design Review 3.1.4 Construction Appraisal Team Inspection 3.2 Open Inspection Items 3.3 Enforcement History 3.4 Qualifications of Licensee Personnel 3.5 Licensing and Design Issues 3.6 Regional Staff Concerns

4. Quality Assurance 4.1 Organizations 4.2 Audits 4.3 Stop Work 4.4 Independent Evaluations 4.5 Conclusions

5. Hearings - Petition to Intervene

6. Allegations

7. 0.I. Investigations

8. Summary and Conclusions 2

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Operational Readiness

1. Introduction Clinton is a 2984 MWT General Electric BWR/6 Boiling Water Reactor, with a Mark III containment. The plant is located in central Illinois in DeWitt county, approximately 22 miles north of Decatur and 30 miles west of Champaign, Illinois. Condenser cooling is provided by a 5,000 acre man-made lake formed by an earthen dam on Salt Creek. The balance of the Plant was designed by Sargent and Lundy Engineers. The plant was constructed by Baldwin Associates, a consortium of construction firms based in Illinois.

The Clinton plant is co-owned and managed by Illinois Power Company, with home offices located in Decatur, Illinois. Other co-owners are Soyland Power Cooperative and Western Illinois Power Cooperative.

Based on Regional review and the results of our inspection efforts, we have determined that construction and preoperational testing of the Clinton facility has been completed in substantial agreement with docketed commitments and regulatory requirements with the exception of items delineated in the Attachment one to the Clinton Power Station operating license. The attachment one is being provided to your staff by separate memorandum. This report provides the bases for the above findings.

Since issuance of the Construction permit in February 1976, the NRC has conducted approximately 300 inspections at the Clinton site. To accomplish the inspection program, in excess of 29,000 inspection hours of direct inspection effort have been expended. As a result of these inspections 120 violations have been identified by NRC inspectors at Clinton. No orders have been issued. One civil penalty amounting to

$90,000 was issued on October 5, 1982. Two escalated enforcement cases are pending. (See Section 3.3) i Section 2 of this report summarizes the Region III assessment of licensee performance during SALP periods One through Five, which covers the period July 1, 1979 through August 31, 1985.

1 Sections 3, 6, and 7 describe the Region III inspection program at the Clinton site, resolution of allegations related to Clinton, and the results of investigations performed by the Office of Investigations.

Section 4 describes the Illinois Power Company (IP) quality assurance program and its evaluations throughout the construction period. This i section also deals with independent evaluations performed for the Clinton site. ,

I Section 5 deals with the agreement with the state of Illinois in withdrawing from the licensing board proceedings.

1 Section 8 provides the overall conclusions of the staff's assessment of Clinton's readiness for operation.

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2. Summary of SALP Reports The performance of Illinois Power Company (IP) at Clinton has been evaluated five times by means of the SALP (Systematic Assessment of Licensee Performance) program. SALP six report period closed on August 31, 1986. Inputs are currently being prepared. The SALP meeting with the licensee will be held prior to exceeding five percent power.

The five assessment periods and the applicant's performance are summarized below:

SALP One The first Clinton SALP addressed performance during the period July 1, 1979, through June 30, 1980. A management meeting was held with the applicant on October 28, 1980, to discuss the results of the SALP evaluation. The NRC concluded that the noncompliance history appears to be average when compared with other facilities at approximately the same stage of construction. Overall licensee performance was judged as adequate. Increased NRC followup was planned in the areas of quality assurance, management, and training.

SALP Two The second Clinton SALP covered IP's performance during the period from July 1, 1980 to September 30, 1981. The management meeting with the applicant was held on June 8, 1982. The applicant was rated in nine functional areas. I The overall regulatory performance of Illinois Power Company at the Clinton Nuclear Generating Station was deemed to be marginal during the assessment period, warranting increased management attention in Quality Assurance and Quality Control Programs. The applicant was rated Category 2 in six areas. The applicant was rated Category 3 in two areas -- Quality Assurance, and Piping Systems and Supports. The' applicant was not rated in Electrical Power and Distribution. The dppliCant Was rated Category 3 in Quality Assurance due to the number and nature of quality related issues such as those experienced in the piping and electrical areas. The Category 3 rating in the piping area i

l was due to issues identified during the inspection conducted early in 1981 resulting in a stop work on large bore hangers. The Electrical l functional area wae, not rated because it was deemed not to be at least minimally satisfactory. The applicant's performance did not meet this standard in that work was stopped and remained stopped at the time of the evaluation due to significant quality assurance deficiencies identified in early 1982. These deficiencies, while identified after the evaluation period, were based on conditions existing during the SALP evaluation period. The latter three functional areas are discussed further in Section 3.1.

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SALP Three SALP Three covered IP's performance during the period October 1, 1981 to September 30, 1982. The management meeting with the applicant was held on March 17, 1983. The SALP report covered eleven functional '

areas.

Quality assurance was rated as a Category 3. Support systems were not rated because licensee performance was in a period of transition between identifying past weaknesses and correcting them. Electrical Power and Distribution did not receive a rating because it was not at least minimally acceptable and work had already been stopped to correct significant quality assurance deficiencies (see Section 3.1.1 and SALP 2).

The NRC observed that there was positive evidence in the second half of the assessment period to indicate a rededication to quality assurance and that Region III was encouraged by the results achieved towards the end of the assessment period.

SALP Four SALP Four for Clinton covered IP's performance during the period from October 1, 1982 through February 29, 1984. The management meeting with the applicant was held on May 31, 1984. This period represented a major transition between Stop Work Orders initiated in certain areas during the previous assessment period and a return to general construction activities towards the latter part of this assessment period.

The applicant was rated in ten functional areas. All functional areas were rated as Category 2. Overall, the NRC concluded that the applicant's performance was found to be improved and acceptable in each functional area and that commitment to quality was generally evident at all levels of management and staff. The applicant's staff effort to improve performance in Support Systems, Electrical Power and Control Systems, and Quality Assurance was deemed by the NRC to be notable.

SALP Five SALP Five for Clinton covered the period March 1, 1984 to August 31, 1985. The management meeting with the applicant was held on December 12, 1985. The regulatory performance at the Clinton Power Station was considered by the NRC to be acceptable during the assessment period. The applicant was rated as Category 1 in three areas (Containment and other Safety-Related Structures, Piping Systems and Supports, and Licensing Activities). IP was rated as Catagory 2 in the other eleven areas.

Increased management attention to all areas of performance was apparent during the latter part of the assessment period.

3. Region III Inspection Program Starting in 1975, a number of NRC inspections (approximately 300) have been conducted at the Clinton Station. The inspections are summarized in Table 3.1 and Figure 3.1.

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3.1 Construction and Preoperational Inspection Programs 3.1.1 Construction Preconstruction inspections began at the Clinton Site in 1975.

During the period 1975 thru 1980 the inspections and enforcmement actions taken by RIII were average for construction sites at that stage of completion.

During a team inspection conducted by Region III inspectors between February 9 and March 5, 1981, a number of significant deficiencies were found in the area of fabrication, installation, and inspection of seismic Category 1 supports and restraints for piping and electrical raceways. A Confirmatory Action Letter (CAL) dated February 18, 1981 was issued by Region III documenting the stop work on large bore pipe hangers imposed by IP on February 13, 1981 and the action to be taken by Illinois power to resolve problems identified during that inspection. Subsequently a trial installation and inspection program was initiated by Illinois Power on a limited number of large bore hangers.

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

Due to allegations received in December 1981, an inspection was conducted during the period January 5 to March 3, 1982. Significant deficiencies were found in electrical construction activities at the Clinton Power Station. This was evidenced by numerous examples of violations with eleven of the 18 criteria for a quality assurance program as set forth in Appendix B to 10 CFR Part 50. As a result of preliminary investigation findings, Illinois Power company issued a stop work for specified electrical activities. On January 27, 1982, Region III issued a Confirmatory Action Letter (CAL) addressing the stop work order and describing programmatic changes that would be necessary prior to the resumption of such work. Another finding during that inspection related to the intimidation of quality control inspectors by Baldwin Associates management personnel including the discharge of two BA Quality Control inspectors for  ;

providing information to the NRC.

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

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

The applicant initiated a review of other areas. This information was provided to the NRC on June 4, 1982.

This review indicated problems existed in other functional areas. Based on these reviews Illinois Power Company issued eight additional stop work actions, due to quality control inspections not keeping pace with ongoing construction and the identification of additional hardware problems in these additional functional areas. The stop work orders included heating, ventilation, and air conditioning (HVAC) work; first attachment welds associated with HVAC components; electrical conduits; electrical equipment installation; electrical instrumentation; structural steel; refueling bellows; and procurement of spare and replacement parts.

In July 1982 there was an IP-NRC management meeting to discuss the numerous and repetitive problems identified by IP and the NRC. During the meeting IP presented a Quality Recovery Program (QRP) to the NRC to demonstrate that assembled structures, systems and components met ~ regulatory requirements. The NRC subsequently requested IP to provide more explicit description of their plans for reinspection of work performed prior to June 1982. After further meetings, the NRC issued a CAL on September 1, 1982,-acknowledging IP's intention to perform a sampling reinspection of work completed prior to July 1982 and to perform a 100% reinspection of documents pertaining to construction and other quality activities.

Due to several false starts on the reinspection of completed work, the NRC issued a CAL on October 5, 1982 ,

which stopped all overinspections until further training 1 was completed and until a more complete overinspection program plan was developed by IP and concurred in by the NRC.

After a new submittal by IP, the NRC concurred on December 3, 1982 with the intent of the reinspection plan. After several inspections by the NRC overviewing limited reinspections by IP and BA, the reinspection program was fully implemented in September 1983.

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The overinspection plan approved by the NRC called for sampling by both BA and IP. Each overinspection group (BA & IP) would select a sample from a lot based on MIL Standard 105-D and inspect independently of each other. Many components received three 100% inspections.

(Initial QC inspection, BA verification inspection and IP overinspection) because the resultant lot sizes were too small for sampling.

During 1982 and 1983 a number of improvements other than those listed above were made by IP including;

• A number of Engineering, Quality Assurance, and Management personnel were moved on site including a Vice President to take charge and direct Quality Assurance, Engineering, Startup, and Operations activities.

• Stone and Webster was retained by IP as first line management in support of construction.

• The IP and BA Quality organizations were changed to a more functional mode and those staffs were greatly increased in size. IP clarified and strengthened its role in management of the QA program.

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• IP developed an enhanced program for corrective action.

• Overall training programs for IP and BA were extensively modified and improved.

• BA job instructions and quality control checklists were revised and upgraded.

As a condition of the CAL, each area affected by a stop work order was released only after Region III verified by review and inspection that the prerequisites for the recovery plan were in place and implemented. Region III assured itself that implementing procedures were in place, personnel were trained to the procedural requirements and IP had assured itself that work was ready to restart. All stop works were lifted by IP by December 1983.

A number of inspections were conducted by the NRC to verify the implementation of the overinspection program.

Two violations were identified in the electrical area regarding completeness of vendor documentation and storage of materials. Both items were of minor significance.

After a review of IP and BA's overinspection of large bore piping and mechanical supports and data provided by IP, the NRC concurred in the termination of the overinspection program in that area in July 1985.

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Subsequently, the conclusion of the overinspection program was documented by IP in a letter to Region III on April 3, 1986. Based on numerous inspections of the Clinton Nuclear Power station and Sargent and Lundy, the NRC concurred in this action. Illinois Power concluded that none of the thousands of discrepant attributes identified during overinspection had any significance to safety.

In a letter to IP on September 4, 1986, Region IIII-stated: " Based on Region III's review of Illinois Power Company's overinspection data and engineering evaluations and Region III's independent inspection, review, and evaluation, it is concluded that the Overinspection Program was conducted in accordance with approved plans and procedures, and that none of the discrepant attributes identified during the overinspection had significant safety implications. Region III's review of the Overinspection Program is completed and the results are acceptable to us."

In a letter dated November 15, 1986, IP stated they intended to terminate a records verification program (RVP) which had been instituted in 1983 due to a large number of documents having a number of deficiencies.

The RVP was intended to augment the normal Clinton Power Station Quality Assurance records program and provide additional assurance on the acceptability of the IP construction QA records.

IP stated that the results of the RVP, after reviewing 80% of the documents, indicated that there were no safety significant nonconformances identified as a result of the RVP reviews, no difficulties that had adverse implications on hardware quality, and that there was an adequate level of confidence in the acceptability of the Clinton construction QA records. The NRC performed an inspection of the Clinton RVP in January and February 1986. The inspection was an indepth review consisting of RVP controls, implementation and qualification of personnel.

The NRC concluded the decision to terminate the RVP program was well supported and the NRC concurred with the termination.

3.1.2 Preoperational Testing During late 1984, all of 1985, and through the present, Region III has inspected the program for preoperational testing and it's implementation at Clinton Power Station.

As discussed in Section 2.0, IP was rated category 2 in this area during SALP 5. Current performance trends show further improvement in this SALP functional area. IPs 9

recent performance in this area has been very good with only minor regulatory issues identified during the conduct of the test program. Test results, which are currently under review by Region III, have generally demonstrated the quality of the design and hardware at Clinton.

Hardware deficiencies identified dur9 g the test program have been reported when required, dorumented, dispostioned, and corrected in accordance with the licensee's QA program. There are no safety significant issues in this are that restrain the issuance of an operating license.

The licensee has requested deferral of the performance of a number of preoperational tests until after fuel load.

The deferral request was reviewed by Region III and found to be technically sound. Region III's only reservation in this area was the potential impact of increased activity levels in the small Clinton Power Generation Control Complex (horseshoe) on the ability of inexperienced operators to provide control over plant operations.

Recent inspections have demonstrated that adequate controls are in place to allow low power operation.

Recent inspections by the NRC have identified improper post maintenance and post modification testing of systems following Pre-Operational testing. The licensee has reviewed all modification packages and has retested as appropriate. Region III has reviewed a sample of the maintenance and modification testing packages and found them to be acceptable. Enforcement actions are still under review.

3.1.3 Independent Design Review In May 1984, Illinois Power submitted a plan to the NRC for an independent design review of the Clinton Power Station. The review was intended to provide the NRC with additional assurance that the design of Clinton was consistent with the design description in the Final Safety Analysis Report and Safety Evaluation Report and its supplements.

The review was started in July 1984 by Bechtel Corporation and was completed in December of the same year. NRC's Office of Inspection a :d Enforcement ensured that the review was conducted in accordance with the approved plan as documented in a special inspection report dated November 1984. The special inspection included evaluations of the review team's walkdown activities and the comprehensiveness of the design reviews being conducted. The final Independent Design Report was issued by Bechtel Corporation in January 1985.

The report's conclusion was that the design work which 10

4 was reviewed generally satisfied licensing commitments and met acceptable standards for technical adequacy; however, there were discrepancies with undocumented engineering judgments, control of document changes, and control of design interfaces. The Office of Inspection and Enforcement substantiated Bechtel's conclusion that none of the discrepancies were significant enough to require an independent design review in other systems.

Region III conducted an inspection at Sargent & Lundy, the architect engineer, in May 1985 to verify implementation of the corrective actions agreed to as a result of the final Independent Design Review Report.

Results of the Region III inspection were favorable and were summarized in Supplemental Safety Evaluation Report (SSER) Amendment 5.

3.1.4 Construction Appraisal Team (CAT) Inspection The CAT inspection was discussed during the December 1984 meeting held in the Region III office with Illinois Power, the State of Illinois Attorney General, and NRC staff.

The meeting provided general agreement between the State of Illinois and the NRC on conduct of the CAT inspection.

Approximately 2500 inspection hours were utilized during the inspection conducted during May and June 1985. The CAT inspection included concrete placement and testing; electrical raceways, supports, cables and equipment; pipe, pipe supports and restraints; expansion anchors; heating, ventilating and air conditioning; welding; nondestructive examinations; and structural steel. Also included were the general quality aspects of procurement, maintenance, material traceability, and processing field changes and nonconforming conditions. Some items selected for inspection included those which had been completed as part of the overinspection program. The CAT identified problems with the program for inspection of electrical cable separation. Other concerns include: unqualified switchboard wire used b,v plant maintenance personnel in environmentally qualifiti panels; rejectable indications on radiographs of welds n.sde on the containment liner and some vendor supplied tanks discrepant records of soils work; untraceable / unspecified materials used to fabricate vendor supplied fasteners or mechanical equipment; and deficient wiring / workmanship in vendor supplied electical panels. These findings were discussed at the exit meeting held at the site in June 1985.

These findings were documented in a report dated August 15, 1985. The Region III staff has reviewed actions taken by IP in response to those findings.

This action was completed in 1986.

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3.2 Open Inspection Items

A review of all open items has been completed and there are no open items which would preclude issuance of a low power

' license. However, there are a number open or unresolved inspection items which Region III has recommended to NRR for consideration as license conditions. These have been forwarded to NRR in a separate memo. Additional items that will remain open beyond fuel load are listed in Table 3.2.

3.3 Enforcement History Notices of Violations have been issued to Clinton, when appropriate, during the construction and preoperational testing of the facility. Table 3.1 summarizes the number of inspections and violations identified. A civil penalty in the amount of $90,000 was imposed on October 5, 1982.

The civil penalty was imposed for intimidation of quality control inspectors and numerous examples of violations of their QA program. Further information is contained in Section 3.1.1.

Two escalated enforcement actions are pending:

! An enforcement conference was held on August 15, 1986. The citation involved a finding by the Department of Labor that l

a Baldwin Associate employee was improperly fired after bringing quality concerns to his management. The enforcement package has been sent to headquarters for processing. IP has informed the NRC that the decision by the Department of Labor will be appealed.

An enforcement conference was held on August 29, 1986. This issue dealt with the finding by an NRC inspector that the i shutdown service water pump cubicles were not properly floodproofed. The improper floodproofing includes unsealed t

access hatches and construction openings that had not been closed up. An enforcement package is being prepared for transmittal to Headquarters.

Subsequent to the early 1982 findings by the NRC, the licensee l

has generally been responsive to NRC findings and has taken

, adequate corrective actions to preclude repetition.

3.4 Qualification of Licensee Personnel During detailed examination of the training plan, as delineated in Section 13.2 of the FSAR, several issues were raised regarding plant training..

One issue regarding the supervisory training being provided STAS was resolved by submittal of an amendment to the FSAR j

which clarifies the applicant's commitment to provide a

" forty contact hour" supervisory course to STAS.

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4 The second issue involved providing STAS with three months on-the-job training (0JT). This issue was resolved by submittal of an amendment to the FSAR which dele ~ted the applicant's exception to the INP0 STA Guideline for "in training." All STAS will complete three months on-the-job training.

The shift staffing levels of licensed and nonlicensed operators are adequate to support startup and power operations.

4 The minimum standard shift for plant operation is as follows:

1 Shift Supervisor, SR0

1 Assistant Shift Supervisor, SR0 2 Control Room Operators, R0 or SR0 2 Auxiliary Operators 1 Shift Technical Advisor

,, 1 Radiation Protection Technician 1 Radwaste Operator *

• Not required by technical specifications A minimum five shift crew rotation will be used.

The first Operator and Senior Operator license examinations were conducted in October 1985, with the following results:

18 SR0 Candidates - 14 passed 4 R0 Candidates - 3 passed The second Operator and Senior Operator license examinations were conducted in October 1985, with the following results:

14 SR0 Candidates - 13 passed 8 R0 Candid;tes - 6 passed The third Operator and Senior Operator license examinations were conducted in January 1986, with the following results:

12 SRO Candidates - 7 passed 4 R0 Candidates - 3 passed A fourth " retake" Operator and Senior Operator license examination was conducted in April 1986, with the following results:

8 SR0 Candidates - 5 passed 2 R0 Candidates - 2 passed 13

While experience is limited there currently are sufficient numbers of experienced Senior Reactor Operators to meet 4

• regulatory requirements and to support safe plant operation.

Four Shift Supervisors and six Assistant Shift Supervisors have completed the applicant's Supervisory Operating Plant Experience (S0PE) program or were previously licensed operators at large commercial BWRs (Cooper and Brunswick). The 50PE program provided at least six months of hot operating experience on a same type plant (LaSalle), including at least six weeks at i

power levels greater than 20% and startup/ shutdown experience.

At least one of the above experienucd licensed Senior Operators will be on each shift. This requirement is being imposed by a license condition for the first year from fuel load or until the attainment of a nominal 100% power level, whichever occurs 4

later.

3.5 Licensing and Design Issues There are no licensing or design issues identified except l

' those which are stipulated in proposed License No. NPF-55 for the Clinton plant.

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! 3.6 Regional Staff Concern Each Region III professional was requested by memoranda dated July 30, 1986, to identify concerns beyond those already addressed by either inspection reports or staff testimony.

No concerns are currently known which would preclude the issuance of a low power license for the Clinton Plant. Issues remaining to be completed after fuel load which neither preclude issuance of a low power license or are included as a license condition, are identified in Table 3.2.

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4. Quality Assurance During plant construction, a number of NRC inspections have been conducted to review the adequacy of the licensee's Quality Assurance (QA) Program. Following is a brief description of the evaluation of the QA Organization and the actions taken by the licensee to improve it's QA program:

4.1 Organization 1973 - 1977 The initial QA organization was set up reporting to the Project Manager with communication channels directly to the Corporate Vice President in charge of projects. During this period minor organizational changes occurred as the emphasis changed from Primary Design Engineering to initiation of Plant Construction. The Construction Permit for Clinton was issued in February 1976.

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1977 - 1982 During this period, the QA organization reported to the Manager of Generation Engineering. Corporate QA was located in Decatur, Illinois. Site QA was a small organization serving primarily as an audit function.

1982 - 1986 Due to problems identified by the NRC during January 1982, major changes were made in the Quality Assurance organization.

Quality Assurance was restructured to report to the Executive Vice President and then subsequently to the Vice President i in charge of quality assurance, engineering, startup and

operations.

i The Quality Assurance organization was changed to a more

functional mode including quality engineering, audits and i

l surveillance. Staff size was increased. Corporate Quality Assurance was moved to the Clinton site and assumed inline review responsibilities in site work activities. For further information refer to Section 3.1.

4.2 Audits Since inception of the Clinton Project, IP Quality Assurance has performed over 500 audits. In addition.

Baldwin Associates QA has conducted over 700 external audits and 350 internal audits.

There are no outstanding IP audit findings, which require NRC review prior to low power licensing.

4.3 Stop Work Since work at the Clinton site began, there have been 33 stop work actions initiated by IP or BA Quality Assurance.

Almost one third of these occurred during the 1982 construction shutdown described more fully in Section 3.1.

There have been no stop work actions ordered by the NRC.

Table 4.3 is a list showing a brief description of each stop work. There are no stop work actions in effect at the current time. All previous stop work actions have been j resolved satisfactorily.  ;

4.4 Independent Evaluations

' A number of evaluations have been conducted by parties internal to Illinois Power Company. The activities summarized below were in addition to NRC inspections of a routine or reactive nature and the IE Construction Appraisal Team Inspection.

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Joint Utility Management Audits (JUMA)

JUMA audits were performed each year starting in 1978 to the present.

> The JUMA is an independent audit conducted by members of other participating utilities of the IP Quality Assurance Program. During these audits approximately 70 findings were identified. All these are closed or scheduled to be closed. In the opinion of the 1985 JUMA team, the QA/QC program activities examined were adequate and effectively implemented except as noted in the finding and recommendations (three findings and nine recommendations). The severity of these findings were considered to be average for this type of audit.

Dennis Millican & Associates Inc.

During the time frame from January 25, 1984 to February 15, 1985

Dennis Millican (an Information Management Consultant) conducted a series of reviews regarding Records Management. These studies confirmed documentation problems such as improper changes and illegible forms. Based on these findings and findings by their own QA Department, IP undertook a number of corrective actions to improve the quality of documentation and records at the Clinton site. These corrective actions were reviewed by Region III inspectors and found to be acceptable.

INP0 Reports Construction - During November and December 1983, INPO conducted an evaluation of the Clinton construction project. The INP0 evaluation j team examined organization, design control, construction control, project support, training, and quality and test control.

A number of beneficial practices and areas where improveme'nt was needed were cited in the report. The INP0 document was reviewed by Region III inspectors. Corrective actions taken by the licensee to correct identified discrepancies were reviewed by the NRC and found to be acceptable.

Startup - An INP0 startup team reviewed IP performance in August 1982.

The team identified a number,of beneficial practices including:

• Training of personnel at other sites.

• Staff's involvement in checkout and maintenance

• Equipment layout and maintainability was good '

• Operating experience reviews were effective Some negative items identified included:

• Need for better chemistry facilities 16

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• Coordination betvean plant and construction staff needs improvement Two INP0 startup inspections were conducted in 1985. The INP0 l reports identified a number of good practices and a number of recommendations to improve certain areas. The most significant recommendations for improvement were to (1) prioritize planning and  :

scheduling of day to day activities, (2) provide a more effective use of the simulator to support operator training. These recommendations have resulted in corrective actions by the licensee, some of which are still in progress. These recommendations are consistent with NRC observations. Additional reviews by the NRC are scheduled to be completed prior to exceeding five percent power. This includes observation of day to day activities and reviews of simulator drills utilizing Emergency Operating Procedures.

4.5 Conclusions During the construction and preoperational phase, a. number of inspections and reviews by the NRC and others were conducted to review IP Quality Assurance functions, including the review of licensee stop works during 1982 and the Inspection and Enforcement (IE) CAT inspection conducted in 1985. During the NRC inspections the licensee's Quality Assurance activities were generally deemed to be adequate.

5. Hearings - Petition To Intervene Petitions to intervene were filed in 1980 by the Prairie Alliance and the State of Illinois Attorney General. An Atomic Safety and Licensing Board was established in 1981 and admitted 12 contentions including quality assurance. The number of contentions was ultimately reduced to three by negotiations; however, quality assurance issues remained to be settled. Quality assurance issues were the subject of extensive discussions and exchanges of information among the applicant, the State, and NRC. Illinois Power submitted a " Summary of Quality Improvements and Confirmatory Actions" (QICA) that summarized the major programmatic improvements, corrective actions and confirmatory activities which were initiated at Clinton following the identification of various deficiencies in construction activities in 1981. The QICA addressed the concerns raised by the contention on quality. The programs and plans for improvement included a records verification program, a Final Safety Analysis Report verification program; third party audits; special programs including seismic analyses for as-built safety related piping systems walkdown program, seismic interaction analysis program, electrical separation program, and fire protection program; a configuration program; a system turnover and start-up testing program; the overinspection program; and the independent design review. A meeting was held in December 1984 at Region III's office between NRC and representatives of the State of Illinois Attorney General (IAG). The purpose of meeting was to inform the IAG of NRC inspection activities and the methods used or contemplated to inspect 17

the previously described Illinois Power quality related plans and programs and to respond to IAG questions. Specific matters discussed were the overinspection program, the independent design review, the proposed NRC Construction Appraisal Team (CAT) inspection, and the Operations Quality Assurance Program.

Region III responded in writing to the Illinois Attorney General in January 1985 regarding the NRC actions planned or taken to verify the various programs discussed in Illinois Power's QICA.

Based on negotiations and the previously described programs, plans and meetings, a Joint Stipulation was signed in January 1985 between Illinois Power, the State of Illinois Attorney General, and the Nuclear Regulatory Commission. The Joint Stipulation allows the Illinois Attorney General to participate in matters relating to those quality related issues previously discussed. As a result, the remaining contentions have been withdrawn and Atomic Safety and Licensing Board proceeding terminated. To date, the Illinois Attorney General's office has attended meetings and actively participated in matters related to the independent design review, overinspection, and the CAT inspection.

6. Allegations Allegations concerning both safety-related and nonsafety-related areas at the Clinton site have been received and inspected by the Region III staff since 1981.

1981 and before 12 1982 12 1983 42 1984 49 1985 62 1986 to date 26 Total 203 Generally, the allegetions at Clinton have not resulted in any i significant hardware problems. A large number of the allegations relate to concerns of improper following administrative procedures.

One noted exception was identified involving hardware in which it was alleged that concrete expansion anchors were installed improperly.

NRC review substantiated the allegation. Further followup demonstrated that the problem of improper installation was limited to two crews. '

All of the anchors installed by those,two crews were examined and corrected as necessary.

During early 1986 an inspection of the safeteam program was conducted.

The safeteam concept provides a confidential way for current and terminated employees to raise concerns regarding the plant outside normal corrective action systems wit'outn fear of reprisal. The inspection revealed a number of weaknesses including; failure to address all employee identified concerns, investigative technique was not 18 l

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j appropriate, and investigation records did not adequately support the

! response to the concerns. The licensee, based on the NRC review and a 1 previous audit by a consultant, has made significant changes to their  :

i program. A detailed review of technical concerns during this inspection and a subsequent inspection in August did not reveal any significant discrepancies from a technical standpoint. Because the program is over and above regulatory requirements and because no technical problems were found, no further action is planned.

At the present time there are eighteen allegation files still open.

Most of these have been inspected and are currently being documer.ted.

The remainder have been reviewed and inspections conducted to date have not identified any safety issue which would preclude issuance of a low power license.

The allegations are:

AMS RIII-84-0010 Improper firing AMS RIII-84-0065 Improper firing AMS RIII-85-0113 Employment discrimination AMS RIII-86-0027 Maintenance procedures not followed AMS RIII-86-0034 Inadequate surveillance procedure AMS RIII-86-0081 Improper weld rod control AMS RIII-86-0088 Urine sampling program '

, AMS RIII-86-0109 Improper crane signals l AMS RIII-86-0111 Inadequate control of maintenance 4

AMS RIII-86-0114 Undersized welds d

AMS RIII-86-0122 Substance abuse AMS RIII-86-0126 Improper movats testing j AMS RIII-86-0135 Improper resume

AMS RIII-86-0142 Measuring equipment out of date A

i

7. 0.I. Investigations There are currently seven active OI investigations ongoing at the

Clinton site. The subject matter of these investigations cannot, at l this time, be publicly identified. Nonetheless, investigators from the OI:RIII office and the RIII technical staff have been working j

l closely to ensure that any technically significant issues identified 4

during the OI investigations are provided to the RIII staff for a technical evaluation. To date, none of the infcrmation developed by 01 should, from a technical viewpoint, affect fuel load. ,

8. Summary and Conclusions Inspections conducted by Region III have determined that the applicant

is generally responsive to NRC concerns and issues and that the applicant applies adequate management overview of the plant processes and personnel, i

1

! 19 I

, 1 i

During review and inspection of the Technical Specifications the NRC found a high degree of consistency between the plant Technical Specifications, Safety Evaluation Report (SER), Final Safety Analysis Report (FSAR), as-built configuration, surveillance requirements, and Preoperational Test Acceptance Criteria.

While there were some problems in initial implementation of system turnovers, inspection of the applicants preparation for Operational Readiness have shown that the licensee has a comprehensive and detailed checklist for those items required to be completed both prior to and following fuel load.

Overall, Region III has found the construction and testing programs at the Clinton site to be acceptable. In addition, the steps being taken by IP to complete actions necessary for fuel load are being taken with sufficient management overview and thoroughness.

We, therefore, conclude that Clinton has been constructed substantially in accordance with Construction Permit No. CPPR-137, the FSAR, and NRC regulation, and that Illinois Power Company is ready to load fuel and begin safe low power operation of the facility.

l l

20 l

i i

I CLINTON

) NRC Rlli INSPECTION STATISTICS i

l 1977 -

Violations inspections 1978 _

i 1979 -

1980 -

1981 -

1982 -

1983 -

1984 1985 - - -

i

! 1986 1

i O 10 20 30 40 50 60 70

\

! FIGURE 3.1 l

i CLINTON SITE i

NRC Rill INSPECTION STATISTICS NUMBER INSPECTION CITED HOURS PER HOURS PER YEAR INSPECTIONS HOURS VIOLATIONS INSPECTION VIOLATION 1977+ 19 329 15 17.3 21.9 1978 7 505 4 72.1 126.3 1979 12 555 5 46.3 111.O 1980 27 2054 20 112.3 102.7 1981 32 3592 24 112.3 149.6 1982 25 2372 8 94.8 296.5 1983 24 2615 9 109.0 290.5 1984 43 4066 9 94.6 406.6 1985 65 9724 17 149.6 572.0 1

1986** 44 4131 13 93.9 318.0 I

TOTALS 283 29877 119 105.6 251.1 i

1

. Includes pre-1977 inspections

. o* Includes inspection Rpts issued as of 9/12/86.

~

c/se/se. Tss. DRp TABLE 3.1 l

( TABLE 3.2 Items that will be open past fuel load.

461/79001-BB Environmental qualification of Class 1E equipment to be thru 3B(DRP) completed prior to startup from first refueling outage.

461/84001-04 Followup of portable waste solidification system for use (FRPS) in radwaste solidification; to be completed prior to

, exceeding 5% power.

461/85003-BB MOV common mode failure due to improper torque switch (0PS) setting; to be completed prior to exceeding 5% power.

RE: letter U-600529 of 5/15/86).

461/85005-01 Verify piping vibration, thermal expansion, and dynamic (DRP) effects testing performed during preop testing program (SER 1 & SSER paragraph 3.9.2); to be completed within six months of nuclear heatup.

461/85005-04 Verify modification of scram discharge system to meet (DRP) acceptance criteria (SER paragraph 4.6); to be completed prior to startup from first refueling outage.

461/84023-EE Ruskin fire dampers may not close. To be completed prior to (PSS/ FPS) completed prior to exceeding 5% power.

! 461/85005-05 Verify specified manual and automatic actuation of relief (TPS) valve during preop testing is in compliance with R.G. 1.68 (SER 5.2.2); to be completed prior to exceeding 5% power.

, 461/85005-20 Verify installation of heavy duty turbo charger drive gear l (TPS) assembly on all diesel generator motors (SER 9.6.3.1); to be 5

completed prior to startup from first refueling outage.

461/85005-28 Verify procedures and scheduled maintenance program to I (DRP) monitor leakage and reduce detected leakage are implemented (TMI item III.D.1) (SER 11.4.1); to be completed prior to l exceeding 5% power.

i l 461/85015-03 Verify implementation of the radwaste process control program

) (FRPS) (PCP) (SER 11.4.1); to be completed prior to exceeding 5%

j power.

1

461/85015-07 Confirm necessary revisions to EPG's made, E0P's upgraded, and (DRP) operators trained to be completed prior to exceeding 5% power.

l 461/85039-18 Confirm meterology data availability goals can be achieved; to i (EPS) be completed prior to exceeding 5% power.

! 23

461/85040-03 The classification of the general emergency was inappropriately i (EPS) delayed. This will be examined during the next exercise in j 1/87.

) 461/85040-05 Contamination control practices in the E0F environmental j

(EPS) laboratory were poor and will be observed again during the next exercise in 1/87.

461/85040-06 Information flow to the media via the JPIC was at times poor

, (EPS) and will be observed again during the next exercise in 1/87.

461/85050-01 Licensee to provide a water chemistry control training program; (RECS) to be completed prior to initial criticality.

l 461/85060-03 Repeat of CILRT type A test; to be completed prior to initial

(TPS) criticality.

461/86006-PP Type 410 ss valve stems and shafts have stress corrosion; to j (0PS) be completed prior to startup from first refueling outage, i

461/86005-EE Open penetrations in walls to be completed prior to exceeding

] (PSS/ FPS) 5% power.

461/86008-EE Adequacy of Ray Chem Splices to be completed prior to Nuclear .

(DRP) Heatup.

461/86011-01 Seven RCTS to complete qual cards; to be completed prior to l (RECS) exceeding 5% power.

I

461/86011-02 Licensee to fully implement QA/QC program of CPS 6001.01; to be

! (RECS) completed within six months of fuel load.

461/86017-07 Verify that separate Class 1E power supplies have been (DRP) provided for both fuel zone level channels; to be completed prior to startup from the first refueling outage (SSER 5, paragraph 7.5.1).

461/86021-02 Meteorological stability class determination EPIP have no (EPS) criteria to convert met. instr. data to stability class or hierarchy; to be completed before exceeding 5% power.

461/86024-01 Review contractor calibrations of normal range HVAC and SGTS i monitoring systems; to be completed before exceeding 5% power.

(FRPS) 461/86024-02 Review installation of shielding near the solid radwaste j (FRPS) solidification system; to be completed within 90 days of

! criticality.

i

461/86028-08 Emergency lighting surveillance procedure development; to be 4

(PSS-FPS) completed prior to exceeding 5% power.

4 4

24 i

1 461/86028-09 Fire protection administrative controls have not been fully (PSS-FPS) implemented; to be completed prior to exceeding 5% power.

461/86028-12 Information needed about oil collection system; to be (PSS/ FPS) completed prior to exceeding 5% power.

q 461/86028-13 Licensee to verify the maximum depth of frost to assure that j (PSS/ FPS) underground fire main does not freeze; to be completed prior to exceeding 5% power.

461/86036-02 Change access controls; to be completed within six months of j (SGS) receiving operating license.

461/86037-01 Review IP corrective actions concerning a nuclear material (FRPS) handling incident; to be completed within 90 days of loading

fuel.

461/86037-03 Questions concerning adequacy of ISI program; to be completed (OPS) prior to exceeding 5% power.

i 461/86041-01 NRR to provide acceptance of loss of offsite response to EDG; (TPS) to be completed prior to exceeding 5% power.

461/86048-04 CPS integrated plant operation procedures require additional (DRP) review to assure that Reg Guide 1.33 Appendix A, paragraph 2.C.c and g are adequately addressed; to be completed prior to exceeding 5% power.

461/86050-01 Review preop test results of the OG system; to be completed j (FRPS) prior to initial criticality.

! 461/86050-02 Review test results of solid radwaste system; to be completed (FRPS) within 3 months after commercial operation.

i 461/86050-03 Review test results of ATI radwaste system; to be completed (FRPS) prior to exceeding 5% power.

461/86050-04 Review actions taken as a result of recommendations made in (FRPS) liquid radwaste system; to be completed within 3 months after commercial operation.

461/86037-04C Verify method of tracking out of service annunciators to be (DRP) completed prior to exceeding 5% power _

1 461/86042-01 Periodic call drill to be completed by commercial operation.

461/86045-07 MOV internal wiring, rockbestors firewall III needs evaluation l (OPS) for EQ to be completed prior to 5% power.

461/86054-08 Equipment enhancement, hydrogen rule to be completed prior to (PSS) end first refueling outage.

I  :

25 i

461/86054-09 Annunciation for faulted NSPS division to be completed prior (PSS) to end of first refueling outage.

461/86054-10 Design modification to eliminate temporary wiring for shutdown (DRP) panel to be completed prior to end of first refueling outage.

461/86054-11 Changes to main control room annunciator displays to be (DRP) complete prior to exceeding 5% power.

461/86054-12 Wiring for 4 valves to SPDS to be completed prior to end (DRP) of first refueling outage.

461/86054-13 Spent fuel pool pump motor post LOCA qualifications to be (PSS) completed prior to startup from shutdown involving fuel off-loading.

461/86054-14 Preop test deferrals complete in accordance with exemptions (DRP) listed in Appendix N.

461/85039-23 Resolve paging problems to be completed by initial criticality.

461/85012-02 Independent review of annunciation response and surveillance procedures to be completed by mode required.

461/86048-03 Shutdown service water pump cubicles floodproofing. Hardware changes complete, awaiting licensee response.

461/86037-02 Surveillance procedure revision to be completed by initial criticality.

461/86054-04 Resolve tempora y modification to LPCS injection valve; completi m to be determined after licensee response received.

26

TABLE 4.3 STOP WORK ACTION AT CLINTON Date Description 4/76

• Placing of selected backfill stopped in the excavation of the main power block due to potential compaction problems.

8/77

• Placement of diagonal containment rebar was stopped due to bending of rebar in excess of specifications.

5/78

• Installation of imbeds stopped due to lack of control in traveler system.

12/79

• Fabrication / installation of HVAC hangers stopped due to use of unapproved procedures.

5/80

• Safety-related concrete placement was stopped due to loose shear ties.

9/80

• Welding non-safety attachment to saftey-related structures was stopped due to inadequate procedural controls to meet ASME and AWS requirements.

10/80

• Valve disassembly was stopped due to lack of approved travelers.

11/80

• Setting of control room consoles (PGCC) was stopped due to passing of QA holdpoint on traveler.

11/80

• Safety related work stopped due to inadequate number of quality control inspectors (short labor walkout).

2/81

• Installation of large bore pipe hangers stopped due to inadequate and untimely inspection and installation prior to approval of design calculations.

3/81

• HVAC work stopped due to lack of required travelers and drawings.

4/81

• Expansion anchors - concrete core drilling was stopped due to inadequate procedures and training.

6/81

• Preheat and post heat work stopped due to accidental welding of a ground lead to the reactor pressure vessel.

27

=

11/81

• HVAC related component support drawing releases were

stopped due to lack of reviewed and approved 3

calculations.

1/82

• Installation of electrical cable tray and tray attachments was stopped due to discrepancies identified by the NRC.

i 1/82

• Work on recirculation pump motor was stopped due to lack of approved traveler.

i 2/82

• Startup testing was stopped due to lack of adequate operational quality program.

2/82

• All welding was stopped due to weld rod identified as E-7028; found to be non - ferrous.

4 2/82

• Work on refueling bellows stopped due to lack of ,

1 adequate procedures for NDE and movement of bellows '

unit.

3/82

• Termination of instrument cables stopped due to problem of method of terminating in accordance with specifications.

3/82

• Procurement of spare parts stopped due to failure to ,

meet PSAR commitments.

1

. 3/82

• All core drilling stopped due to weak procedural l control.

3/82

• All fuel pool liner work stopped due to confusion on correct code requirements.

6/82

• All safety-related HVAC worked stopped due to program concerns identified during sampling verifications.

6/82

• All conduit installation stopped due to inspection falling behind production.

6/82

• All electrical equipment installation stopped due to inadequate traveler and inspection program.

6/82

• All instrumentation stopped due to problems ,

identified in audit. '

6/82

• All containment structural steel installation stopped due to problems found during verification review.

8/82

• All non safety HVAC work in Catagory 1 structures

{

stopped due to interface control problems.

! 10/82

• Containment gas control boundary testing was stopped j due to inadequate procedures.

i i 28 l

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