IR 05000461/2009002

IR 05000461-09-002, 01/01/09 - 03/31/09, Clinton Power Station, Integrated Inspection Report

ML091130101
Person / Time
Site:	Clinton
Issue date:	04/22/2009
From:	Ring M NRC/RGN-III/DRP/B1
To:	Pardee C Exelon Generation Co
References
IR-09-002
Download: ML091130101 (31)

Text

ril 22, 2009

SUBJECT:

CLINTON POWER STATION NRC INTEGRATED INSPECTION REPORT 05000461/2009-002

Dear Mr. Pardee:

On March 31, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Clinton Power Station. The enclosed report documents the inspection results, which were discussed on April 9, 2009, with Mr. F. Kearney and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mark A. Ring, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62 DISTRIBUTION:

See next page

Letter to from M. Ring dated April 22, 2009 SUBJECT: CLINTON POWER STATION NRC INTEGRATED INSPECTION REPORT 05000461/2009-002 cc w/encl: Site Vice President - Clinton Power Station Plant Manager - Clinton Power Station Manager Regulatory Assurance - Clinton Power Station Senior Vice President - Midwest Operations Senior Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director - Licensing and Regulatory Affairs Manager Licensing - Clinton, Dresden and Quad Cities Associate General Counsel Document Control Desk - Licensing Assistant Attorney General J. Klinger, State Liaison Officer,

SUBJECT:

CLINTON POWER STATION NRC INTEGRATED INSPECTION REPORT 05000461/2009-002

Dear Mr. Pardee:

On March 31, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Clinton Power Station. The enclosed report documents the inspection results, which were discussed on April 9, 2009, with Mr. F. Kearney and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mark A. Ring, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62 DISTRIBUTION:

See next page DOCUMENT NAME: G:\CLIN\CLIN 2009-02.doc Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE Clinton E RIII RIO NAME BKemker MRing

• MAR for DATE 04/22/09 04/22/09 OFFICIAL RECORD COPY

Letter to from M. Ring dated April 22, 2009 SUBJECT: CLINTON POWER STATION NRC INTEGRATED INSPECTION REPORT 05000461/2009-002 DISTRIBUTION:

Tamara Bloomer RidsNrrDorlLpl3-2 Resource RidsNrrPMClinton Resource RidsNrrDirsIrib Resource Patrick Hiland Kenneth OBrien Jared Heck Allan Barker Carole Ariano Linda Linn Cynthia Pederson (hard copy - IRs only)

DRSIII DRPIII Patricia Buckley Tammy Tomczak ROPreports Resource

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-461 License No: NPF-62 Report No: 05000461/2009-002 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station Location: Clinton, IL Dates: January 1 through March 31, 2009 Inspectors: B. Kemker, Senior Resident Inspector D. Lords, Resident Inspector J. Benjamin, Senior Project Engineer J. Draper, Reactor Engineer D. Jones, Reactor Engineer M. Mitchell, Health Physicist R. Winter, Reactor Engineer S. Mischke, Resident Inspector, Illinois Emergency Management Agency Approved by: M. Ring, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000461/2009-002, 01/01/09 - 03/31/09, Clinton Power Station, Integrated Inspection

Report.

This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings No violations of significance were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

Summary of Plant Status

The unit was operated at or near full power during the inspection period with the following exception:

On February 28, 2009, the licensee reduced power to about 66 percent to perform control rod pattern adjustment, control rod settle testing, scram time testing, and main turbine control/intermediate valve and main steam isolation valve testing. The unit was returned to full power later the same day upon completion of testing.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Extended Freezing Period Walkdown

a. Inspection Scope

During post-winterization walkdowns conducted on February 15, 2009, the inspectors toured plant areas to monitor the physical condition of cold weather protection features following a period of extended freezing temperatures. The inspectors observed insulation, heat trace circuits, space heater operation, and weatherized enclosures to ensure operability of affected systems.

This inspection constituted one site imminent adverse weather inspection sample as defined by Inspection Procedure 71111.01.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk significant systems:

• Division 2 Standby Gas Treatment Train during maintenance on Division 1 Standby Gas Treatment Train;

• High Pressure Core Spray (HPCS) System (single train risk significant system);and

• Residual Heat Removal (RHR) System Train A during maintenance on RHR System Train B.

The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones. The inspectors reviewed operating procedures, system diagrams, Technical Specification (TS) requirements, and the impact of ongoing work activities on redundant trains of equipment. The inspectors verified that conditions did not exist that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components were aligned correctly and available as necessary.

In addition, the inspectors verified that equipment alignment problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted three partial system walkdown inspection samples as defined by Inspection Procedure 71111.04.

b. Findings

No findings of significance were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete system alignment inspection of the component cooling water system to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment lineups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding work orders was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment alignment problems were being identified and appropriately resolved.

This inspection constituted one complete system walkdown inspection sample as defined by Inspection Procedure 71111.04.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors performed fire protection tours in the following plant areas:

• Fire Zone CB 1-f, General Access Area - El. 762'0",

• Fire Zone CB 1-g, Unit 2 Cable Spreading Rooms - El. 781'0";

• Fire Zone A2-m, Containment Electrical Penetration (East) Area - El. 762'0";

• Fire Zone A3-e, Containment Electrical Penetration (West) Area - El. 762'0";

• Fire Zone A-4, Division 1 Battery Room - El. 781'0"; and

• Fire Zone A-5, Division 2 Battery Room - El. 781'0".

The inspectors verified that transient combustibles and ignition sources were appropriately controlled and assessed the material condition of fire suppression systems, manual fire fighting equipment, smoke detection systems, fire barriers and emergency lighting units. The inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; that the licensees fire plan was in alignment with actual conditions; and that fire doors, dampers, and penetration seals appeared to be in satisfactory condition.

In addition, the inspectors verified that fire protection related problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted six quarterly fire protection inspection samples as defined by Inspection Procedure 71111.05AQ.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

The inspectors observed licensed operators during simulator training on February 4, 2009. The inspectors assessed the operators response to the simulated events focusing on alarm response, command and control of crew activities, communication practices, procedural adherence, and implementation of Emergency Plan requirements.

The inspectors also observed the post-training critique to assess the ability of licensee evaluators and operating crews to self-identify performance deficiencies. The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements.

This inspection constituted one quarterly licensed operator requalification inspection sample as defined by Inspection Procedure 71111.11.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated the licensee's handling of selected degraded performance issues involving the following risk significant structures, systems, and components (SSCs):

• Reactor Recirculation System; and

• Emergency Diesel Generators.

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the SSCs. Specifically, the inspectors independently verified the licensee's handling of SSC performance or condition problems in terms of:

• appropriate work practices;

• identifying and addressing common cause failures;

• scoping of SSCs in accordance with 10 CFR 50.65(b);

• characterizing SSC reliability issues;

• tracking SSC unavailability;

• trending key parameters (condition monitoring);

• 10 CFR 50.65(a)(1) or (a)(2) classification and reclassification; and

• appropriateness of performance criteria for SSC functions classified (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSC functions classified (a)(1).

In addition, the inspectors verified that problems associated with the effectiveness of plant maintenance were entered into the licensee's corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted two maintenance effectiveness inspection samples as defined by Inspection Procedure 71111.12.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for maintenance and emergent work activities affecting risk significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• Planned maintenance during the week of January 20th on the HPCS System (risk significant single train system);

• Planned maintenance during the week of February 2nd on the 4160 Volt Bus 1 Reserve Feed and 6900 Volt Bus 1A Reserve Feed Breakers, and Standby Liquid Control Pump A;

• Planned maintenance during the week of February 9th on the Division 2 Diesel Generator and Division 2 Standby Gas Treatment System;

• Planned maintenance during the week of March 2nd on the Division 1 Hydrogen Recombiner and Division 1 Standby Gas Treatment System;

• Planned maintenance during the week of March 16th on RHR Heat Exchanger B and Division 2 Shutdown Service Water System; and

• Emergent maintenance following the Emergency Reserve Auxiliary Transformer Static VAR [Volt-Ampere Reactive] Compensator Trip on February 21st.

These activities were selected based on their potential risk significance relative to the reactor safety cornerstones. As applicable for each of the above activities, the inspectors reviewed the scope of maintenance work in the plants daily schedule, reviewed Control Room logs, verified that plant risk assessments were completed as required by 10 CFR 50.65(a)(4) prior to commencing maintenance activities, discussed the results of the assessment with the licensees Probabilistic Risk Analyst and/or Shift Technical Advisor, and verified that plant conditions were consistent with the risk assessment assumptions. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify that risk analysis assumptions were valid, that redundant safety-related plant equipment necessary to minimize risk was available for use, and that applicable requirements were met.

In addition, the inspectors verified that maintenance risk-related problems were entered into the licensees corrective action program with the appropriate significance characterization. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted six maintenance risk assessment inspection samples as defined by Inspection Procedure 71111.13.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• AR 00821106, "1SX014C Did Not Fully Close Via Main Control Room Handswitch;"

• AR 00803617, "Switchyard South Bus Voltage Exceeds High Limit;"

• AR 00814191, "Six

(6) Bolt Assemblies Are Missing From Penetration 1EE44E;"

• AR 00864500, Auxiliary Building Steam Tunnel Temperature Shows a Step Change and Increasing Trend;

• AR 00890462, "Nuclear Oversight Identified Key Probabilistic Risk Assessment Operator Actions Not Directly Supported by Procedures;" and

• AR 00872963, 0VC022A Open Stroke Time Outside Acceptance Criteria.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors verified that the conditions did not render the associated equipment inoperable or result in an unrecognized increase in plant risk. When applicable, the inspectors verified that the licensee appropriately applied TS limitations, appropriately returned the affected equipment to an operable status, and reviewed the licensees evaluation of the issues with respect to the regulatory reporting requirements. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

In addition, the inspectors verified that problems related to the operability of safety-related plant equipment were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted six operability evaluation inspection samples as defined by Inspection Procedure 71111.15.

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

.1 Temporary Modifications

a. Inspection Scope

The inspectors reviewed the following temporary plant modifications:

• EC 372721, Install Shim on Side of Valve Limit Switch Actuator to Provide Additional Travel for Limit Switch #5 on 1B21F028A; and

• EC 369695, Remove Nuisance Alarm Input to Annunciator Window 5012-6B.

The first temporary modification added magnet shims to a main steam system valve actuator to address past issues with limit switch #5 re-setting. The second temporary modification removed a nuisance alarm input to a main control room annunciator, while maintaining use of the remaining alarm inputs to the annunciator.

The inspectors reviewed the temporary modifications and the associated 10 CFR 50.59 screening/evaluations against applicable system design basis documents, including the Updated Final Safety Analysis Report (UFSAR) and the TS to verify whether applicable design basis requirements were satisfied. The inspectors reviewed the operator logs and interviewed engineering and operations department personnel to understand the impact that implementation of the temporary modifications had on operability and availability of the affected plant SSCs. The inspectors reviewed post modification testing performed and existing corrective action assignments necessary to remove the temporary modifications and restore the affected SSCs to an approved permanent design configuration.

The inspectors also reviewed a sample of action requests pertaining to temporary modifications to verify that problems were entered into the licensee's corrective action program with the appropriate significance characterization and that corrective actions were appropriate.

This inspection constituted two temporary modification inspection samples as defined by Inspection Procedure 71111.18.

b. Findings

No findings of significance were identified.

.2 Permanent Modifications

a. Inspection Scope

The inspectors reviewed the engineering analyses, modification documents, and design change information associated with the following permanent plant modification:

• EC 349235, "Replace Division 1 Diesel Generator Governor Actuators."

During this inspection, the inspectors evaluated the implementation of the design modification and verified, as appropriate, that:

• the compatibility, functional properties, environmental qualification, seismic qualification, and classification of materials and replacement components were acceptable;

• the structural integrity of the SSCs would be acceptable for accident/event conditions;

• the implementation of the modification did not impair key safety functions;

• no unintended system interactions occurred;

• the affected significant plant procedures, such as normal, abnormal, and emergency operating procedures, testing and surveillance procedures, and training were identified and necessary changes were completed;

• the design and licensing documents were either updated or were in the process of being updated to reflect the modification;

• the changes to the facility and procedures, as described in the UFSAR, were appropriately reviewed and documented in accordance with 10 CFR 50.59;

• the system performance characteristics, including energy needs affected by the modification continued to meet the design basis;

• the modification test acceptance criteria were met; and

• the modification design assumptions were appropriate.

Completed activities associated with the implementation of the modification, including testing, were also inspected, and the inspectors discussed the modification with the responsible engineering and operations staff.

This inspection constituted one permanent modification inspection sample as defined by Inspection Procedure 71111.18.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed post-maintenance testing for the following activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• Planned maintenance to replace Division 1 And Division 2 Rod Control Information System Power Supplies;

• Planned maintenance on Control Room Ventilation Makeup Train 'A' Downstream Air Flow Controller 0FICVC072;

• Planned maintenance on Drywell Cooling Ventilation Train B Side Stream Filter Skid 1FI-VP350B;

• Planned maintenance on Division 1 Standby Gas Treatment System Valves and Room Cooler;

• Planned maintenance to replace Hydraulic Control Units for Control Rods 12-17 and 36-25;

• Planned maintenance on the Division 3 Essential Switchgear Cooling System Chiller; and

• Planned maintenance to replace a circuit card for the Swing Battery Charger 1DC11E Feed to DC Bus.

The inspectors reviewed the scope of the work performed and evaluated the adequacy of the specified post-maintenance testing. The inspectors verified that the post-maintenance testing was performed in accordance with approved procedures; that the procedures contained clear acceptance criteria, which demonstrated operational readiness and that the acceptance criteria was met; that appropriate test instrumentation was used; that the equipment was returned to its operational status following testing, and that the test documentation was properly evaluated.

In addition, the inspectors reviewed corrective action program documents associated with post-maintenance testing to verify that identified problems were entered into the licensee's corrective action program with the appropriate characterization. Selected action requests were reviewed to verify that the corrective actions were appropriate and implemented as scheduled.

This inspection constituted seven post-maintenance testing inspection samples as defined by Inspection Procedure 71111.19.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following surveillance testing activities to determine whether risk significant systems and equipment were capable of performing their intended safety function and to verify that the testing was conducted in accordance with applicable procedural and TS requirements:

• CPS 9051.01, HPCS Pump & HPCS Water Leg Pump Operability, (Inservice Test);

• CPS 9052.01, "LPCS [Low Pressure Core Spray] /RHR A & LPCS/RHR A Water Leg Pump Operability," (Inservice Test);

• CPS 9831.01, "LPRM [Local Power Range Monitor] Calibration;"

• CPS 9069.02, Shutdown Service Water Valve Operability Test, (Inservice Test);

• CPS 9080.01, "Diesel Generator 1A Operability - Manual and Quick Start Operability;"

• CPS 9813.01, "Control Rod Scram Time Testing;" and

• CPS 9031.06, Main Turbine Stop Valve and CIV [Combined Intermediate Valve]

Tests.

The inspectors observed selected portions of the test activities to verify that the testing was accomplished in accordance with plant procedures. The inspectors reviewed the test methodology and documentation to verify that equipment performance was consistent with safety analysis and design basis assumptions, and that testing acceptance criteria were satisfied.

In addition, the inspectors verified that surveillance testing problems were entered into the licensees corrective action program with the appropriate characterization and significance. Selected action requests were reviewed to verify that corrective actions were appropriate and implemented as scheduled.

This inspection constituted three in-service tests and four routine surveillance tests for a total of seven inspection samples as defined by Inspection Procedure 71111.22.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a full scale emergency preparedness drill on February 25, 2009, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. This drill was planned to be evaluated and was included in performance indicator data regarding drill and exercise performance. The inspectors observed emergency response operations in the Operations Simulator, Operations Support Center, and Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensees drill critique to compare any inspector-observed weaknesses with those identified by the licensees staff in order to evaluate the critique and to verify whether the licensees staff was properly identifying weaknesses and entering them into the corrective action program.

This inspection constituted one emergency preparedness drill inspection sample as defined by Inspection Procedure 71114.06.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Public Radiation Safety

2PS2 Radioactive Material Processing and Transportation (71122.02)

.1 Radioactive Waste System

a. Inspection Scope

The inspectors reviewed the liquid and solid radioactive waste system description in the UFSAR for information on the types and amounts of radioactive waste (radwaste)generated and disposed. The inspectors reviewed the scope of the licensees audit program with regard to radioactive material processing and transportation programs to verify that it met the requirements of 10 CFR 20.1101(c).

This inspection constituted one sample as defined in IP 71122.02-5.

b. Findings

No findings of significance were identified.

.2 Radioactive Waste System Walkdowns

a. Inspection Scope

The inspectors performed walkdowns of the liquid and solid radwaste processing systems to verify that the systems agreed with the descriptions in the UFSAR and the Process Control Program and to assess the material condition and operability of the systems. The inspectors reviewed the status of radwaste processing equipment that was not operational and/or was abandoned in place. The inspectors reviewed the licensees administrative and physical controls to ensure that the equipment would not contribute to an unmonitored release path or be a source of unnecessary personnel exposure.

The inspectors reviewed changes to the waste processing system to verify that the changes were reviewed and documented in accordance with 10 CFR 50.59 and to assess the impact of the changes on radiation dose to members of the public. The inspectors reviewed the current processes for transferring waste resin into shipping containers to determine if appropriate waste stream mixing and/or sampling procedures were utilized. The inspectors also reviewed the licensees methods for waste concentration averaging to determine if representative samples of the waste product were provided for the purposes of waste classification, as required by 10 CFR 61.55.

This inspection constituted one sample as defined in IP 71122.02-5.

b. Findings

No findings of significance were identified.

.3 Waste Characterization and Classification

a. Inspection Scope

The inspectors reviewed the licensees radiochemical sample analysis results for each of the licensees waste streams, including dry active waste, spent resins, and filters. The inspectors also reviewed the licensees use of scaling factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting radionuclides). The reviews were conducted to verify that the licensees program assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G of 10 CFR Part 20. The inspectors also reviewed the licensees waste characterization and classification program to ensure that the waste stream composition data accounted for changing operational parameters and thus remained valid between the annual sample analysis updates.

This inspection constituted one sample as defined in IP 71122.02-5.

b. Findings

No findings of significance were identified.

.4 Shipment Preparation and Shipment Manifests

a. Inspection Scope

The inspectors reviewed the documentation of shipment packaging, radiation surveys, package labeling and marking, vehicle inspections and placarding, emergency instructions, determination of waste classification/isotopic identification, and licensee verification of shipment readiness for five material and radwaste shipments made in 2007 to 2009. The shipment documentation reviewed consisted of:

• One Limited Quantity Shipment to a Contractor; and

• Three LSA-II and One Type-B(U) Packages to Barnwell.

For each shipment, the inspectors determined if the requirements of 10 CFR Parts 20 and 61 and those of the Department of Transportation (DOT) in 49 CFR Parts 170-189 were met. Specifically, records were reviewed and staff involved in shipment activities was interviewed to determine if packages were labeled and marked properly, if package and transport vehicle surveys were performed with appropriate instrumentation, if radiation survey results satisfied DOT requirements, and if the quantity and type of radionuclides in each shipment were determined accurately. The inspectors also determined whether shipment manifests were completed in accordance with DOT and NRC requirements, if they included the required emergency response information, if the recipient was authorized to receive the shipment, and if shipments were tracked as required by 10 CFR 20, Appendix G.

This inspection constitutes one sample as defined by Inspection Procedure 71122.02-5.

Selected staff involved in shipment activities were observed by the inspectors to determine if they had adequate skills to accomplish shipment related tasks and to determine if the shippers were knowledgeable of the applicable regulations to satisfy package preparation requirements for public transport with respect to NRC Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial, and 49 CFR Part 172, Subpart H.

This inspection constitutes one sample as defined by Inspection Procedure 71122.02-5.

b. Findings

No findings of significance were identified.

.5 Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed condition reports, audits and self assessments that addressed radioactive waste and radioactive materials shipping program deficiencies since the last inspection to verify that the licensee had effectively implemented the corrective action program and that problems were identified, characterized, prioritized and corrected. The inspectors also verified that the licensee's self-assessment program was capable of identifying repetitive deficiencies or significant individual deficiencies in problem identification and resolution.

The inspectors reviewed corrective action reports from the radioactive material and shipping programs since the previous inspection, interviewed staff and reviewed documents to determine if the following activities were being conducted in an effective and timely manner commensurate with their importance to safety and risk:

• Initial problem identification, characterization, and tracking;

• Disposition of operability/reportability issues;

• Evaluation of safety significance/risk and priority for resolution;

• Identification of repetitive problems;

• Identification of contributing causes;

• Identification and implementation of effective corrective actions;

• Resolution of Non-Cited Violations tracked in the corrective action system; and

• Implementation/consideration of risk significant operational experience feedback.

This inspection constituted one sample as defined in IP 71122.02-5.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

.1 Review of Submitted Quarterly Data

a. Inspection Scope

The inspectors performed a review of the data submitted by the licensee for the Fourth Quarter 2008 Performance Indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter (IMC) 0608, "Performance Indicator Program."

This inspection was not considered to be an inspection sample as defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.2 Unplanned Scrams per 7000 Critical Hours

a. Inspection Scope

The inspectors verified the Unplanned Scrams per 7000 Critical Hours Performance Indicator for Unit 1. The inspectors reviewed each Licensee Event Report (LER) from January 1, 2008, through December 31, 2008, determined the number of scrams that occurred, and verified the licensee's calculation of critical hours. The inspectors also reviewed the licensee's corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

This inspection constituted one performance indicator verification inspection sample as defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.3 Unplanned Scrams with Complications

a. Inspection Scope

The inspectors verified the Unplanned Scrams with Complications Performance Indicator for Unit 1. The inspectors reviewed each LER from January 1, 2008, through December 31, 2008, determined the number of scrams that occurred, and evaluated each of the scrams against the performance indicator definition. The inspectors also reviewed the licensee's corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

This inspection constituted one performance indicator verification inspection sample as defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.4 Unplanned Transients per 7000 Critical Hours

a. Inspection Scope

The inspectors verified the Unplanned Transients per 7000 Critical Hours Performance Indicator for Unit 1. The inspectors reviewed power history data from January 1, 2008, through December 31, 2008, determined the number of power changes greater than 20 percent full power that occurred, evaluated each of the power changes against the performance indicator definition, and verified the licensee's calculation of critical hours.

The inspectors also reviewed the licensee's corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator. One minor reporting error was previously identified by the inspectors.

This inspection constituted one performance indicator verification inspection sample as defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.5 Safety System Functional Failures

a. Inspection Scope

The inspectors verified the Safety System Functional Failures Performance Indicator for Unit 1. The inspectors reviewed each LER from January 1, 2008, through December 31, 2008, determined the number of safety system functional failures that occurred, evaluated each LER against the performance indicator definition, and verified the number of safety system functional failures reported. The inspectors also reviewed the licensee's corrective action program database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

This inspection constituted one performance indicator verification inspection sample as defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Some minor issues were entered into the licensees corrective action program as a result of the inspectors observations; however, they are not discussed in this report.

This inspection was not considered to be an inspection sample as defined by Inspection Procedure 71152.

b. Findings

No findings of significance were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Closed) LER 05000461/2007-002-00, Improper Installation of Stanchions in

Containment Pool Swell Zone The licensee failed to adequately secure four radiation protection (RP) stanchions to the deck grating at the 755' elevation in the containment building, which could have affected the function of safety-related equipment following a design basis accident. Contrary to procedure CPS 1019.05, Transient Equipment/Materials, Step 8.5.3, the four stanchions were secured to the deck grating with plastic tie-wraps instead of metal grating clips. The licensee performed evaluation EC 365177, Review of Design Basis of RP Stanchions in Containment, and concluded that the tie-wraps would not be able to withstand the force of suppression pool swell. The licensee identified two containment isolation valves (1FC007, Spent Fuel Pool Cooling and Cleanup Containment Outlet Inboard Isolation Valve and 1FP053, Fire Protection Containment Inboard Isolation Valve) that could have been affected by a stanchion missile hazard.

The licensees evaluation conservatively assumed that the missiles created could impinge on the two containment isolation valves and prevent their containment isolation function. It was also determined that during a loss of offsite power/loss of coolant accident, containment isolation could only be assured if the Division 1 diesel generator was operable during the time the stanchions were in place. The licensee reported this event as a condition that could have prevented fulfillment of the containment isolation system safety function in accordance with 10 CFR 50.73(a)(2)(v)(D). The performance issue related to this event was discussed in NRC Inspection Report 05000461/2007007.

The NRC issued a Non-Cited Violation associated with a Green inspection finding for the licensees failure to assure that activities affecting quality were accomplished in accordance with prescribed documented instructions, procedures, or drawings. The inspectors determined that the information provided in LER 05000461/2007-002-00 did not raise any new issues or change the conclusions of the previous review.

LER 05000461/2007-002-00 is closed.

This inspection constituted one event follow-up inspection sample as defined by Inspection Procedure 71153.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted the following observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.

• Multiple tours of operations within the security alarm stations;

• Tours of selected security officer response posts;

• Direct observation of personnel entry screening operations within the plants Main Access Facility; and

• Security force shift turnover activities.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

.2 Review of Institute of Nuclear Power Operations (INPO) Assessment Report

The inspectors completed a review of the preliminary INPO evaluation for the Clinton Power Station assessment conducted in October/November 2008. During this review, the inspectors did not identify any new safety significant issues.

4OA6 Management Meetings

.1 Resident Inspectors Exit Meeting

The inspectors presented the inspection results to Mr. F. Kearney and other members of the licensees staff at the conclusion of the inspection on April 9, 2009. The licensee acknowledged the findings presented. Proprietary information was examined during this inspection, but is not specifically discussed in this report.

.2 Interim Exit Meetings

Interim exit meetings were conducted for:

• Radioactive Material Processing and Transportation Inspection with Mr. F. Kearney and other members of the licensees staff on January 9, 2009. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Chickering, Corrective Action Program Administrator

T. Conner, Operations Director

A. Darelius, Emergency Planning Manager

J. Domitrovich, Maintenance Director

J. Ellis, Work Management Director

R. Frantz, Regulatory Assurance

M. Otten, Operations Training Manager

M. Kanavos, Plant Manager

F. Kearney, Site Vice President

J. Peterson, Regulatory Assurance

M. Reandeau, Shift Operations Superintendent

J. Stovall, Radiation Protection Manager

J. Ufert, Fire Marshall

C. VanDenburgh, Nuclear Oversight Manager

M. Vandermyde, Reactor Engineering Supervisor

R. Weber, Engineering Director

C. Williamson, Security Manager

LIST OF ITEMS

Opened

None

Closed

05000461/2007-002-00 LER Improper Installation of Stanchions in Containment Pool Swell Zone (Section 4OA3.1)

Discussed

None Attachment