IR 05000461/2003005

IR 05000461-03-005; 07/01/2003-09/30/2003; Clinton Power Station; Operability Evaluations and Licensed Operator Requalification

ML033040105
Person / Time
Site:	Clinton
Issue date:	10/30/2003
From:	Ann Marie Stone NRC/RGN-III/DRP/RPB3
To:	Skolds J Exelon Generation Co, Exelon Nuclear
References
IR-03-005
Download: ML033040105 (34)

Text

ber 30, 2003

SUBJECT:

CLINTON POWER STATION NRC INTEGRATED INSPECTION REPORT 05000461/2003005

Dear Mr. Skolds:

On September 30, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Clinton Power Station. The enclosed reports documents the inspection findings which were discussed on October 9, 2003, with Mr. K. Polson and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and to 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.

This report documents one finding and associated violation of NRC requirements whose significance is to be determined. The finding relates to your staff's failure to properly evaluate a potential configuration change on a number of safety-related motor-operated valves. We have determined that this finding is greater than minor; however, the significance determination will be completed once we resolve past operability and the extent of condition concerns. This finding did not present an immediate safety concern and corrective actions including additional inspections by your staff have been implemented.

In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief Branch 3 Division of Reactor Projects Docket No. 50-461 License No. NPF-62

Enclosure:

Inspection Report No. 05000461/2003005 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-461 License No: NPF-62 Report No: 05000461/2003005 Licensee: AmerGen Energy Company, LLC Facility: Clinton Power Station Location: Route 54 West Clinton, IL 61727 Dates: July 1 through September 30, 2003 Inspectors: B. Dickson, Senior Resident Inspector C. Brown, Resident Inspector T. Tongue, Project Engineer D. Smith, Dresden Senior Resident Inspector D. McNeil, Senior Operations Engineer R. Walton, Operations Engineer D. Eskins, LaSalle Resident Inspector D. Zemel, Illinois Emergency Management Agency Observers: J. Bond, NRC Intern D. Tharp, Reactor Engineer Approved by: Ann Marie Stone, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000461/2003005; 07/01/2003 -09/30/2003;Clinton Power Station. Operability Evaluations and Licensed Operator Requalification.

This report covers a 3-month period of baseline resident inspection and announced baseline inspections on licensed operation requalification. The inspection was conducted by Region III inspectors and the resident inspectors. One Unresolved Item (URI) with potential safety significance greater than minor and one minor examination security violation were identified.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the sate operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A. Inspector-Identified and Self Revealing Findings

Cornerstone: Mitigation Systems

TBD The inspectors identified a violation having safety significance greater than minor.

This finding resulted from the licensees failure to evaluate a potential configuration change in accordance with the licensees established configuration control process following the installation of modified mounting bolts in Limitorque SMB-2 actuators.

The installed mounting bolts achieved less thread engagement than required by design documentation.

This finding is considered an unresolved item (URI) pending a review of licensees evaluation of these issues and completion of significance determination. The inspectors considered this issue greater than minor because the finding was associated with the Mitigating System crosscutting attribute of Equipment Performance and affected the Mitigating System objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding was determined to have a potential safety significance greater than minor because the affected valve operators were used in both Division I and Division II low pressure emergency core cooling systems. (Section 1R15)

Licensee-Identified Violations

No findings of significance were identified.

REPORT DETAILS

Summary of Plant Status

At the beginning of the inspection period, the plant operated at approximately 93.6 percent of rated thermal power (maintaining about 102 percent of rated electrical output). On September 7, 2003, operators reduced reactor power to approximately 60 percent to perform a control rod pattern adjustment, control rod drive scram time testing and fuel channel bow surveillance testing. On September 8, 2003, operators increased reactor power to 91 percent power (100 percent of rated electrical output). The plant remained at that power level through the end of the inspection period.

1R01 Adverse Weather

a. Inspection Scope

The inspectors verified that the licensee had completed preparations for adverse weather in a timely manner before the weather actually presented a challenge. The inspectors reviewed the risk-significant equipment and ensured that the equipment was in a condition to meet the requirements of Technical Specifications (TSs), the Operational Requirements Manual (ORM), and the Updated Safety Analysis Report (USAR) with respect to protection from adverse weather. The inspectors verified that minor issues identified during the inspection were entered into the licensees corrective action system by reviewing the associated condition reports (CRs).

On July 8,2003, the inspectors completed one sample by verifying preparations for adverse weather and walking down selected plant areas based on their importance for availability of mitigating systems, before predicted severe thunderstorms and high winds. These areas included the Emergency Reserve Auxilary Transformer (ERAT),the ERAT-Static VAR compensator, a construction site adjacent to the main power transformers, and the screen house.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments

.1 Partial Walkdowns

a. Inspection Scope

The inspectors performed five partial walkdowns of accessible portions of divisions of risk-significant mitigating systems equipment during times when the divisions were of increased importance due to the redundant divisions or other related equipment being unavailable. The inspectors utilized the valve and electric breaker checklists listed in the Attachment to verify that the components were properly positioned and that support systems were lined up as needed. The inspectors also examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors reviewed outstanding work orders and condition reports (CRs) associated with the divisions to verify that those documents did not reveal issues that could affect division function. The inspectors used the information in the appropriate sections of the Updated Safety Analysis Report (USAR) to determine the functional requirements of the systems.

The following five systems were inspected:

• Control room heating ventilation and air conditioning system A during maintenance on B system;

• Standby liquid control system;

• Division 1 residual heat removal (RHR) system during work on Division 2 RHR;

• 125-Vdc distribution system during work in the 345 Kv switchyard; and

• Reactor core isolation cooling (RCIC) system.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05Q and 05A)

.1 Quarterly Fire Zone Walkdowns

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of fire fighting equipment, the control of transient combustibles and ignition sources, and on the condition and operating status of installed fire barriers. The inspectors selected fire areas for inspection based on their overall contribution to internal fire risk, as documented in the Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate a plant transient, or their impact on the plants ability to respond to a security event. The inspectors used the documents listed in the to verify 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; and that fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors verified that minor issues identified during the inspection were entered into the licensees corrective action program.

The following nine areas were inspected by walkdowns:

• Turbine building, 762-foot North including the motor-driven reactor feed pump (MDRFP) room (Fire Zone T-1h);

• Fuel building, 781-foot East and West (Fire Zone F-1p);

• Control building, 800 and 828-foot level including the main control room and control room heating, ventilation, and air conditioning system (Fire Zones CB-1i and CB-6);

• Auxilary building, 781-level, Division-1 auxiliary power and cable-spreading room (Fire Zones A-2n, A-2o, and CB-3a);

• Diesel-generator building, 712- and 737-foot level, Division-3 oil storage tank room (Fire Zones, D-4a and -4b);

• Auxiliary building, 707 to 781 foot levels, Division-1 residual heat removal heat exchanger room (Fire Zone A-2b);

• Fuel building, 712-foot level, high pressure core spray room (Fire Zone F-1b)and control building, 762-foot level, Division-3 switchgear room (Fire Zone CB-5a and -5b);

• Auxiliary building, 781-foot level, Division-2 switch gear and cable spreading room (Fire Zones A-3f, -3g and CB-3a); and

• Control building, Division 2 and 3 cable-spreading rooms (Fire Zone CB-1g).

b. Findings

No findings of significance were identified.

.2 Annual Fire Drill Assessment

a. Inspection Scope

The inspectors assessed fire brigade performance and the drill evaluators critique for an announced fire brigade drill for a simulated fire by the main electro-hydraulic control system on July 15, 2003. The drill simulated a fire caused by a leak in an external filtration system. The inspectors focused on command and control of the fire brigade activities; fire fighting and communications practices; material condition and use of fire fighting equipment; and implementation of pre-fire plan strategies. The inspectors evaluated the fire brigade performance using the licensees established fire drill performance criteria. The inspectors verified that minor issues identified during the inspection were entered into the licensees corrective action program. The documents listed in the Attachment to this report were used by the inspectors to evaluate this area.

The inspectors completed one sample for the annual fire drill requirement by evaluating this fire drill.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors verified that flooding mitigation plans and equipment were consistent with the design requirements and risk analysis assumptions. The inspectors reviewed the Updated Final Safety Analysis Report, Section 3.4.1 for internal flooding events and reviewed condition reports and work orders and completed one sample on the following:

• Flood control measures for flooding between emergency core cooling system (ECCS) rooms.

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed heat exchanger performance testing activities to verify identification of potential deficiencies which could mask degraded performance, to verify potential common-cause heat sink performance problems that have the potential to increase risk, and to verify the identification and resolution of heat-sink performance problems that could result in initiating events or that could affect multiple heat exchangers in mitigating systems and thereby increase risk. The inspectors completed one sample by reviewing the results with several licensee inspections of the Division 1, Division 2 and Division 3, essential switchgear room cooler heat exchangers.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification

Sections 1R11.1 through 1R11.7 represent completion of one sample for the biennial licensed operator requalification program inspection.

Section 1R11.8 represents completion of one sample for the quarterly testing/training activity inspection.

.1 Facility Operating History

a. Inspection Scope

The inspectors reviewed the plants operating history from November 2001 through October 2003, to assess whether the Licensed Operator Requalification Training (LORT) program had identified and addressed operator performance deficiencies at the plant.

b. Findings

No findings of significance were identified.

.2 Licensee Requalification Examinations

a. Inspection Scope

The inspectors performed a biennial inspection of the licensees LORT program. The inspectors reviewed the annual requalification operating test and biennial written examination material to evaluate general quality, construction, and difficulty level. The operating examination material reviewed consisted of five operating tests, each containing two dynamic simulator scenarios and six job performance measures (JPMs).

The biennial written examinations reviewed consisted of approximately 40 open reference multiple choice questions. The biennial examinations were conducted in September, October, and November 2003. The inspectors reviewed the methodology for developing the examinations, including the LORT program 2 year sample plan, probabilistic risk assessment insights, previously identified operator performance deficiencies, and plant modifications. The inspectors also reviewed the licensees program and assessed the level of examination material duplication during the current year annual examinations as compared to the previous years annual examinations.

b. Findings

No findings of significance were identified.

.3 Licensee Administration of Requalification Examinations

a. Inspection Scope

The inspectors observed the administration of the requalification operating test to assess the licensees effectiveness in conducting the test and to assess the facility evaluators ability to determine adequate performance using objective, measurable performance standards. The inspectors evaluated the performance of one shift crew in parallel with the facility evaluators during four dynamic simulator scenarios. In addition, the inspectors observed licensee evaluators administer several JPMs to various licensed crew members. The inspectors observed the training staff personnel administer the operating test, including pre-examination briefings, observations of operator performance, individual and crew evaluations after dynamic scenarios, and the post operating test crew de-brief by the training department evaluators. The inspectors evaluated the ability of the simulator to support the examinations. A specific evaluation of simulator performance was conducted and documented under Section 1R11.7, Conformance With Simulator Requirements Specified in 10 CFR 55.46, of this report. The inspectors also reviewed the licensees overall examination security program.

b. Findings

No findings of significance were identified. However, one minor violation was identified by the inspectors during the validation of the dynamic simulator scenarios. The digital recorders used in the simulator had an internal memory that was not completely erased at the end of each validation session. Since personnel not signed on the requalification examination security agreement had access to the simulator, they could have viewed examination material, giving them an unfair advantage on a subsequent dynamic simulator scenario examination. The inspectors believed it highly unlikely that an actual compromise of examination material occurred due to the difficulty of retrieving the information. However, because of the potential for compromise, this was considered a violation of 10 CFR 55.49, "Integrity of examinations and tests." Because the violation is minor it normally would be not documented. However, all violations of examination security are required to be documented. This violation was discovered by station personnel and entered in the stations corrective action program (CR177191, Paperless Recorders Not Being Erased During Simulator Validation). An acceptable method of clearing the memory has been incorporated into the stations examination security procedures.

.4 Licensee Training Feedback System

a. Inspection Scope

The inspectors assessed the methods and effectiveness of the licensees processes for revising and maintaining its LORT program up to date, including the use of feedback from plant events and industry experience information. The inspectors reviewed the licensees quality assurance oversight activities, including licensee training department self-assessment reports. The inspectors evaluated the licensees ability to assess the effectiveness of its LORT program and their ability to implement appropriate corrective actions.

b. Findings

No findings of significance were identified.

.5 Licensee Remedial Training Program

a. Inspection Scope

The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the previous annual requalification examinations and the training planned for the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations.

The inspectors reviewed remedial training procedures and individual remedial training plans.

b. Findings

No findings of significance were identified.

.6 Conformance With Operator License Conditions

a. Inspection Scope

The inspectors reviewed the facility and individual operator licensees conformance with the requirements of 10 CFR Part 55. The inspectors reviewed the facility licensees program for maintaining active operator licenses and to assess compliance with 10 CFR 55.53

(e) and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators and which control room positions were granted credit for maintaining active operator licenses. In addition, the inspectors reviewed the facility licensees LORT program to assess compliance with the requalification program requirements as described by 10 CFR 55.59 (c).

b. Findings

No findings of significance were identified.

.7 Conformance With Simulator Requirements Specified in 10 CFR 55.46

a. Inspection Scope

The inspectors assessed the adequacy of the licensees simulation facility (simulator)for use in operator licensing examinations and for satisfying experience requirements as prescribed in 10 CFR 55.46, Simulation Facilities. The inspectors also reviewed a sample of simulator performance test records (i.e., transient tests, scenario test and discrepancy resolution validation test), simulator discrepancy and modification records, and the process for ensuring continued assurance of simulator fidelity in accordance with 10 CFR 55.46. The inspectors reviewed and evaluated the discrepancy process to ensure that simulator fidelity was maintained. Open simulator discrepancies were reviewed for importance relative to the impact on 10 CFR 55.45 and 55.59 operator actions as well as on nuclear and thermal hydraulic operating characteristics. The inspectors conducted interviews with members of the licensees simulator staff about the configuration control process and completed the IP 71111.11, Appendix C, checklist to evaluate whether or not the licensees plant-referenced simulator was operating adequately as required by 10 CFR 55.46

(c) and (d).

b. Findings

No findings of significance were identified.

.8 Quarterly Testing/Training Activity

a. Inspection Scope

On September 18, 2003, the inspectors observed a licensed operator annual requalification dynamic examination on the simulator. The inspectors observed scenario ESG-LOR-06-00. This scenario involved a loss of the A unit auxiliary transformer, with a subsequent loss of all condensate, condensate booster, and feedwater pumps, coincident with a stuck open power-operated relief valve. This observation constituted one quarterly sample.

The inspectors reviewed licensed operator requalification training to evaluate operator performance in mitigating the consequences of a simulated event, particularly in the areas of human performance. The inspectors also evaluated crew performance in the areas of:

• communication clarity and formality;

• timely performance of appropriate operator actions including following emergency operating procedures;

• appropriate alarm response;

• proper procedure use and adherence; and

• senior reactor operator oversight, allocation of resources and command and control.

Crew performance in these areas was compared to licensee management expectations and guidelines as presented in the following documents:

• OP-AA-101-111, Roles and Responsibilities of On-Shift Personnel, Revision 0;

• OP-AA-103-102, Watchstanding Practices, Revision 2;

• OP-AA-104-101, Communications, Revision 1; and

• OP-AA-106-101, Significant Event Reporting, Revision 2 The inspectors also assessed the performance of the training staff evaluators involved in the requalification process. For any weaknesses identified, the inspectors observed the licensee evaluators to verify that they also noted the issues and discussed them in the critique at the end of the session. The inspectors verified all issues were captured in the training program and licensee corrective action process.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the effectiveness of the licensees maintenance efforts in implementing the maintenance rule (MR) requirements, including a review of scoping, goal-setting, performance monitoring, short and long-term corrective actions, and current equipment performance problems. These systems were selected based on their designation as risk significant under the MR, or their being in the increased monitoring (MR category (a) (1)) group. In addition, the inspectors interviewed the system engineers and maintenance rule coordinator. The inspectors also reviewed condition reports and associated documents for appropriate identification of problems, entry into the corrective action system, and appropriateness of planned or completed actions. The documents reviewed are listed at the end of the report. The inspectors completed two samples by reviewing the following:

• Rod control and information system; and

• Drywell cooling (VP) system (system in (a)(1) status and criteria to be considered prior to transfer to (a)(2) status, January 1, 2002 to August 2003).

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessment and Emergent Work Evaluation

a. Inspection Scope

The inspectors observed the licensees risk assessment processes and considerations used to plan and schedule maintenance activities on safety-related structures, systems, and components particularly to ensure that maintenance risk and emergent work contingencies had been identified and resolved. The inspectors completed six samples by assessing the effectiveness of risk management activities for the following work activities or work weeks:

• Verification of licensees action for protecting Division-2 emergency diesel generator (EDG) and ECCS equipment during Division-1 shutdown service water (SX) system 24-hour operability surveillance test;

• Installing Astromed recording monitor following unexpected turbine driven reactor feed pump trouble alarm in main control room;

• Review of troubleshooting and operation contingency plan in response to increased air in-leakage to main condenser;

• Review replacing 345kV-switchyard breaker 4518;

• Review of the risk evaluation for trouble-shooting and attempted repair for main condenser air in-leakage; and

• Risk evaluation for Division-3 EDG and SX outage week including major diesel overhaul.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following operability determinations and evaluations affecting mitigating systems to determine whether operability was properly justified and the component or system remained available such that no unrecognized risk increase had occurred.

The inspectors completed eight samples of operability determinations and evaluations as follows:

• Supporting operability documentation (SOD) for CR 157529, Diesel generator temperature and pressure switches do not have the required procurement qualifications for safety-related applications;

• SOD for CR 170723, Oil leak on generator outboard bearing;

• SOD for CR 170350, Diesel generator lube oil/filter bypass relief valves do not have the required procurement qualifications for safety-related applications;

• SOD for CR 146142, Diesel generator lube oil switches do not have procurement qualifications for safety related applications;

• SOD for CR 134566, Shutdown Service Water Pump Room cooling system providing excess cooling;

• An evaluation of Reactor Core Isolation Cooling system test return valve to reactor core isolation cooling system ST valve over torqued;

• An evaluation of CR 176490 Chunk of rust found in Diesel Generator Air Start system check valve; and

• An evaluation of information supporting operability of safety-related motor operated valves actuator mounting bolts with less thread engagement than procedurally required CR 177160.

b. Findings

Introduction:

The inspectors identified a violation having potential safety significance greater than minor. This finding resulted from the licensees failure to evaluate a potential configuration change in accordance with the licensees established configuration control process following the installation of modified mounting bolts in Limitorque SMB-2 actuators. The installed mounting bolts achieved less thread engagement than required by design documentation. This finding is considered an unresolved item (URI) pending a review of licensees evaluation of these issues.

Description:

On September 23, 2003, while performing preventive maintenance activities on the residual heat removal heat exchanger bypass valve (1E12-F048B), the licensee observed that the motor-operated valve actuator wobbled as maintenance workers manually stroked the valve. The actuator used in this application was a Limitorque SMB-2.

The licensees immediate investigation of this issue revealed that the operator mounting bolts were not in contact with the valve body flange, thus allowing the actuator to wobble. Upon further investigation of this issue, the licensee discovered that the operator mounting bolts were bottomed out in the pre-tapped actuator casing bolt holes. The licensee indicated that a search of maintenance records showed that the operator mounting bolts were changed out during a previous two-year preventive maintenance window. This occurred when maintenance personnel noted that the bolts installed then did not meet the minimum requirements of the stations valve maintenance procedure CPS 8451.05, Limitorque Operator Removal/Installation.

Appendix I of CPS 8451.04 required those mounting bolts for the Limitorque SMB-2 valve actuator have a minimum thread engagement length of one-inch. The maintenance personnel changed the bolts out to meet the one inch thread engagement criteria; however, during replacement did not recognize that the bolts had bottomed out.

Following the identification that 1E12-F048 was wobbly the licensee installed a bolting configuration that securely fastened the actuator to the valve.

The licensee documented that 1E12-F048B was wobbly in condition report 177160.

Additionally in this condition report, the licensee documented that a similar incident occurred on the residual heat removal heat exchanger outlet valve (1E12-F003B).

Specifically, during installation of the operator mounting bolts, the bolts bottomed out.

However, here the licensee recognized that the bolts had bottomed out and hence modified the bolts such that less than one inch thread engagement was achieved. The condition report also documented that per discussions with the stations engineering staff, 3/4 inch thread engagement for the operator mounting bolts was acceptable.

This was based on a review of calculation IP-CL-018, Revision 0, that documents the stresses in the casing threads were only 52 percent of the allowable. As for addressing the operability of this valve in this condition report, the shift manager documented that the valve was operable because engineers had performed an evaluation that showed that 3/4 inch thread engagement was adequate.

The inspectors reviewed calculation IP-CL-018 and noted that the calculation was for a minimum thread engagement of one inch, not 3/4 inch. The licensee stated that based on the margin shown in IP-CL-018, engineering judgement was used to approve 3/4 inch thread engagement. The inspectors noted that Exelon procedure CC-AA-10 Configuration Control Process Description stated that a design input comprises the criteria, parameters, bases, assumptions and other design requirements upon which detailed final design is based. Exelon Procedure CC-AA-10 also stated that a change to configuration information represented a configuration change. The inspectors concluded that installation of operator mounting bolts that achieved less than the minimum vendor recommended thread engagement and less than the minimum as specified in the licensees design documentation could represent a changed to a critical design input and therefore needed to be evaluated as a potential configuration change.

The licensee agreed with the inspectors conclusion and initiated condition report (CR 178682) documenting this issue. The inspectors considered this issue a performance deficiency.

The inspectors also noted the following issues:

• The licensee's review of the extent of condition was limited to the two identified cases. The inspectors noted that Appendix I of CPS 8451.04 contains instructions regarding all Limitorque actuators used by the licensee in safety-related applications and questioned the licensee regarding the extent of condition scope. The licensee agreed and later identified seven additional valves which could be impacted by this issue. After further discussions, the licensee generated CR 179001 to document the need for a more extensive look at all safety related Limitorque operator mounting bolts.

• By the end of the inspection period, the licensee completed inspection of five of the seven SMB-2 Limitorque actuators used in safety-related systems. These valves were located both divisions of the residual heat removal system. The licensee noted that each of the five actuators had operator mounting bolts which did not meet the previously established minimal thread engagement. The shortest thread engagement length was on the residual heat removal heat exchanger outlet valve (5/8 inch thread engagement). At the end of the inspection period, the licensee was performing an evaluation to assess the adequacy of 5/8 thread engagement for these types of Limitorque actuators.

The completed evaluation is needed to fully assess the significance of the previously discussed performance deficiency.

• The inspectors questioned engineering assumptions made by the licensee in calculation IP-CL-018. For example, the licensee assumed that the bolts effective grip length was equal to the length of the bolts thread engagement.

The inspectors concluded that this assumption resulted in a higher than actual joint stiffness factor. This higher than actual joint stiffness factor would result in non-conservative outcome when calculating the remaining joint force as thread engagement is decreased from the one inch minimum requirement.

Additionally, in IP-CL-018, the licensee referenced an equation for calculating the grip members stiffness constant. This equation differed from the equation noted by the inspectors in several references during the inspectors initial evaluation. The difference in the equations represented an approximate 50 percent reduction in the grip members stiffness constant. This reduction would affect the calculated induced load in the mounting bolt and consequently the shear stress seen on the internal thread of the actuator casing. An assessment of the accuracy of the calculation needs to be completed in order to assess the significance of the previously discussed performance deficiency.

• The inspectors questioned the licensee regarding the past operability of residual heat removal heat exchanger bypass valve (1E12-F048B). For approximately two years, the actuator remained in a condition such that, under design basis seismic loading, the valves functionality may be questionable. This information is needed to assess the safety significance of the performance deficiency described above.

Analysis:

The inspectors considered the licensee failure to properly evaluate a potential configuration change a performance deficiency. The inspectors used IMC 0612, Appendix B, to disposition this issue and determined that it was more than minor because the finding was associated with the Mitigating System crosscutting attribute of Equipment Performance and affected the Mitigating System objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to properly analysis configuration change could lead to degradation in the valve ability to perform appropriately during a design basis accident. This finding was determined to have a potential safety significance greater than minor because that affected valve operators were used in both Division I and Division II low pressure emergency core cooling systems. However, the inspectors were unable to assess the finding in accordance with IMC 0609,Significance Determination Process due to the open issues noted above. the complete the significance determination. Therefore, no color is assigned to this finding at this time.

Enforcement:

Appendix B, 10 CFR Part 50, Criteria III, stated that design changes, including field changes, shall be subjected to design control measures commensurate with those applied to the original design. Exelon procedure CC-AA-10 Configuration Control Process Description stated that a design input comprises the criteria, parameters, bases, assumptions and other design requirements upon which detailed final design is based. Appendix I of CPS 8451.04 required a minimum thread engagement length of one-inch mounting bolts for the Limitorque SMB-2 valve actuator in question. Contrary to the above, about two years ago, following the licensee identification that the operator mounting bolts for several Limitorque SMB-2 did not fit properly, the licensee installed bolts with thread engagement less than the required minimum. This was completed without performing the appropriate level design control review. At the end of the inspection period, the licensee was addressing a number of inspector-identified issues. This issue is considered an unresolved item (URI 05000461/2003005-01) pending additional review of the licensees evaluations and a completed significance determination review.

1R16 Operator Work-Arounds

a. Inspection Scope

The inspectors reviewed an operations work-around with particular focus on the method by which instructions and contingency actions were communicated and reviewed to on-shift licensed operators.

The inspectors completed one sample by reviewing the following:

• operator work around (OWA) -1CP-RCV, Condensate recycle valve - 3 broken hangers upstream of valve found during polisher operations, WO#489984.

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post maintenance testing activities associated with maintenance or modification of important mitigating, barrier integrity, and support systems that were identified as risk significant in the licensees risk analysis. The inspectors reviewed these activities to verify that the post maintenance testing was performed adequately, demonstrated that the maintenance was successful, and that operability was restored. During this inspection activity, the inspectors interviewed maintenance and engineering department personnel and reviewed the completed post maintenance testing documentation. The inspectors used the appropriate sections of the TS and USAR, as well as the documents listed in the Attachment, to evaluate this area.

The inspectors completed six samples by observing and evaluating the post-maintenance testing subsequent to the following activities:

• Hydrogen ignitors after ignitor maintenance;

• Division-3 4160 Vac breaker after breaker replacement;

• Control room HVAC (VC) B after system outage week;

• Control rod drive hydraulic control unit testing after scram solenoid valve replacement;

• Condensate-booster pump testing after shaft-seal replacement; and

• Control room HVAC testing after VC A modulating damper repairs.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors witnessed selected surveillance testing and/or reviewed test data to verify that the equipment tested using the surveillance procedures met the TS, the ORM, the USAR, and licensee procedural requirements, and demonstrated that the equipment was capable of performing its intended safety functions. The activities were selected based on their importance in verifying mitigating systems capability and barrier integrity. The inspectors used the documents listed in the Attachment to verify that the testing met the frequency requirements; that the tests were conducted in accordance with the procedures, including establishing the proper plant conditions and prerequisites; that the test acceptance criteria were met; and that the results of the tests were properly reviewed and recorded. In addition, the inspectors interviewed operations, maintenance and engineering department personnel regarding the tests and test results.

The inspectors completed eight samples by evaluating the following surveillance tests:

• High pressure core spray operability test;

• Reactor core isolation cooling system valve operability and pump flow quarterly surveillance test;

• Diesel fire pump (DFP) B capacity test and operability test;

• Average power range monitor (APRM) channel functional tests;

• Division-2 shutdown service water (SX) quarterly operability test;

• Standby liquid control system, quarterly surveillance test;

• Control room heating, ventilation, and air conditioning (HVAC); and

• Evaluation of the Division-3 EDG monthly for oil leak on generator bearing during monthly operability test.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the three following temporary modifications to determine whether the safety functions of important safety systems were affected and if the licensee followed their established procedure for temporary modifications CC-AA-112 Temporary Configuration Changes, Revision 5. The inspectors utilized selected sections of TSs and the USAR and 10CFR50.50 Screening and Review, and Evaluation. The inspectors also interviewed the system engineers.

• EC 341096 - Temporary Modification (TMOD) to eliminate the run back signal to the B Reactor Recirculation Flow Control Valve during a loss of feedwater concurrent with a low water level;

• EC 341953 and EC 341754, Reroute wiring to the A and B Reactor Recirculation Flow Control Valves, Rotary Variable Differential Transformers (RVDT) to compensate for damaged wiring; and

• Temporary Modification #337100, Raised alarm and trip setpoint for main generator bearing vibrations.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

The inspectors reviewed the licensees assessment of the performance indicators (PIs)discussed below to determine the accuracy and completeness of the PI data.

Cornerstone: Mitigating Systems

a. Inspection Scope

The inspectors sampled the licensees submitals for performance indicators (Pis) for the periods listed below. The inspectors used PI definitions and guidance contained in Revision 2 of Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline to verify the accuracy of the PI data. The following two PIs were reviewed:

• safety system unavailability (SSU) - emergency AC power

• safety system functional failures The inspectors reviewed selected applicable conditions and data from logs, licensee event reports, and CRs from July 2002 through June 2003 for each PI area specified above. The inspectors independently re-performed calculations where applicable. The inspectors compared that information to the information required per each performance indicator definition in the guideline to ensure that the licensee reported the data accurately.

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 system at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Minor issues entered into the licensees corrective action system as a result of inspectors observations are generally denoted in the report.

The inspectors also reviewed a licensee training department self-assessment report.

The licensees self-assessment reviewed the licensed operator training program 2 months prior to this inspection activity. The self-assessment was reviewed to ensure that any issues identified during the self-assessment were appropriately evaluated, prioritized, and controlled.

b. Findings

No findings of significance were identified.

.2 Third Quarter-2003 Prompt Investigations and Apparent Cause Evaluations Trend

Review (Annual Sample)

a. Inspection Scope

The inspectors reviewed the CRs listed in the Attachment to determine if there was a discernible trend in either the causes or the corrective actions for the CRs. This area was selected as a sample because insights gained would assist in assessing the cross-cutting area of human performance. The review included 11 licensee prompt investigations and apparent cause evaluations initiated from July through September 2003. The reports were reviewed for trends in either the causes or the corrective actions for the CR as well ensuring that the full extent of the issues were identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized.

b. Findings and Observations

There were no findings identified associated with the 11 reviewed CRs. The inspectors noted that human performance was a contributing factor on 2 of the CRs involving work orders which required a scope change before being implemented. In the first case, the workers had not checked both the E02 and the E03 electrical prints to ensure agreement on wiring details before starting work and had not checked the wiring on a second component for energization before lifting a lead -- causing drop in condensate-booster pump discharge pressure. In the second case, the clearance order had been revised to prevent hanging a clearance tag on a component to be worked on. (The tag would have precluded working on the component.) The personnel that changed the scope of the clearance order did not follow the same rigor as specified for the initial clearance order preparation with the result that some electrical contacts for the computer system would have remained energized. The mistake was caught before anyone signed on to the clearance order. The changes in work scope had created conditions where personnel did not use the same amount of rigor in checks and balances to ensure proper conduct of work. The errors were by different work groups and were attributed to weak human performance attributes in self-checking as contributing causes.

4OA3 Event Follow-up

On August 14, 2003, following the loss of power grid on East coast, the inspectors responded to the main control room. The inspectors verified that there were no immediate consequences to the facility.

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. K. Polson and other members of licensee management at the conclusion of the inspection on October 9, 2003. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

.2 Interim Exit Meetings

An interim exit meeting was conducted for:

• Biennial Operator Requalification Program Inspection with Mr. K. Polson on October 3, 2003.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Bement, Site Vice President

K. Polson, Plant Manager

M. Baetz, Operations Support/Services Manger

J. Cunningham, Work Management Director

R. Davis, Radiation Protection Director

R. Frantz, Regulatory Assurance Representative

M. Hiter, Access Control Supervisor

W. Iliff, Regulatory Assurance Manager

J. Madden, Nuclear Oversight Manager

D. Schavey, Operations Director

R. Schmidt, Maintenance Manager

J. Sears, Chemistry Manager

T. Shortell, Training Director

J. Williams, Site Engineering Director

C. Williamson, Security Manager

R. Zacholski, Shift Operations Superintendent

LIST OF ITEMS

Opened

05000461/2003005-01 URI Thread Engagement of Limitorque Actuator Mounting Bolts less than vendor recommendations.

Closed

None

Discussed

None Attachment