ML20202H754: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot insert)
 
(StriderTol Bot change)
 
Line 1: Line 1:
#REDIRECT [[IR 05000461/1997025]]
{{Adams
| number = ML20202H754
| issue date = 02/13/1998
| title = Insp Rept 50-461/97-25 on 971125-980122.Violations Noted. Major Areas Inspected:Operations,Engineering,Maint & Plant Support
| author name =
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name =
| addressee affiliation =
| docket = 05000461
| license number =
| contact person =
| document report number = 50-461-97-25, NUDOCS 9802230014
| package number = ML20202H744
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 25
}}
See also: [[see also::IR 05000461/1997025]]
 
=Text=
{{#Wiki_filter:_
      .
    *
                          U.S. NUCLEAR REGULATORY COMMISSION
                                                        REGION 111
                      Docket No:                        50-461
                      License No:                      NPF-S2
                        Report No:                        50-461/97025(DRP)
                        Licensee:                        lilinois Power Company
.
                        Facility:                        Clinton F'ower Station
                        Location:                        Route 54 West
                                                          Clinton, IL 61727
                        Dates:                            November 25,1997 - January 22,1998
                        inspectors:                        T. W. Pruett, Senior Resident inspector
                                                          K. K. Stoedter, Resident inspector
                                                          K. N. Selburg, Radiation Specialist
                                                          D. E. Zemel, Illinois Department of Nudear Safety
                        Approved by:                      Thomas J. Kezak, Chief
                                                          Reactor Projects Branch 4
  ,
        9802230014 900213          *
        {DR ADOCK 05000461
                      PDR
                            ..        _ _ _ - - _ _ _ _
 
                                                          -.            _ - _ _ _ _ _ _ - - _ _ _ _ -    - _ - _ _
,
    .
                                                                        EXECUTIVE SUMMARY
                                                                          Clinton Power Station
                                                              NRC inspection Report No. 50-461/97025(DRP)
      This inspection included aspects of licensee operations, engineering, maintenance, and plant
      support. The report covers an eight-week period of resident inspection.
      Operations
      .        One violation was identified due to the failure to implement required Technical
              Specification actions to restore isolation capability to secondary containment penetrations
              between October 18 and December 16. Additionally, on-shift operations personnel were
              unfamiliar with how to implement licensing department guidance on acceptable
              administrative contrels associated with Technical Specification 3.5.2.D.3.
              (Section 01.1.b.1)
      .        One violation war, identified due to the failure to implement required Technical
              Specification actions to restore either the Division I or 11 inverter to service. Specifically,
              operations personnel failed to recognize that declaring all 480VAC motors inoperable
              required an entry into Technbal Specification 3.8.8, " inverters-Shutdown."
              (Section 01.1.b.2)
      +      Fourteen examples of the faiivre of operations personnel to implement the Technical
              Specifications since January 1996 were identified by NRC inspectors and/or the licensee.
              The multiple failures represent a weakness in the ability to implement the requirements of
              the Technical Specifications and a poor awareness of plant conditions which impact
              Technical Specification requirements. (Section 01.1.b.3)
      .      The decision to continue work even though three out of four source range monitors
                (SRMs) were exhibiting unexpected responses indicated a poor awareness of conditions
                with the potential to impact Technical Specifications, and was an example of a poor
                questioning attitude and oversight of maintenance activities by operations personnel.
                (Section 01.'..b.4)
        *      A 13-day delay in restoring SRMs to an operable status was an example of poor
                awareness of plant conditions and a lack of operations personnelinvolvement in restoring
                Technical Specification equipment to a fully operable status. The avoidable delay in
                restoration resulted in an unnecessary entry into plant Technical Specification 3.3.1.2,
                " Source Range Monitor Instrumentation." (Section 01.1.b.5)
        *        Implementation of Technical Specifications for SRM channel functional testing was poor
                in that operadons personnel were unable to initially explain the basis which allowed
                tran:,fer of the reactor mode switch from shutdown to run. Additionally, operations
                personnel did not document the applicable Special Operation Technical Specification
                which allowed the deviation from the requirements of Technical Specification 3.3.1.2 prior
                to man;pulating the reactor mode switch. (Section 01.1.b.5)
        .      The failure to notice or provide a reason for the abnormally low cooling water inlet and
                outlet temperature indication associated with Rasidual Heat Removal (RHR) Heat
                                                                                                          2
  )
                                                                                                        .
            __    _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . . . -
 
        .
                                                                                                                  l
      .
                    Exchanger A following a transfer of shutdown cooling was an example of poor awareness -
                    of plant indications by operations personnelin the c sin control room. (Section 01.1.b.6)
          .        The failure to notine or provide a reason for the abnormal vent velve position indication
                    associated with RHR Heat Exchanger A was an example of poor awareness of plant
                    Indications by operations personnel in the main control room. (Section 01.1.b.7)
          -.        The inability to explain the status of the normally operating fuel building ventilation system
                    was an example of poor awareness of plant conditions by operations persone.
                  ;(Section 01.1.b.8)-
            .        Several deficiencies were ident;fied involving the operations mode restraint tracking          '
                    system, which included: condition reports and engineering evaluations which were not
                    identified as mode restraints; condition reports and engirieering evaluations which were -
                    classified as mode restraints but not tracked on a mode restraint list; ineffective
                    implementation of corrective actions for previously identified mode restraint issues; and
                    multiple departmer.tal tracking systems for mode restraints. (Section 01.2)
            .        During the transfer of shutdown cooling from RHR Train B to RHR Train A, r.,perations
                    personnel appropriately referenced procedures, acknowledged annunciators, and
                    performed the transfer without any significant complications. (Section 01.3)
          -*        An auxiliary operator was knowledgeable of systems and provided good respot'ses to
                      questions during a tour of the containment, fuel, control, and auxiliary buildings.
                      (Section 01.4) -
                      Several discrepancies were noted during a walkdown of the altemate source of control
                      room ventilation including: incorrect revisions of procedures, an uncontrolled vendor
                      manual, and a lack c,f implementation of vendor recommended preventive maintenance -
                      items.- (Section O2,1)
              Maintenance
          -.        Maintenance personnel demonstrated good procedure usage during functional testing of -
                      the Division ill 4.its KV Bus under voltage relay in that they reviewed each step prior to
                      performance, exhibited good independent verification techniques, were aware of the
                      purpose of the surveillance test, and understood problems which could be encountered if
                      the surveillance was not successfully completed. (Section M1.2)
              ..      Maintenance personnel did not effectively plan work activities for the initial 480VAC motor
  -
                      inspections in that work began on the Shutdown Service Water (SSW) Pump Room A
                      Supply Fan motor without having the appropriate parts on site, without having all parts .
                      approved through an accredited quality assurance program, and without having a method
,
    .
                      for grossing the motor bearings prior to installation. (Section M1.4)
              .        One example of a non-cited violation was identified for the failure to follow procedures
                        invulving the installation of an isolation transformer riuring testing of SRMs. Two
'
                        examples of a poor questioning attitude were identified which involved the continuance of
                        a maintenance activity even though there was an unexplained increase in test parameters
                        and an unexplained increase in main control room SRM indications. (Section M1.5)
                                                                    3
 
                                                                                        _ - - _ _
      .
    .
          .      'An audit conducted by qualit/ assurance involving receipt inspections and shelf life
                  determinations identified several weaknesses in the material management program and
                  represented a continued improvement in the quality assurance organization's ability to
                  perform thorough evaluations. (Section M7.1)
          Pla 4 Sucoort
            ,
i
          .
                  One example of an individualincorrectly processing through a PCM-1B was identified.
                  (Section R4.1)
          .
                  No deficiencies were noted during a lighting tour of the protected area. (Section S2.1)
  ,
                                                                                                          )
                                                            4
        _              ________
 
                  - _ __                            _ __                _ - _ _ _ _ - _ _ _ - _ - _
                                    -
                                                                                                                ?
  .
                                                          Report Details
      Summantol_PlanLRtatua
      The plant remained shut down during the inspection period. Major activities included the removal
      of sitt from the service water intake structures, a Division li olectrical bus outage, and the -
      init!ation of team assignmes,ts for the licensee's Plan For Excellence. On January 6,1998, the
    - licensee announced that a three-year contract had been signed, which would allow the facility to-
      be managed by PECO Nuclear, a division of PECO Energy Company of Philadelphia,
                                                          l. Operations
    :01        Conduct of Operations
    - 01.1 Operators' Awareness of Plant Conditions and Technical Specifications
        a.      Inspection Scoce (717.QI)
                The inspectors performed frequent observations of control room activities and questioned
                operations personnel on the statu2 of plant equipment, indications, and Technical
                Specifications (TS).                                                                            ,
                                                                                                                  l
        b.      Observations and Findinas
                  Several examples of poor awareness oi TS entry mditions or plant conditions by
                  operations personnel were identified which invu . _ the failure to verify that automatic -
                  containment isolation signals were operable, the automatic transfer of the Division 11
                . Inverter, the impact of Source Range Monitor (SRM) Channel A maintenance on SRM
                  Channels B, C, and D, the performance of SRM channel functional testing, low cooling
                  water inlet and outlet temperature indications on RHR Heat Exchanger A, incorrect valve
                  position indication on RHR Heat Exchanger Vent Valves E12-R609B and E12 R608A, .
                  and the status of the Fuel Building Ventilation (VF) system,
          b.1        Failure to Maintain Containment isolation Signal Operable
                  Technical Specification 3.5.2, Required Action D.3, specified that actions ce initiated to
                . restore isolation capability in each secondary containment and secondary containment
                  bypass penetration flow path that was not isolated. The Bases for TS 3.5.2 stated that
                  secondary containment penetration isolation capability must be ensured by verifying at
                  least one isolation valve and associated instrumentation are OPERABLE or other
                . acceptable administrative controls are in place to assure isolation capability for each
                ~ effected penetration. A description of what constitutes "other acceptable admhistrative
                  controls".was not provided in the TS Bases.
                    On November 26, due to the inability to maintain at least one isolation valve operable for
                    each effected penetration, licensing personnel provided the operations department with a
                    letter which specified the steps necessary to comply with "other acceptable administrative
                    controls," pursuant to TS 3.5.2.D.3 Bases. The letter required that operations personnel:
                                                                  5
t.
                    _ __ _ __ __
 
                                    -
                                              _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ - _ ___                              -__ - -_
        .
      .
                                          1.                                  Maintain a list of secondary containment penetrations that
                                                                              remain open,
                                          ~ 2.                                Idantify which of these penetrations are auto-closed upon
                                                                              receipt of an isolation signal, and
                                          3.                                  In the event of an auto-Isolation signal, monitor the
                                                                                response of these valves and take manual action to isolate
                                                                                any penetrations that fail to close.
                                On December 17, the inspectors verified that a list of effected secondary containment
                                penetrations had been developed which identified those penetrations that auto-closed                      ;
                                upon receipt of an isolation signal. The inspectors questioned on shift operations
                                personnel to determine which auto-isolation signals were required to be operable (e.g., all
                                secondary containment auto isolation signals or those isolation signals which pertained to
                                the valves being left open). The individuals questioned were not familiar with the auto-
                                - isolation signals which were required to be operable in order to comply with the
                                requirements for other administrative controls. The inspectors considered the
                                unfamiliarity with implementation of other acceptable administrative controls associated
                                with TS 3.5.2.D.3 an example of a poor questioning attitude and poor implementation of
                                the TS 3.5.2.D.3 requirements.
                                  On December 18, after consultation with licensing personnel, operations personnel
                                  determined that circuits associated with core alters'.lons, movement of irradiated fuel, and
                                  operations with a potential for draining the reactor vessel, which also provided an auto-
                                  isolatioti signal to secondary containment isolation valves that remained open, were
                                  required to be operable. Additionally, operations personnel informed the inspectors that a
                                  review of tests and surveillances for the associated auto-isolation circuits had been
                                  performed to ensure operability of the required circuits.
                                  On December 19, the inspectors independently verified the auto-isolation instruments
                                  associated with valves which remained open and determined that the Containment
                                  Building Fuel Transfer Pool Ventilati6n Plenum Radiation - High instruments were
                                  inoperable because surveillance testing on Plant Radiation Ms. . ors 1-RIX-FR008A, -B,
                                  -C, and -D were overdue. The 1-RIX-PR008 Monitors provided an auto-isolation signal to
                                  Secondary Containment isolation Dampers 1VF04Y, " Fuel Building Supply Outboard
                                  Isolation," 1VF06Y, " Fuel Building Supply Inboard Isolation," 1VF07Y, " Fuel Building
                                  Exhaust inboard Isolation Damper," and 1VF09Y, " Fuel Building Exhaust Outboard
                                  isolation Damper." Consequently, the auto-isolation capability of Dampers 1VF04Y, -6Y,
                                  -Y, and -9Y were not maintained in accordance with the provisions establish for other
                                    administrative controls pursuant to TS 3.5.2.D.3.
                                  The inspectors performed a review of plant conditions and determined that as of
g                                  September 2,1997, the licensee was required to maintain the auto-isolation circuity for
                                . the 1-RIX-PROO8 monitors operable. However, on October 18 operations personnel
                                    unknowingly allowed the surveillance testing on the 1-RIX-PROO8 monitors to lapse
                                    (exceed the 1.25 frequency). On December 16, operations personnel closed De opers
                                      1VF04Y,- 6Y, -7Y, and -9Y in preparation for a Division ll electrica! bus outage. The
                                      1-RIX-PROO8 monitors wero restored to an operable status on December 22, p'ar 'o
                                      reopening Dampers 1VF04Y, -6Y,-7Y, and -9Y. The failure to implement requirst.
                                                                                                            C
  ;-
  -. .  - _ _ _ - - - - _ _ .
 
.
                actions to restore isolation capability to secondary coretainme,rit penetrations between
                October 18 and December 16, demonstrated a poor awareness of plant systems and is a
                violation of TC 3.5.2.D.3 (VIO 50 46119702541).
  - b.2 ' Failure to Recognize T8 Conditions for inoperable inverters
                  On December 25,1997, at 12:45 p.m., operations oorsonnel received an annunciator due
                  to the Division 11 Nuclear Steam Protection System Inverter transferring from its normal to
                  its attemate power supply. Both operations and electrical maintenance personnel
                  responded, but were unable to determine the cause of the inverter transfer.
                    Subsequently, operations personnel considered the invertor inoperable.
                    On December 28, at 8:30 p.m., operations personnel made an entry into the main control-
                    room logs which specified that as of 4:00 p.m. on December 28, TS Lim!iing Concluion for
            ' Operation (LCO) 3.8.8, " inverters-Shutdown," was entered due to the Division I and 11
                    inverters being inoperable.
                    The inspectors questioned operations personnel to de: ermine: (1) why th6 TS 3.8.8 entry
                    condition was not noted on December 25, and (2) following identification on
                      December 28, why didn't operations personnel specify the time of entry as 12:45 p.m. on
                      December 25. Operations personnel stated that they initially bsileved the required
                      actions to be taken in response to two inoperable inverters were adequately covcred by
                      TS 3.8.2, ?AC Sources - Shutdown" and TS 3.8.10, "Distribuilon - Shutdown." In addition,
                      multiple operating crews failed to recognize that the actions to be taken when the
                      Division I and 11 inverters were inoperable were clearty delineated in TS 3.8.8. Operations -
                - personnel stateo that the date and time of entry on Cecember 28 had been based on
                        recognition of the Division ! inverter being inoperable and that + hey should have predated
                - the LCO entry time to 12:45 p.m. on December 25.
                        On December 29, operations perso_nnel informed the inspectors that the Division I
                        inverter was inoperable because the 480VAC motor which supplied power to the inverter
                        room cooler was out of service due to motor over grossing concems. The inspectors                ,
                        questioned operations personnel to determine why TS 3.0.8 hed not been entered on
                          November 8,1997, when the 480VAC motors for both the Division I and 11 inverter room
                          coolers were out of service since the inoperable room coolers resulted in both inverters -
                          being inoperable. After reviewing TS and other associated documentation, operations
                          personnel determined that they had missed entry into TS 3.8.8 when the 48"VAC motors
                          for the inverter room coolers were declared inoperable on November 8. As a result, the
                          required actions for TS 3.8.8 were not performed until 50 days after the inverters were
                          initially inoperable. The failure to recognize an entry into a condition prohibited by TS
                          demonstrated a poor awareness and questioning attitude by operations personnel.
                          Technical Specification 3.8.8, inverters - Shutdown, requ;res, in pari, that one divisional
                            inverter capable of supplying one division of the Division I or 11 onsite Class IE
                            uninterruptible AC bus electrical power distribution subsystems required by L.CO 3.8.10,
                            " Distribution Systems - Shutdown," shall be operable. With one or more required
                            divisional inverters inoperable, the LCO requires tnat actions be initiated to declare the
                              affected required features inoperable immediately or suspend core alterations, suspend        i
                              handling of irradiated fuel assemblies in primary and secondary containment, suspenc;
                              operations with the potential to drain the vessel, and initiate actions to restore required
                                                                          7
        _ - _ - _ _ _ _ _ _ -
 
          .-_-                      ---__                          _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ = _ _ _ _ _ - _ _ _ _ _ _ _ -
    .
                divisionallaverters to an operable status immediately. The inspectors determined that
                the failure to implement the Required Actions of the associated Conditions for -
                approximately 50 days a violation of TS 3.8.8 (VIO 50 461/9702542),
      : b.3      Adverse Trond involving implementation of T8
                The inspectors noted that there have been multiple examples det m in NRC
                inspection reports and Licensee Event Reports (LER) which involved inadequate
                implementation of the TS. The following examples were previously noted by the
                inspectors between the period of January 1996 and December 1997:
                  NRC Report 50-461/97022: Two examples of the failure to implement TS Required
                                                      - Actions involving immediate actions and attemate shut
                                                        uown cooling.
                  NRC Report 50-461/97015; One example involving the installation of a non qualified
                                                        portable battery charger to the Division 11 Battery.
                  NRC Report 50-461/96006: Two examples involving the plant not being placed in -
                                                        MODE 4 and not locking the mode switch in the refuel
                                                        position.
                  NRC Report 50-461/96005: Two examples involving control room ventilation and
                                                        reactor water cleanup room floor plugs.
'
                  LER 50-461/97011:                    One example involving the failure to verify breaker position
                                                        every seven days.
                  LER 50-461/97007:                    One example involving seismia qualification of circuit
                                                        breakers.
                  LER 50-461/97002:                    One example involving EDG testing.
                  LER 50-461/96019:                    One example involving surveillance testing of SRMs.
                  LER 50-461/96003:                    One example involving a breach of secondary containment.
              .  The inspectors noted that the mu4iple examples of inadequate TS implementation was an
                  adverse cendition which the licensee had not previously recognized. On January 5,1998,
                  the inspectors discussed the TS deficiencies with senior licensee personnel. In response
                  to the inspectors' concem, the licensee initiated condition report (CR) 198-01-059 on
                  January 7,1998, to document an adverse trend in TS awareness and implementation.
                  The Assistant Plant Manager- Operations stated that emergent training on TS, a review
                  - of existing TS applicable to the plant conditions, and discussions with shift supervisors
                  would be performed as an interim measure until a more thorough review could be
                    initiated.
  -
                                                                    8
                                          . _ _ - _ _
 
                                            ___ _ _ _ _ -______ -_ _ _-_-
        -t
      4
          b4    McIntenance on SRM Channel A
                On December 2,1997, during preventive maintenance to perform current to voltage (1/V)
                plots on SRM Channel A, the SRM Channel B, C, and D count rate increased and a short
              : period alarm annunciated in the main control room. Operations personnel questioned
                control and instrumentation (C&l) personnel to deterrr.ine if the maintenance activity
                caused the unexpected increase in count rates. C&l responded that they were not the -
                cause of the increased counts end resumed work.
                Upon resumption of the maintenance activity operations personnel observed a second
                increase in count rate on SRM Channels B,_C, and D. Once again o; erations personnel
                questioned C&l personnel regarding the impact of the SPM A activity on SRMs B, C, and
                D. Again, C&I responded that they did not believe they were responsible, but
                recommended that the test voltage be adjusted a third time on SRM A to check the
                response on SRMs B, C. and D. As the test voltage was raised, operations personnel
                noted an increase in the count rate on SRM Channels B, C, and D. Following the third
                unexpected and unexplained increase in count rate, operations personnel directed that
                C&l stop the work activity on SRM Channel A. _The inspectors considered the delay in
                work stoppage until a third unexpected response occurred an example of poor
                questioning attitude and overs;ght of maintenance activitie; by operations personnel.
                  On December 3, the inspectors questioned operations personnel to determine the
                  applicellity of SRM TS. Operations personnel stated that SRMs B, C, and D were
                  operable since the maintenance activity on SRM Channel A had been stopped. The -
                  inspectors questioned operations and engineering personnel to determine if the
                  operability review assessed whether or not adequate separation existed between the
                  SRM channels, given the unexpected and unexplained response on SRM Channels B, C,
                  and D. Engineering personnel discussed the issue with the vendor and were unable to
                  determine if adequate separation existed between the SRM Channels. Because the
                  response to SRM Channels B, C, and D was unexpected, and because engineering was
                  unable to determine if adequate separation existed between SRM Channels, operations
                  personnel declared all four channels of SRM inoperable and verified the required actions :
                  of TS 3.3.1.2, "Cource Range Monitor Instrumentation."
                  On December 10, engineering personnel completed an evaluation of the unexpected
                  response on SRMs 0, C, and D, and determined that the event was related to noise -
                  generation created due to the setting of the discriminator threshold level and improper                          -
                                                                                                                                      I
                  isolelion of the 120 Vac power supply to the measuring and test equipmem (See
                  Section M1.5). Even though the licensee eventually demonsteated that adequate
  e                separation existed between the SRM channels, the inspectort. considered the lack of :
                  recognition of conditions with the potential to impact TS ari example of poor awaraness
                  and questioning attitude by operations personnel,
          b.5    Channel Functionel Testing of SRMs
.
                    On December 22,1907, SRM Channels A, B, and C were inoperable end operations
#
                    personnel were imp'emeoting the required actions of TS 3.3.1.2 wnich rpecihd that witn
                    less than two operable SRM channels, fully insert all inv rtable control rodt and pkce the
N                  rentor mode switch in the shutdown position. SRM A was consbered inoperable
a
                    because operations personnel had allowed the channel functionc' test to Irpse on
                                                                              S
  ,
                                                                                                                                        l
                                                                                                                                        !<
    ,
p
          ,                                                              ..g        m_m_-_          _ __ __ _ _._ _ _ _ _ _ - - - -
 
                                                    _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
        December 10. SRM B was considered inoperable because operations personnel had not
        completed post maintenanca testing following maintenance completed on December 15.
        SRM C was considered inoperable on December 22, due to uner.plained inteimittent
        spiking. Prior to December 22, SRM C had been placed on the main control room
        deficiency list due to intemdttent spiking.
        - The licensee initially attempted to restore SRM C to service on December 23, prior to
          performir4 testing on the remaining SRMs.- However, trouble shooting activities on
          SRM C_ wore unsuccessful, and operations personnel decided to complete channel
          functional testing on SetMs A, B, and D.
          The inspectors questioned operations personnel to determine: (1) why testing had been
          deferred to the point that an unnecessary entry into TS 3.3.1.2 was required, and (2) why
        - reliance was placed on a suspect monitor to meet the TS 3.3.1.2 requirements for two
          operable SRMs. Operations personnel stated that a lack of operations involvement in the
          schMuling process resulted in an unacceptable delay in restoring SRMs to service in a              ,
          timstj manner. The inspectors considered the delay in restoring the SRMs to operable
          status an example of poor awareness of plant conditions ared a lack of operations
          involvemem in restoring TS equipment to a fully operable status.
          During a review of the December 23 station logs, the inspectors noted a log entry at
          12:35 p.m. which specified that SRM channel functional testing had commenced, that all
.          rods were inserted, and that there were no core alterations in progress. The inspectors
          noted that SRM channel functional testing required that the reactor mode switch be
          placed in the run position, which was contrary to the TS 3.3.1.2 required action to
            maintain the reactor mode switch in the shut down position.
          The inspectors questionod on shift operations personnel to determine why it was
            acceptable to transfer the reactor mode switch from the required position. Operations
            personnel involved in the SRM channel functional testing were initially unable to explain .
            the rational for transferring the reactor mode switch. Upon further review, operations
            personnel stated that the actions taken were consistent with implementation of Special
    '
            Operations TS 3.10.2, " Reactor Mode Switch Interlock Testing," which allows transfer of
            the reactor mode switch to other positions to allow testing provided all control rods
            remain fully inserted in core cells containing one or more fuel assemblies; and no core
            alterations are in progress.
  .
            The inspectors noted that the station logs indicated that tha control rods were fully
            inserted and that no core alterations were in progress.' However, no entry had been
            made specifying that the provisions of TS 3.10.2 were being invoked in order to perform            4
            testing. Operations personnel acknowledged that an entry in the station log should have
            been made which specified the applicable TS being utilized for the plant condition. The
r            inspectors determined that implementation of the TS for SRM channel functional testing
            by operations personnel was poor in that they were unable to initially explain the basis
          - which allowed transfer of the reactor mode switch and because operations personnel did
              not document the applicable TS prior to manipulating the reactor mode switch.
I
                                                                        10
)'
  y
      .
 
  .
                                                                                                      I
    b.6  Cooling Water Temperature Indication for Residual Heat Removal Heat Exchanger
        On December 17, following the transfer from RHR B to RHR A, the inspectors noted that
        the cooling water inlet and outlet temperature indications for RHR Heat Exchanger A were
,        pegged low. On shift operations personnel questioned by the inspectors had not noticed        '
        the abnormal indication and were unable to provide an explanation for the low reading.
        Operations personnel stated that the temperature indicators were typically not used since
          a separate instrument for the parameter was normally referenced. The inspectors
        considered the failure to notice or provide a reason for the abnormally lov/ Indication an
          example of poor awareness of plant indications.
          Approximately 30 minutes later, during subsequent discussions with operations
          personnel, a reactor operator recalled that the cutlet temperature indicator may have
          been a main control room deficiency. Through a search of MWR tags in a storage bin in
          the control room and a review of the MWR database, the on shift operators were able to
        = locate documentation which described the deficiency on the outlet temperature indication.-
          The inlet temperature indication did not have a separate deficiency tag but was described
          in the remarks section of the MWR database for the outlet temperature indication. The
          inspectors noted that nothing existad on the contrd room panel to prompt the operators
          of a main control room deficiency and a log of main control deficiencies was not
          maintained in the control room (See Section 02.1).
    b.7  RHR Heat Exchanger Vent Valve Position Indication -
          The inspectors questioned operations personnel to determine why the main control room
          valve position indication for RHR Heat Exchanger Vent Valves E12-R609B, and .
          E12-R608A did not indicate full closed even though the valves were fully closed.              j
-
          E12-R609B indicated approximately 2 percent, and E12-R608A indicated approximately
          5 percent open even though both valves were tagged in the fully closed position.
          Operations personnel stated that the valve indications are not utilized and therefore the
          discrepancy had not been noted or documentsd as a deficieacy. The inspectors
          considered the lack of recognition of the inaccurate valve position indication an example
          of poor questioning attitude and awareness of plant systems by operations personnel,
    b.8  Status of Fuel Building Ventilation System
          On Oncember 19,1997, on shift operations personnel noted an increase in fuel building
          fire alarms due to the normal ventilation system being secured to support maintenance
          involving the Division 11 bus outage. The inspectors questioned on shift operations
          personnel to determine why the fuel building ventilation (VF) system was out of service
          and received different reasons.-
          The first individual stated that he was unsure why W was inoperative but speculated that
          it was because sensing instruments powered from Division 11 were deenergized. The
            second individual stated that there was only one train of VF which was powered from
            Division ll.
                                                      11
                                                                  _ _ _ _ _
 
                                                                            - _ _ _ _ _ _ _ _ _                _ _ _ _
  k
              Upon further review, the inspectors detcrmined that the in' series VF system isolation
              dampers are powered from both Division I and 11. Securing Division I or ll electrical
              busses removes pnwer from the dampers which actuate to the fail close position. The
              inspectors noted that Procedure CPS 3514.01C006, " Bus / Unit Sub outages,4160V Bus
              (1 AP09E) Outage," required that the VF system be secured as a prerequisite.
              Nevertheless, the inspectors determined that inability of on shift operations personnel to
              explain the status of the normally operating VF system an example of poor awareness of
              plant conditions.
'
      c.      Conclusions
              The inspectors identified that since January 1996, on at least 14 occasions, operations
              personnel failed to properly implement the TS. The multiple failures represent a
              weakness in the licensee's ability to property implement the requirements of the TS and a -
                poor of awareness of plant conditions which impact TS requirements,
              Two violations involving the failure to impicment the TS associated witi1 secondary
                containment and inverters were identified. Additionally, several examples of a poor
                awareness of plant conditions and poor questioning attitude were identified, which
                involved the performance of maintenance and testing on SRMs, the status of control
                room indications for RHR heat exchanger temperature and valve position and the
            - operational status of the fuel building ventilation system.
    01.2 ' Trackina of Plant Mode Restraints
      a.        Inspection Scoce (71707)
                The inspectors reviewed the program for tracking mode restraints to ensure that all items
                                                                                                                      '
                had been entered into the mode change restraint list (MCRL) or ott'er appropriate tracking
                method,
      b.        Observations and Findinos
                The inspectors determined that the means for tracking condition reports or maintenance
                work requests identified as mode restraints were inconsistent in addition, multiple lists
                between the operations, planning,- engineering, and corrective action program
                departments made retrievability and tracking of mode restraint items cumbersome. For
              . example, at the inspector's request, the licensee identified at least 31 CRs which were
                classified as mode restraints but were not listed in the official MCRL The inspectors
                were also unable to cross reference severalitems between the system status file, the
                MCRL, the shift supervisor restraint list, the corrective action review board restraint list,
              = and the engineerhg list.
                Because'of the cumbersome process, the inspectors reviewed CR 1-97-05-024, "Failura
                to Propedy identify Mode Restraints," initiated May 2,1997, to determine the status of
                corrective actions from previously identified deficiencies involving CRs which were either
                not identified as mode restraints or were not in a tracking system. During the review of
                the CR, the licensee noted that the informal processes were cumbersome, prone to
                human error, and that tools needed to be developed to effectively and officiently track
                mode restrs!nts. Examples of deficiencies included new mode restraints identified during
                                                            12
o        - -            _ _ _ _ - _ - _ .
 
                                                                                            - - _
                                                                                                            ,
      - engineering reviews'which were not communicated to operators, shift supervisors and
        shift resource managers, CRs which were incorrectly identified as not being a mode -
        restraint, and engineering evaluations which identified mode restraints but were not .
        specified on the MCRL
        Corrective actions included revisions to procedures to improve awareness of mode
        restraints and the development of a mode restraint database. During discussions with
        operations personnel, the inspectors were informed that the MCRL database was not-
        utilized as the official restraint list because it was difficult to use and the information in the
        database did not include all of the mode restraints,
        in response to the inspectors' observations, the licensee reinttiated an effort to improve
        the identification and tracking of mode restraints._ Nevertheless, the inspectors -
        considered the inability to implement actions to improve the cumbersome processes of
        tracking mode restraints an example of the licensee's continued inability to implement
          effective corrective actions. Improvements in the corrective action program are being
          reviewed as part of the NRC's oversight of improvement initiatives at the facility,
  c.    Conclusions
                                                                                                              :
          Several problems were identified involving the mode restraint tracking system which
          included: condition reports and engineering evaluations which were not identified as
          mode restraints, condition reports and engineering evaluations which were classified as
          mode restraints but not trackert on a mode restraint list ineffective implementation of
          corrective actions for previously identified mode restraint issues, and multiple
          departmental tracking systems for mode restraints.
  01.3 Transfer of Shut Down Coolina Systems (71707)
        - On December 17,1997, the inspectors observed control room operators transfer
            shutdown cooling from RHR Train B to RHR Train A. Operations personnel appropriately                .
                                                                                                                '
            referenced procedures, acknowledged annunciators, and performed the transfer without
a
            any significant complications.-
  =01A Non Licensed Operator Tour (71707)
            On January S,1998, the inspectors accompanied a rion-licensed operator on tours of the
              containment, fuel, control, and auxiliary buildings during the performance of Procedure
              CPS 3800.02C001, "C-Area Daily Rounds." The auxiliary operator was knowledgeable of
              systems contained within the C-Area and provided good responses to questions asked by
              the inspectors involving equipment operation.
                                                        13
          . _ _ _ _ _ _ - _ _ _ _ _ _
 
                                                          _ _ _ _ _ _ _ _ _ _ _ _ _  _ _ _ - _ - _ _ _ - .
  4
    . 02    Operational Status of Foollities and Equipment
      02.1 Walkdown of Backuo Control Room Ventilation Fans
      a.    Inspection Scope (71707)
            The inspectors performed a walkdown of the altomate source of main control room
            ventilation which is utilized in the event of a station blackout,
      b.    Ooservations and Findinos
            On December 3,1997, the inspectors performed a walkdown of the altemate source of -
            main control room ventilation. The altemate source requires the installation of prestc.ged
            gasoline powered fans and ducting and the repositioning of MCR doors in accordance
                                                                                                            '
            with Procedure CPS 4200.01C001,"MCR Cooling During a SBO." The altemate
            ventilation source was originally rsquired to maintain MCR temperature betow 107"F at
            the end of a S80 event. However, during a subsequent engineering review in
            January 1996, the licensee determined that the altemate source would not be required
              and revised CPS Procedure 4200.01 to place gasoline powered fans in service only if
              temperatum reaches 107*F.
              The inspectors noted the foisowing discrepancies during the walkdown: (1) the incorrect
            - revision of Procedure 4200.010002, "DC Load Shedding During a 880" was located in -
              the 800' Turbine Building locker, (2) an uncontrolled copy of the vendor manual for the
              gasoline engines was located in the 800' Turbine Building locker, and (3) the vendor
              preventive maintenance recommendations for the gasoline engine were not being
              implemented.
,            The licensee initiated CRs 1-g7-12-087 and 197-12114, replaced the incorrect revision
              of CPS Procedure 4200.01C002, and commenced a review of the vendor recommended
              preventive maintenance items. The inspectors noted that the discrepancies were typical
              of previous NRC findings and that corrective actions were been developed as part of
              several restart initiatives to address concems with procedure quality, vendor manuals,
              and implementation of preventive maintenance items describe in technical manuals,
        c.    Conclusions
              Several discrepancies were noted during a walkdown of the attemate source of control
              room ventilation including; incorrect revisions of proceduies, uncantrolled vendor
                                                                                    '
              manuals, and a lack of implementation of vendor recommended preventive maintenance
              items.
                                                                                                              ,
                                                                                                            )
                                                          14
 
- - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ -
                                                                                        II. Maintenance
                    M1                              Conduct of Maintenance
                    M1.1 General Comments (62707 and 61726)
                                                      The inspectors observed or reviewed the following maintenance and surveillance
                                                      activities:
                                                      CPS Procedure #"3.40          Division til 4.16 KV Bus Under Voltage Relay (Degraded
                                                                                    Voltage) Functional Test"
                                                      CPS Procedi w        ; ,. 12  Neutron Monitor Detector testing
                                                      CPS Procedure 9061.03          VR!VQ Valve Operability
                                                                                                                                              .
                                                      Various MWRs involving 480 VAC Motor inspections
                        M1.2 Division 1114.16 KV Bus Under Voltaae Relev (Dearaded Voltaae) Functional Test (61726)
                                                      The inspectors observed the Division ill 4.16 KV Bus under voltage relay functional test
                                                      and concluded that maintenance personnel demonstrated good procedure usage in that
                                                      they reviewed each step prior to performance, exhibited good independent verification
                                                      techniques, were aware of the purpose of the surveillance test, and understood problems
                                                      which could be encountered if the surveillance was not successfully completed.
                          M1.3 Fix-It-Now Team                                                                                                ,
                                  a.                  Insoection Scope (62707)
                                                      The inspectors reviewed the licensee's implementation of the Fix-It-Now (FIN) process.
                                                      This included a review of applicable procedur3s and the Updated Safety Analysis Report
                                                      (USAR), interviews with various FIN team members, and observations of work performed
                                                      by the FIN team. The FIN team consisted of personnel from Operations, Clerical,
                                                      Maintenance Planning, Radiation Protection, Control and Instrumentation, Electrical
                                                      Maintenance, and Mechanical Maintenance departments,
                                    b.                Observations and Findinas
                                                      The licensee implemented the FIN team in accordance with CPS Procedure 1029.03,
                                                        " Implementation of the FIN Process." One d;fference between the FIN team process and
                                                        the description in the procedure involved the experience of the FIN team leader (FTL).
                                                        CPS Procedure 1029.03 required the FTL to have experience as an on-shift senior
                                                        reactor operator, however, the current FTL had no such experience. The licensee had
                                                        submitted a request for a procedure change, however, the procedure revision had not
                                                        occurred since there was also a USAR change pending which regarded the FIN team.
                                                        The USAR stated that the FTL would report to the maintenance planning supervisor. The
                                                        USAR change would remove the responsibilities of FIN team oversight from the
                                                                                                  15
 
                        _ _ _ _ _ _ _ _ _ - - - _ _ - - .                          _
                                                                                                    ,
,
        maintenance planning supervisor and add them to the maintenance improvement team
        leader. Once this change request w'.s accepted, the procedure could be updated, and          3
        the FIN team would be adequately described in licensee documents. The inspectors
        verified that the licensea had submitted the appropriate revisions,
  c.  Conclusions
        The FIN team's work process was in accordance s ith licensee procedures.
  M1.4 480 Volt Motor inspections
  a.    Inspection Scope (62707)
        The inspectors reviewed the licensee's plans and implementation of the plans for
        480VAC motor removal, inspection, and reinstallation. The inspectors interviewed
        various personnelinvolved with the planning and implementation of these activities,
        reviewed various documents, and performed inspections of some of the motors after they
        had been disassembled.
  b.    Observations and Findinas
        On November 8,1997, the operations department declared all 480VAC motors inoperable
        when they determined that the motors could be degraded due to potential over greasing
          during maintenance activities. Excessive grease on the motor windings could result in
          motor damage from heat degradation. The licensee decided that 96 480V motors would
          be inspected for signs of over greasing. The scope of these inspections included
          disassembly, inspection, cleaning of each motor, replacing the bearings, and reinstalling
          the motor.
          On November 21, the licensee initiated work on the first motor,1VH01CA S.utdown
          Service Water Pump Room A Supply Fan) on an "at risk" basis. The licensee considered
          the activity to be "at risk" because several issues necessary to support motor reassembly
          had not been resolved. Specifically, replacement bearings had not been received, the
          bearii g supplier did not have an approved quality assurance program, and the initial
          lubrication method had not been estelished. The bearing parts were received on
5          November 24, the review of the beanng suppliers QA program was completed on
          December 1, and the initiallubrication method was approved on December 5.
          The inspectors were concamed that the licensee started work on a component without
          having appropriate reassembly instructions or the necessary parts. The inspectors
          cqnsidered the licensee's decision to begin work on equipment needed to support
          availability of the Divis;on i Shutdown Service Water Pump without having appropriate
          instructions or the necessary parts an example of non-conservative decision making. The
          inspectors noted that a delay in reassembly of the motor and restoring the pump to an
          operable status would have occurred had it not been for the identification of
          discrepancies requiring shipment of the motor to the vendor for inspection.
                                                          16
                                                            _ _ _ _ _ _ - _ _ _ _ .
 
  c.  Conclusions
        The inspectors noted that the licensee had not effectively planned work activities for the
        initial 480 volt motor inspection. Specifically, the licensee began work on the 1VH01CA
        motor without having the appropriate parts on site, without having all parts aporoved
        through an accredited quality assurance plogram, and without having a method for
        greasing the motor bearings prior to installation.
]
  M1.5 SRM Current to Voltece Testina
  a.    insoection Scope (62701)
        The inspectors reviewed the results of C&l maintenance activities on SRM A performed in
        accordame with CPS Procedure 8731.12, " Neutron Monitoring Detector Testing."
  b.    Observations and Findinas
        On December 2,1997, during the performance of current to voltage (t/V) testing on SRM
        A, C&l technicians stopped work to rearrange measuring and test equipment (M&TE).
        The last measurement taken prior to rearranging the test equipment was an input voltage
          of 300V, output voltage of 12mV, and output amperage 0.12 microamps.
        The C&l technicians unknowingly reconnected the test me,ter to a 120VAC power supply
        without installing an isolation transformer. The isolation transformer is used when
          connecting to an AC source to prevent ground noise from impacting the test results. The
          T st measurement taken after resuming testing indicated an approximate 50 fold increase
              'h an input voltage of 450, the output voltage was 575mV, and output amperage was
          b. d microamps). The C&l technicians performing the test did not question the significant
          rise in parameters and as such, did not note that the M&TE was improperty installed. The
          insoectors determined that the C&l technicians demonstrated a poor questioning attitude
          by . et determining the cause of the significant increase in parameters following the
          resumption of the maintenance activity. The inspectors noted that the licensee did not
          question the significant rise in parameters during their review of the event.
          When the C&l technicians raised the input voltage to 1000V, the control room indication
          for SRMs B, C, and D increased causing a short period alarm. The C&l technicians
          responded th t they were not the cause of the short period alarm when questioned by
          operations anc res umed testing. The C&l technicians increased voltage a second time
          and once again, the short period alarm annunciated in the main control room. The C&l
          technicians responded that they did not believe they were responsible and had operations
          personnel monitor SRM indication while they increased the input voltage a third time.
          Once again, SRM indication increased. Following the third increase operators dir6::ted
          that C&l technicians cease the maintenance activity. The inspectors determined that the
          C&l technicians demonstrated a second example of a poor questioning attitude b; not
          determining the cause of the increase in SRM B, C, and D, indications prior to resuming
          the maintenance activity.
                                                      17
 
                    . _
                                  _ _ ____ __ - _ _ _ _ _ _ _ _ _ _ _ _ - _                    _ _ _ _ _  _ _ _ _    -
      _ . .
    -
  _                                                                                                      _
  .
                    On December 12, engineering personnel determined that the increase in indication on
                    SRMs B, C, and D was attributed to the failure to install an isolation transformer between
                    the test meter and the 120VAC power supply. The lack of the isolation transformer
                    allowed noise generation from the ground path to be radiated from the unshielded
                    portions of the SRM A detector ceble to the other unshielded SRM detector cables.
                    CPS Procedure 8713.12, Section 8.3.3, "l/V Plot for SRMs," requires, in part, that an
                    isolation transformer be used if the test meter is powered from an AC source. The failure
                    to install the isolation transformer when connecting the test meter to a AC source is
                    considered a violation of TS 5.4.1. This licensee identified and corrected violation is
                    being treated as a non-cited violation consistent with Section Vll.B.1 of the NRC
                    Enforcement Policy (NCV 50 461/97025-03).
              c.    Conclusions
                    _ One example of a failure to follow procedures involving the installation of an isolation
                    transformer during testing of SRMs was identified. Two examples of a poor questioning -
                      attitude were identified which involved the continuance of a maintenance activity even
                      though there was an unexplained increase in test parameters and an unexplained
                      increase in main control room SRM indications.
              M7      Quality Assurance in Maintenance Activities
              M7.1 Material Manaaement and Procurement / Materials Quality Assurance Audit (62707) -
                        The licensee's quality assurance department performed an audit (Q38-97-15) of the              7
                        Material Management department and the Procurement / Materials department from
                        October 20, through November 7,1997. The inspectors noted that Quality Assurance
                        (QA) performed a thorough audit based on findings involving inadequacies in the receipt
                        inspection process and shelf life detemlinations. The inspectors determined that the
                        audit findings were indicative of improved performance in QA audits.
              M8'        Miscellaneous Maintenance issues (92902)
            - M8.1 (Closed) Licensee Event Report No. 50-461/96-008: Loose term!nal connection causes
                        reactor recirculation pumps to trip from fast to slow resulting in a manual scram. On
                        June 13,1996, control room operators received alarms indicating that both reactor
                          recirculation (RR) pumps had downshifted to slow speed due to sensing a falso Level 3          ,
                        signal on two RR low level trip units. The licensee initially developed corrective actions to
                          install special lugs at certain terminal points to allow easy installation of temporary
                          electrical test equipment. After further investigation, the licensee changed the corrective
                          actions to a revision of preventive maintenance work documents and briefings to
                          maintenance personnel. The inspectors considered the corrective actions appropriate for
                          this issue.
              M8.2- (Closed) Notice of Violation No. 50-461/97011-08: Failure h complete an impact matrix.
                          On May 14,1997, a C&l technician improperly lifted the leads between terminals
                          associated with the feedwater low trip unit and caused an unexpected run back of the "A"
                          RR flow control valve. The licensee evaluated the task, technical specification
                          surveillance procedures, and other PM tasks for systems which could significantly impact
                                                                            18
s
 
                                                  .              ..          .  . _ _ _
      .
    .        .
                                                                .
          _
                    plant operations. These procedures were annotated with waming statements which
                    indicated the !mpact on plant systems should steps in the procedure be deviated.
                    Training was performed for Cal technicians to ensure they understood the importance of
                    procedure adherence. Finally, the licensee installed electrical test and monitoring
                    equipment on certain electrical terminal points to ease the completion of preventive
                    maintenance. Th inspectors considered the corrective actions appropriate for this issue.
          . M8.3 (Closed) Licangp.e Event Report 97013-00: Failure to adequately verify no trips exist
                    during surveillance test results in inadvertent actuation of standby gas treatment system.
                    On May 8,1997, operations and maintenance personnel failed to establish and verify that
                    plant protective logic was in the appropriate condition, resulting in an inadvertent
                      actuation of the standby gas treatment system during a channel functional test c( process -
                      radiation Monitor PR006A. Corrective actions included revisions to plant procedures to
                    - require notifications to supervision if incorrect switch positions were observed and to
                      improve procedure clarity. The inspectors determined that the corrective actions were
                      sopropriate for this issue.
            M8.4 (Closed) Notice of Violation No. 50-461/97011-06: This violation was closed during
                      review of LER 97013.
            M8.5 (Closed) Notice of Violation No. 50-461/96009-07: Untimely Completion of Use History
                      Analysis (UHA). The inspectors reviewed Procedure CPS No.1512.01, " Calibration and
                      Control of Measuring and Test Equipment," and determined that the licensee had
                      incorporated the criterion to generate a condition report for any UHAs which are not
s                      generated in 21 dasys. A report of UHA's status was compiled weekly by a C&l technician,
                      with a copy provided to the C&l group leader for review. Yhe inspectors reviewed UHAs
                      which were required to be completed from January through November 1997, and noted
                    - that the majority of the UHAs were completed within 21 days, and those which were not
                      ccmpleted were documented in a condition report.
                      Quartetty assessments of UHAs were performed by C&I technicians. These
                      assessments constituted intemal audits of the measurement and test equipment (M&TE}
                      program, including a ininimum requirement to review completed UHA forms for accuracy
                      and completeness and to review a sample of completed MWRs for proper documentation
                      and M&TE usage. From these units, the licensee determined whether a supervisory
                      evaluation or a condition report needs to be issued. The inspectors considered the
                    - corrective actions appropriate for this issue.
              M8.6 (Closed) Notice of Violation No. 50 461/97011-09: Preconditioning of breakers. The
                      inspectors verified that procedures had been revised to ensure that field installed molded
                      case circuit breakers are not preconditioned prior to functional testing. The inspectors
                      considered the corrective actions appropriate for this issue.
.
                                                                    19
  .
        .
                        - _ _ _ _ _ _ _ _ _ _ _ _
 
                            --__--                                    _______ - __ - __      ____-__
  -
                        -          -
                                                Ill. Ennineerina
    E8-      Miscellaneous Engineering issues
    E8.1 -(Closed) Notice of Violation No. 50-461/95003-01a: Failure of Division 111 Emergency
              Diesel Generator Bearing Due to inadequate Lubrication, As part of the licensee's -
              corrective actions to prevent recurrence, Plant Manager's Standing Order (PMSO)- 078,
              " Plant Component Oil Consumption," was developed to track oil consumption for
          - permanent plant components between scheduled maintenance intervals to ensure that
              any chronic oil leaks or excessive oil consumption were identified and tracked.
          - The inspectors reviewed the implementation of PMSO-078 and determined that current
              practices for tracking and trending oil consumption were not meeting the intent of the -
c            corrective action. For example, PMSO-078 directs that an oil consumption form be
          -
              completed any time oil is added to a plant component outside of a scheduled -
              maintenance interval. The inspectors interviewed engineering and maintenance
              personnel and determined that the oil consumption forms were only being utilized by the
              operations department. Although maintenance personnel were allowed to add oil to plant
              components outside of a scheduled maintenance interval, they used a MWR or activated
                                                                                                        '
              a PM task to perform the oil addition. Due to the maintenance department's use of
              MWRs and PMs to add oil, the oil consumption form included in PMSO-078 was not
              completed. Engineering personnel stated that they were unsure how oil added via a PM
              or MWR was tracked but believed that the system engineers tracked the performance or
              PMs and MWRs for their respective systems.
              The inspectors were concemed that having two means of tracking oil consumption which
              were not all inclusive could result in the mis-identification of a chronic oil leak or
              excessive oil consumption. The inspectors discussed their concem with licensee :
            - management and were informed that changes would be made to ensure that any addition
              6f oil to a component would be tracked to verify there was not an increase in oil
              consumption.- Deficiencies in the licensee's equipment trending program have been
            - identified in previous NRC Inspection Reports and licensee asussments, improvements
            ' in the trending program will be reviewed as part of the NRC's oversight of licensee
              improvement initiatives.
    E8.2      (Closed) Notice of Violation No. 50-461/96015-05a: Failure to have appropriate ECCS
              response time testing acceptance criteria. The inspectors reviewed the safety evaluation
              and USAR change package developed in response to this violation and had no further
              concems.
    E8.3      (Closed) Notice of Violation No. 50-461/96015-05b: Failure to have safety evaluation for
-
              manual operation of the component cooling water (CCW) expansion tank. The inspectors
              reviewed safety evaluation 96-082 which documented the manual operation of the CCW
              expansion tank and had no concems. The licensee's co Tective actions for improving the
                10 CFR Part 50.56 safety evaluation program appeared appropriate.
                                                        20
 
                                                                                __ _ _ _ _ _ _ _ _ _ _ _ _
    f
  .
                                                    IV. Plant Support
      R4      Staff Knowledge and Performance in RP&C
      R4.1 : Imoroner Use of the Exit Portal MonbgIn
      a.    losendon Scope (71750)
              The inspectors performed routine observations of radiation worker practices upon _ ogress
              from radiologically controlled areas.                                                          ;
        b.    ObseNations and Findidas
              On December g, igg 7, prior to entering the control room from the radiologically controlled
              area (RCA), the inspectors observed a non-licensed operator (NLO) processing through
              the PCM-18. : The inspectors noted that the PCM-13 unit had a trouble light illuminated        >
              with a contaminated detector indication. The individual processed through the PCM-1B
              and received the " count clear-you may pass" signal. The NLO noted the inspectors
              obsewing the top of the detector, tsoticed the contaminated detector indication, but
              assumed that since the PCM 1B indicated that he was not contaminated, he could exit
              the radiologically controlled area (RCA). The inspectors contacted the radiation 1
              protection (RP) desk to determine whether individuals could process through tt,e PCM-1B
              with a contaminated detector. RP stated that the PCM-1B could not be used when a
              trouble light was illuminated.
            - The technician contacted the operations shift supervisor who discussed the improper use
              of the PCM-1B during the operations shift briefing. The NLO identified himself to the shift
              supervisor as the indivioual who had incorrectly processed through the monitor. - The -          ,
              inspectors interviewed the NLO and noted that he did not recall receiving training on
                appropriate actions for processing through a PCM 1B when it indicated a contaminated
                detector. Through a review of the Control of Radioactive Material Handbook, the
                inspectors noted that on Page 7-25, Step 2, under personnel contamination monitors,
                were the instructions, "Do not use the PCM if the TROUBLE light is illuminated." While
                this information was relayed to the NLO during radiation worker training, the individual did
                not recall loaming this information. The inspectors considered processing through a
                  PCM-1B with a contaminated detector annunciator an example of a poor questioning
                  attitude and poor awareness of plant indications by operations personnel.
,
          c.      Conclusions
                  Processing through a PCM-1B with a contaminated detector annunciator was an example
                  of a poor questioning attitude and poor awareness of plant indications ty operations
                  personnel.
      82          Status of Security Facilities and Equipment
      S2.1 - Liahtina Tour of Protect Area (71750)
                      No lighting deficiencies were noted during a tour of the protected area on December 29,
                  .1997.
                                                              21
s
      ..      _ _ _ _ _ _ _ . _ _ . . - -
 
    -
j                                                                                                4
  .
                                        V. Manaaement Meetinas
      X1    Exit Meeting Summary
      The inspectors presented the inspection results to members of licensee management at the
      conclusion of the inspection on January 22,1998. The licensee acknowledged the findings
      presented. The inspectors asked the licensee whether any materials examined during the  ,
                                                                                              '
      inspection should be considered proprietary. No proprietary information was identified.
      X3-    Management Meeting Summary
      On January 8,1998, NRC members of the Clinton Restart Panel met with lilinois Power
      management to discuss the development of the Plan For Excellence and engineering design
      reviews.
                                                                                                K
                                                      22
 
    .
                                              PERSONS CONTACTED
        Licensee
        W. MacFarland IV Chief Nuclear Officer
__
        G. Baker, Manager - Quality Assurance
J      - W. Bousquet, Director - Plant Support and Services
        J. Gruber, Director Corrective Action
  }    J. Hale, Director - Flanning & Scheduling
        B. Joyce, Assistant Plant Manager- Maintenance
        M. Lyon, Assistant Plant Manager- Operations
        R. Phares, Manager - Nuclear Safety and Performance improvement
        J. Place, Director- Plant Radiation and Chemistry
        W. Romberg, Assistant Vice President
        J. Sipek, Manager - Regulatory interface
        L. Wigley, Manager- Nuclear Station Engineering Department      d
  I
.
O
                                                          23
 
                                                                                                          - _ _ _ _
                                  INSPECTION PROCEDURES USED
  IP 37551: Engineering Observations
  IP 61726: Survelilance Observations
  IP 62707: Maintenance Observations                                                                              ,
  IP 71707: Plant Operations
  IP 71750: Plant Support
  IP 92902: Follow up . Mair.tenance
  IP 92903: Follow-up Engineering
                            ITEMS OPENtiD, CLOSED, AND DISCUSSED
  Opentd
  97025-01 VIO          Failure to implement required Tc actions for maintaining secondary
                        containment isolation capablF,.
2  97025-02 VIO          Failure to implement required TS actions for maintaining either the                          i
                        Division I or ilinverters.
    97025-03 NCV        Failure to install test meter isolation transformer.
    Closed
    96 008-00 LER        Loose terminal connection causes reactor recirculation F.u.nps to trip from
                        fast to slow resulting in operation in the restricted zone and manual scram.
    96006-07 VIO        Untimely Completion of Use History Analysis.
    9701106 VIO          Restoration of caution tag.
    9701108 VIO          Failure to complete an impact rnatrix.
    9701109 VIO          Pr(conditionirig of breakers.
    97013-00 LER          Failure to adequately verify no trips exist during surveillance test results in
                          inadvertent actuation cf standby gas treatment system.
    95003 01a V'"        Failure of Division lli EDG bearing due to inadequate lubrication,
    96015-05a VIO        Failure to have appropriate ECCS response time testing acceptance
                          criteria.
    96015 05b VIO        Failure to hr.ve safety evaluation for manual operation of the CCW
                          expansion tank.
,  97025-03 NCV          Failure to install test meter isolation transformer.
            _                                                                  _ _ _ .            =
                                                      24
 
    .
                                    t
                                                                                                  i
                                            LIST OF ACRONYMS USED
      CAL        Confirmatory Action Letter
      CCW        Component Cooling Water
      CFR        Code of Federal Regulations
      C&l  - Controls and Instrumentat!on
      CPS        Clinton Power Station
,      CR          Cor.dition Rorort
      FIN        Fix It Now
      FTL        FIN Team Leeder
      1/V        Current to Voltage
      LCO        Limiting Condition for Operation
      LER          Licensee Event Report .
      MCR          Main control Room
      MCRL        Mode Change Restrain List
      MWR          Maintenance Work Request
      M&TE        Measurement and Test Equipment
      NLO          Non Licensed Operator
      NRC          Nuclear Regulatory Commission
      NSED        Nuclear Station Engineering Department
      PMSO        Plant Managers Standing Order -
                                                                                                    '
      RCA          Radiologially Controlled Area
      RHR          Residual Heat Removal
      RP          Radiation Protection
      SBO          Station Blackout
      SRM          Source Range Monitor
F.    TS-          Technical Specification
        UHA        . Use History Analysis
        URI        Unresolved item .
        USAR        Updated Safety Anatysis Report
        VF          Fuel Building Ventilation
    -        =              _.. ==                                              =_
                                                                              25
  t-
              m.m.        m..          ..        .__.__._____a- _ _ _ . - _ _ _ _ __ _ _ _ . . _ _
}}

Latest revision as of 11:03, 20 December 2021

Insp Rept 50-461/97-25 on 971125-980122.Violations Noted. Major Areas Inspected:Operations,Engineering,Maint & Plant Support
ML20202H754
Person / Time
Site: Clinton Constellation icon.png
Issue date: 02/13/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202H744 List:
References
50-461-97-25, NUDOCS 9802230014
Download: ML20202H754 (25)


See also: IR 05000461/1997025

Text

_

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION 111

Docket No: 50-461

License No: NPF-S2

Report No: 50-461/97025(DRP)

Licensee: lilinois Power Company

.

Facility: Clinton F'ower Station

Location: Route 54 West

Clinton, IL 61727

Dates: November 25,1997 - January 22,1998

inspectors: T. W. Pruett, Senior Resident inspector

K. K. Stoedter, Resident inspector

K. N. Selburg, Radiation Specialist

D. E. Zemel, Illinois Department of Nudear Safety

Approved by: Thomas J. Kezak, Chief

Reactor Projects Branch 4

,

9802230014 900213 *

{DR ADOCK 05000461

PDR

.. _ _ _ - - _ _ _ _

-. _ - _ _ _ _ _ _ - - _ _ _ _ - - _ - _ _

,

.

EXECUTIVE SUMMARY

Clinton Power Station

NRC inspection Report No. 50-461/97025(DRP)

This inspection included aspects of licensee operations, engineering, maintenance, and plant

support. The report covers an eight-week period of resident inspection.

Operations

. One violation was identified due to the failure to implement required Technical

Specification actions to restore isolation capability to secondary containment penetrations

between October 18 and December 16. Additionally, on-shift operations personnel were

unfamiliar with how to implement licensing department guidance on acceptable

administrative contrels associated with Technical Specification 3.5.2.D.3.

(Section 01.1.b.1)

. One violation war, identified due to the failure to implement required Technical

Specification actions to restore either the Division I or 11 inverter to service. Specifically,

operations personnel failed to recognize that declaring all 480VAC motors inoperable

required an entry into Technbal Specification 3.8.8, " inverters-Shutdown."

(Section 01.1.b.2)

+ Fourteen examples of the faiivre of operations personnel to implement the Technical

Specifications since January 1996 were identified by NRC inspectors and/or the licensee.

The multiple failures represent a weakness in the ability to implement the requirements of

the Technical Specifications and a poor awareness of plant conditions which impact

Technical Specification requirements. (Section 01.1.b.3)

. The decision to continue work even though three out of four source range monitors

(SRMs) were exhibiting unexpected responses indicated a poor awareness of conditions

with the potential to impact Technical Specifications, and was an example of a poor

questioning attitude and oversight of maintenance activities by operations personnel.

(Section 01.'..b.4)

  • A 13-day delay in restoring SRMs to an operable status was an example of poor

awareness of plant conditions and a lack of operations personnelinvolvement in restoring

Technical Specification equipment to a fully operable status. The avoidable delay in

restoration resulted in an unnecessary entry into plant Technical Specification 3.3.1.2,

" Source Range Monitor Instrumentation." (Section 01.1.b.5)

  • Implementation of Technical Specifications for SRM channel functional testing was poor

in that operadons personnel were unable to initially explain the basis which allowed

tran:,fer of the reactor mode switch from shutdown to run. Additionally, operations

personnel did not document the applicable Special Operation Technical Specification

which allowed the deviation from the requirements of Technical Specification 3.3.1.2 prior

to man;pulating the reactor mode switch. (Section 01.1.b.5)

. The failure to notice or provide a reason for the abnormally low cooling water inlet and

outlet temperature indication associated with Rasidual Heat Removal (RHR) Heat

2

)

.

__ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . . . -

.

l

.

Exchanger A following a transfer of shutdown cooling was an example of poor awareness -

of plant indications by operations personnelin the c sin control room. (Section 01.1.b.6)

. The failure to notine or provide a reason for the abnormal vent velve position indication

associated with RHR Heat Exchanger A was an example of poor awareness of plant

Indications by operations personnel in the main control room. (Section 01.1.b.7)

-. The inability to explain the status of the normally operating fuel building ventilation system

was an example of poor awareness of plant conditions by operations persone.

(Section 01.1.b.8)-

. Several deficiencies were ident;fied involving the operations mode restraint tracking '

system, which included: condition reports and engineering evaluations which were not

identified as mode restraints; condition reports and engirieering evaluations which were -

classified as mode restraints but not tracked on a mode restraint list; ineffective

implementation of corrective actions for previously identified mode restraint issues; and

multiple departmer.tal tracking systems for mode restraints. (Section 01.2)

. During the transfer of shutdown cooling from RHR Train B to RHR Train A, r.,perations

personnel appropriately referenced procedures, acknowledged annunciators, and

performed the transfer without any significant complications. (Section 01.3)

-* An auxiliary operator was knowledgeable of systems and provided good respot'ses to

questions during a tour of the containment, fuel, control, and auxiliary buildings.

(Section 01.4) -

Several discrepancies were noted during a walkdown of the altemate source of control

room ventilation including: incorrect revisions of procedures, an uncontrolled vendor

manual, and a lack c,f implementation of vendor recommended preventive maintenance -

items.- (Section O2,1)

Maintenance

-. Maintenance personnel demonstrated good procedure usage during functional testing of -

the Division ill 4.its KV Bus under voltage relay in that they reviewed each step prior to

performance, exhibited good independent verification techniques, were aware of the

purpose of the surveillance test, and understood problems which could be encountered if

the surveillance was not successfully completed. (Section M1.2)

.. Maintenance personnel did not effectively plan work activities for the initial 480VAC motor

-

inspections in that work began on the Shutdown Service Water (SSW) Pump Room A

Supply Fan motor without having the appropriate parts on site, without having all parts .

approved through an accredited quality assurance program, and without having a method

,

.

for grossing the motor bearings prior to installation. (Section M1.4)

. One example of a non-cited violation was identified for the failure to follow procedures

invulving the installation of an isolation transformer riuring testing of SRMs. Two

'

examples of a poor questioning attitude were identified which involved the continuance of

a maintenance activity even though there was an unexplained increase in test parameters

and an unexplained increase in main control room SRM indications. (Section M1.5)

3

_ - - _ _

.

.

. 'An audit conducted by qualit/ assurance involving receipt inspections and shelf life

determinations identified several weaknesses in the material management program and

represented a continued improvement in the quality assurance organization's ability to

perform thorough evaluations. (Section M7.1)

Pla 4 Sucoort

,

i

.

One example of an individualincorrectly processing through a PCM-1B was identified.

(Section R4.1)

.

No deficiencies were noted during a lighting tour of the protected area. (Section S2.1)

,

)

4

_ ________

- _ __ _ __ _ - _ _ _ _ - _ _ _ - _ - _

-

?

.

Report Details

Summantol_PlanLRtatua

The plant remained shut down during the inspection period. Major activities included the removal

of sitt from the service water intake structures, a Division li olectrical bus outage, and the -

init!ation of team assignmes,ts for the licensee's Plan For Excellence. On January 6,1998, the

- licensee announced that a three-year contract had been signed, which would allow the facility to-

be managed by PECO Nuclear, a division of PECO Energy Company of Philadelphia,

l. Operations

01 Conduct of Operations

- 01.1 Operators' Awareness of Plant Conditions and Technical Specifications

a. Inspection Scoce (717.QI)

The inspectors performed frequent observations of control room activities and questioned

operations personnel on the statu2 of plant equipment, indications, and Technical

Specifications (TS). ,

l

b. Observations and Findinas

Several examples of poor awareness oi TS entry mditions or plant conditions by

operations personnel were identified which invu . _ the failure to verify that automatic -

containment isolation signals were operable, the automatic transfer of the Division 11

. Inverter, the impact of Source Range Monitor (SRM) Channel A maintenance on SRM

Channels B, C, and D, the performance of SRM channel functional testing, low cooling

water inlet and outlet temperature indications on RHR Heat Exchanger A, incorrect valve

position indication on RHR Heat Exchanger Vent Valves E12-R609B and E12 R608A, .

and the status of the Fuel Building Ventilation (VF) system,

b.1 Failure to Maintain Containment isolation Signal Operable

Technical Specification 3.5.2, Required Action D.3, specified that actions ce initiated to

. restore isolation capability in each secondary containment and secondary containment

bypass penetration flow path that was not isolated. The Bases for TS 3.5.2 stated that

secondary containment penetration isolation capability must be ensured by verifying at

least one isolation valve and associated instrumentation are OPERABLE or other

. acceptable administrative controls are in place to assure isolation capability for each

~ effected penetration. A description of what constitutes "other acceptable admhistrative

controls".was not provided in the TS Bases.

On November 26, due to the inability to maintain at least one isolation valve operable for

each effected penetration, licensing personnel provided the operations department with a

letter which specified the steps necessary to comply with "other acceptable administrative

controls," pursuant to TS 3.5.2.D.3 Bases. The letter required that operations personnel:

5

t.

_ __ _ __ __

-

_ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ - _ ___ -__ - -_

.

.

1. Maintain a list of secondary containment penetrations that

remain open,

~ 2. Idantify which of these penetrations are auto-closed upon

receipt of an isolation signal, and

3. In the event of an auto-Isolation signal, monitor the

response of these valves and take manual action to isolate

any penetrations that fail to close.

On December 17, the inspectors verified that a list of effected secondary containment

penetrations had been developed which identified those penetrations that auto-closed  ;

upon receipt of an isolation signal. The inspectors questioned on shift operations

personnel to determine which auto-isolation signals were required to be operable (e.g., all

secondary containment auto isolation signals or those isolation signals which pertained to

the valves being left open). The individuals questioned were not familiar with the auto-

- isolation signals which were required to be operable in order to comply with the

requirements for other administrative controls. The inspectors considered the

unfamiliarity with implementation of other acceptable administrative controls associated

with TS 3.5.2.D.3 an example of a poor questioning attitude and poor implementation of

the TS 3.5.2.D.3 requirements.

On December 18, after consultation with licensing personnel, operations personnel

determined that circuits associated with core alters'.lons, movement of irradiated fuel, and

operations with a potential for draining the reactor vessel, which also provided an auto-

isolatioti signal to secondary containment isolation valves that remained open, were

required to be operable. Additionally, operations personnel informed the inspectors that a

review of tests and surveillances for the associated auto-isolation circuits had been

performed to ensure operability of the required circuits.

On December 19, the inspectors independently verified the auto-isolation instruments

associated with valves which remained open and determined that the Containment

Building Fuel Transfer Pool Ventilati6n Plenum Radiation - High instruments were

inoperable because surveillance testing on Plant Radiation Ms. . ors 1-RIX-FR008A, -B,

-C, and -D were overdue. The 1-RIX-PR008 Monitors provided an auto-isolation signal to

Secondary Containment isolation Dampers 1VF04Y, " Fuel Building Supply Outboard

Isolation," 1VF06Y, " Fuel Building Supply Inboard Isolation," 1VF07Y, " Fuel Building

Exhaust inboard Isolation Damper," and 1VF09Y, " Fuel Building Exhaust Outboard

isolation Damper." Consequently, the auto-isolation capability of Dampers 1VF04Y, -6Y,

-Y, and -9Y were not maintained in accordance with the provisions establish for other

administrative controls pursuant to TS 3.5.2.D.3.

The inspectors performed a review of plant conditions and determined that as of

g September 2,1997, the licensee was required to maintain the auto-isolation circuity for

. the 1-RIX-PROO8 monitors operable. However, on October 18 operations personnel

unknowingly allowed the surveillance testing on the 1-RIX-PROO8 monitors to lapse

(exceed the 1.25 frequency). On December 16, operations personnel closed De opers

1VF04Y,- 6Y, -7Y, and -9Y in preparation for a Division ll electrica! bus outage. The

1-RIX-PROO8 monitors wero restored to an operable status on December 22, p'ar 'o

reopening Dampers 1VF04Y, -6Y,-7Y, and -9Y. The failure to implement requirst.

C

-

-. . - _ _ _ - - - - _ _ .

.

actions to restore isolation capability to secondary coretainme,rit penetrations between

October 18 and December 16, demonstrated a poor awareness of plant systems and is a

violation of TC 3.5.2.D.3 (VIO 50 46119702541).

- b.2 ' Failure to Recognize T8 Conditions for inoperable inverters

On December 25,1997, at 12:45 p.m., operations oorsonnel received an annunciator due

to the Division 11 Nuclear Steam Protection System Inverter transferring from its normal to

its attemate power supply. Both operations and electrical maintenance personnel

responded, but were unable to determine the cause of the inverter transfer.

Subsequently, operations personnel considered the invertor inoperable.

On December 28, at 8:30 p.m., operations personnel made an entry into the main control-

room logs which specified that as of 4:00 p.m. on December 28, TS Lim!iing Concluion for

' Operation (LCO) 3.8.8, " inverters-Shutdown," was entered due to the Division I and 11

inverters being inoperable.

The inspectors questioned operations personnel to de: ermine: (1) why th6 TS 3.8.8 entry

condition was not noted on December 25, and (2) following identification on

December 28, why didn't operations personnel specify the time of entry as 12:45 p.m. on

December 25. Operations personnel stated that they initially bsileved the required

actions to be taken in response to two inoperable inverters were adequately covcred by

TS 3.8.2, ?AC Sources - Shutdown" and TS 3.8.10, "Distribuilon - Shutdown." In addition,

multiple operating crews failed to recognize that the actions to be taken when the

Division I and 11 inverters were inoperable were clearty delineated in TS 3.8.8. Operations -

- personnel stateo that the date and time of entry on Cecember 28 had been based on

recognition of the Division ! inverter being inoperable and that + hey should have predated

- the LCO entry time to 12:45 p.m. on December 25.

On December 29, operations perso_nnel informed the inspectors that the Division I

inverter was inoperable because the 480VAC motor which supplied power to the inverter

room cooler was out of service due to motor over grossing concems. The inspectors ,

questioned operations personnel to determine why TS 3.0.8 hed not been entered on

November 8,1997, when the 480VAC motors for both the Division I and 11 inverter room

coolers were out of service since the inoperable room coolers resulted in both inverters -

being inoperable. After reviewing TS and other associated documentation, operations

personnel determined that they had missed entry into TS 3.8.8 when the 48"VAC motors

for the inverter room coolers were declared inoperable on November 8. As a result, the

required actions for TS 3.8.8 were not performed until 50 days after the inverters were

initially inoperable. The failure to recognize an entry into a condition prohibited by TS

demonstrated a poor awareness and questioning attitude by operations personnel.

Technical Specification 3.8.8, inverters - Shutdown, requ;res, in pari, that one divisional

inverter capable of supplying one division of the Division I or 11 onsite Class IE

uninterruptible AC bus electrical power distribution subsystems required by L.CO 3.8.10,

" Distribution Systems - Shutdown," shall be operable. With one or more required

divisional inverters inoperable, the LCO requires tnat actions be initiated to declare the

affected required features inoperable immediately or suspend core alterations, suspend i

handling of irradiated fuel assemblies in primary and secondary containment, suspenc;

operations with the potential to drain the vessel, and initiate actions to restore required

7

_ - _ - _ _ _ _ _ _ -

.-_- ---__ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ = _ _ _ _ _ - _ _ _ _ _ _ _ -

.

divisionallaverters to an operable status immediately. The inspectors determined that

the failure to implement the Required Actions of the associated Conditions for -

approximately 50 days a violation of TS 3.8.8 (VIO 50 461/9702542),

b.3 Adverse Trond involving implementation of T8

The inspectors noted that there have been multiple examples det m in NRC

inspection reports and Licensee Event Reports (LER) which involved inadequate

implementation of the TS. The following examples were previously noted by the

inspectors between the period of January 1996 and December 1997:

NRC Report 50-461/97022: Two examples of the failure to implement TS Required

- Actions involving immediate actions and attemate shut

uown cooling.

NRC Report 50-461/97015; One example involving the installation of a non qualified

portable battery charger to the Division 11 Battery.

NRC Report 50-461/96006: Two examples involving the plant not being placed in -

MODE 4 and not locking the mode switch in the refuel

position.

NRC Report 50-461/96005: Two examples involving control room ventilation and

reactor water cleanup room floor plugs.

'

LER 50-461/97011: One example involving the failure to verify breaker position

every seven days.

LER 50-461/97007: One example involving seismia qualification of circuit

breakers.

LER 50-461/97002: One example involving EDG testing.

LER 50-461/96019: One example involving surveillance testing of SRMs.

LER 50-461/96003: One example involving a breach of secondary containment.

. The inspectors noted that the mu4iple examples of inadequate TS implementation was an

adverse cendition which the licensee had not previously recognized. On January 5,1998,

the inspectors discussed the TS deficiencies with senior licensee personnel. In response

to the inspectors' concem, the licensee initiated condition report (CR) 198-01-059 on

January 7,1998, to document an adverse trend in TS awareness and implementation.

The Assistant Plant Manager- Operations stated that emergent training on TS, a review

- of existing TS applicable to the plant conditions, and discussions with shift supervisors

would be performed as an interim measure until a more thorough review could be

initiated.

-

8

. _ _ - _ _

___ _ _ _ _ -______ -_ _ _-_-

-t

4

b4 McIntenance on SRM Channel A

On December 2,1997, during preventive maintenance to perform current to voltage (1/V)

plots on SRM Channel A, the SRM Channel B, C, and D count rate increased and a short

period alarm annunciated in the main control room. Operations personnel questioned

control and instrumentation (C&l) personnel to deterrr.ine if the maintenance activity

caused the unexpected increase in count rates. C&l responded that they were not the -

cause of the increased counts end resumed work.

Upon resumption of the maintenance activity operations personnel observed a second

increase in count rate on SRM Channels B,_C, and D. Once again o; erations personnel

questioned C&l personnel regarding the impact of the SPM A activity on SRMs B, C, and

D. Again, C&I responded that they did not believe they were responsible, but

recommended that the test voltage be adjusted a third time on SRM A to check the

response on SRMs B, C. and D. As the test voltage was raised, operations personnel

noted an increase in the count rate on SRM Channels B, C, and D. Following the third

unexpected and unexplained increase in count rate, operations personnel directed that

C&l stop the work activity on SRM Channel A. _The inspectors considered the delay in

work stoppage until a third unexpected response occurred an example of poor

questioning attitude and overs;ght of maintenance activitie; by operations personnel.

On December 3, the inspectors questioned operations personnel to determine the

applicellity of SRM TS. Operations personnel stated that SRMs B, C, and D were

operable since the maintenance activity on SRM Channel A had been stopped. The -

inspectors questioned operations and engineering personnel to determine if the

operability review assessed whether or not adequate separation existed between the

SRM channels, given the unexpected and unexplained response on SRM Channels B, C,

and D. Engineering personnel discussed the issue with the vendor and were unable to

determine if adequate separation existed between the SRM Channels. Because the

response to SRM Channels B, C, and D was unexpected, and because engineering was

unable to determine if adequate separation existed between SRM Channels, operations

personnel declared all four channels of SRM inoperable and verified the required actions :

of TS 3.3.1.2, "Cource Range Monitor Instrumentation."

On December 10, engineering personnel completed an evaluation of the unexpected

response on SRMs 0, C, and D, and determined that the event was related to noise -

generation created due to the setting of the discriminator threshold level and improper -

I

isolelion of the 120 Vac power supply to the measuring and test equipmem (See

Section M1.5). Even though the licensee eventually demonsteated that adequate

e separation existed between the SRM channels, the inspectort. considered the lack of :

recognition of conditions with the potential to impact TS ari example of poor awaraness

and questioning attitude by operations personnel,

b.5 Channel Functionel Testing of SRMs

.

On December 22,1907, SRM Channels A, B, and C were inoperable end operations

personnel were imp'emeoting the required actions of TS 3.3.1.2 wnich rpecihd that witn

less than two operable SRM channels, fully insert all inv rtable control rodt and pkce the

N rentor mode switch in the shutdown position. SRM A was consbered inoperable

a

because operations personnel had allowed the channel functionc' test to Irpse on

S

,

l

!<

,

p

, ..g m_m_-_ _ __ __ _ _._ _ _ _ _ _ - - - -

_ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _

December 10. SRM B was considered inoperable because operations personnel had not

completed post maintenanca testing following maintenance completed on December 15.

SRM C was considered inoperable on December 22, due to uner.plained inteimittent

spiking. Prior to December 22, SRM C had been placed on the main control room

deficiency list due to intemdttent spiking.

- The licensee initially attempted to restore SRM C to service on December 23, prior to

performir4 testing on the remaining SRMs.- However, trouble shooting activities on

SRM C_ wore unsuccessful, and operations personnel decided to complete channel

functional testing on SetMs A, B, and D.

The inspectors questioned operations personnel to determine: (1) why testing had been

deferred to the point that an unnecessary entry into TS 3.3.1.2 was required, and (2) why

- reliance was placed on a suspect monitor to meet the TS 3.3.1.2 requirements for two

operable SRMs. Operations personnel stated that a lack of operations involvement in the

schMuling process resulted in an unacceptable delay in restoring SRMs to service in a ,

timstj manner. The inspectors considered the delay in restoring the SRMs to operable

status an example of poor awareness of plant conditions ared a lack of operations

involvemem in restoring TS equipment to a fully operable status.

During a review of the December 23 station logs, the inspectors noted a log entry at

12:35 p.m. which specified that SRM channel functional testing had commenced, that all

. rods were inserted, and that there were no core alterations in progress. The inspectors

noted that SRM channel functional testing required that the reactor mode switch be

placed in the run position, which was contrary to the TS 3.3.1.2 required action to

maintain the reactor mode switch in the shut down position.

The inspectors questionod on shift operations personnel to determine why it was

acceptable to transfer the reactor mode switch from the required position. Operations

personnel involved in the SRM channel functional testing were initially unable to explain .

the rational for transferring the reactor mode switch. Upon further review, operations

personnel stated that the actions taken were consistent with implementation of Special

'

Operations TS 3.10.2, " Reactor Mode Switch Interlock Testing," which allows transfer of

the reactor mode switch to other positions to allow testing provided all control rods

remain fully inserted in core cells containing one or more fuel assemblies; and no core

alterations are in progress.

.

The inspectors noted that the station logs indicated that tha control rods were fully

inserted and that no core alterations were in progress.' However, no entry had been

made specifying that the provisions of TS 3.10.2 were being invoked in order to perform 4

testing. Operations personnel acknowledged that an entry in the station log should have

been made which specified the applicable TS being utilized for the plant condition. The

r inspectors determined that implementation of the TS for SRM channel functional testing

by operations personnel was poor in that they were unable to initially explain the basis

- which allowed transfer of the reactor mode switch and because operations personnel did

not document the applicable TS prior to manipulating the reactor mode switch.

I

10

)'

y

.

.

I

b.6 Cooling Water Temperature Indication for Residual Heat Removal Heat Exchanger

On December 17, following the transfer from RHR B to RHR A, the inspectors noted that

the cooling water inlet and outlet temperature indications for RHR Heat Exchanger A were

, pegged low. On shift operations personnel questioned by the inspectors had not noticed '

the abnormal indication and were unable to provide an explanation for the low reading.

Operations personnel stated that the temperature indicators were typically not used since

a separate instrument for the parameter was normally referenced. The inspectors

considered the failure to notice or provide a reason for the abnormally lov/ Indication an

example of poor awareness of plant indications.

Approximately 30 minutes later, during subsequent discussions with operations

personnel, a reactor operator recalled that the cutlet temperature indicator may have

been a main control room deficiency. Through a search of MWR tags in a storage bin in

the control room and a review of the MWR database, the on shift operators were able to

= locate documentation which described the deficiency on the outlet temperature indication.-

The inlet temperature indication did not have a separate deficiency tag but was described

in the remarks section of the MWR database for the outlet temperature indication. The

inspectors noted that nothing existad on the contrd room panel to prompt the operators

of a main control room deficiency and a log of main control deficiencies was not

maintained in the control room (See Section 02.1).

b.7 RHR Heat Exchanger Vent Valve Position Indication -

The inspectors questioned operations personnel to determine why the main control room

valve position indication for RHR Heat Exchanger Vent Valves E12-R609B, and .

E12-R608A did not indicate full closed even though the valves were fully closed. j

-

E12-R609B indicated approximately 2 percent, and E12-R608A indicated approximately

5 percent open even though both valves were tagged in the fully closed position.

Operations personnel stated that the valve indications are not utilized and therefore the

discrepancy had not been noted or documentsd as a deficieacy. The inspectors

considered the lack of recognition of the inaccurate valve position indication an example

of poor questioning attitude and awareness of plant systems by operations personnel,

b.8 Status of Fuel Building Ventilation System

On Oncember 19,1997, on shift operations personnel noted an increase in fuel building

fire alarms due to the normal ventilation system being secured to support maintenance

involving the Division 11 bus outage. The inspectors questioned on shift operations

personnel to determine why the fuel building ventilation (VF) system was out of service

and received different reasons.-

The first individual stated that he was unsure why W was inoperative but speculated that

it was because sensing instruments powered from Division 11 were deenergized. The

second individual stated that there was only one train of VF which was powered from

Division ll.

11

_ _ _ _ _

- _ _ _ _ _ _ _ _ _ _ _ _ _

k

Upon further review, the inspectors detcrmined that the in' series VF system isolation

dampers are powered from both Division I and 11. Securing Division I or ll electrical

busses removes pnwer from the dampers which actuate to the fail close position. The

inspectors noted that Procedure CPS 3514.01C006, " Bus / Unit Sub outages,4160V Bus

(1 AP09E) Outage," required that the VF system be secured as a prerequisite.

Nevertheless, the inspectors determined that inability of on shift operations personnel to

explain the status of the normally operating VF system an example of poor awareness of

plant conditions.

'

c. Conclusions

The inspectors identified that since January 1996, on at least 14 occasions, operations

personnel failed to properly implement the TS. The multiple failures represent a

weakness in the licensee's ability to property implement the requirements of the TS and a -

poor of awareness of plant conditions which impact TS requirements,

Two violations involving the failure to impicment the TS associated witi1 secondary

containment and inverters were identified. Additionally, several examples of a poor

awareness of plant conditions and poor questioning attitude were identified, which

involved the performance of maintenance and testing on SRMs, the status of control

room indications for RHR heat exchanger temperature and valve position and the

- operational status of the fuel building ventilation system.

01.2 ' Trackina of Plant Mode Restraints

a. Inspection Scoce (71707)

The inspectors reviewed the program for tracking mode restraints to ensure that all items

'

had been entered into the mode change restraint list (MCRL) or ott'er appropriate tracking

method,

b. Observations and Findinos

The inspectors determined that the means for tracking condition reports or maintenance

work requests identified as mode restraints were inconsistent in addition, multiple lists

between the operations, planning,- engineering, and corrective action program

departments made retrievability and tracking of mode restraint items cumbersome. For

. example, at the inspector's request, the licensee identified at least 31 CRs which were

classified as mode restraints but were not listed in the official MCRL The inspectors

were also unable to cross reference severalitems between the system status file, the

MCRL, the shift supervisor restraint list, the corrective action review board restraint list,

= and the engineerhg list.

Because'of the cumbersome process, the inspectors reviewed CR 1-97-05-024, "Failura

to Propedy identify Mode Restraints," initiated May 2,1997, to determine the status of

corrective actions from previously identified deficiencies involving CRs which were either

not identified as mode restraints or were not in a tracking system. During the review of

the CR, the licensee noted that the informal processes were cumbersome, prone to

human error, and that tools needed to be developed to effectively and officiently track

mode restrs!nts. Examples of deficiencies included new mode restraints identified during

12

o - - _ _ _ _ - _ - _ .

- - _

,

- engineering reviews'which were not communicated to operators, shift supervisors and

shift resource managers, CRs which were incorrectly identified as not being a mode -

restraint, and engineering evaluations which identified mode restraints but were not .

specified on the MCRL

Corrective actions included revisions to procedures to improve awareness of mode

restraints and the development of a mode restraint database. During discussions with

operations personnel, the inspectors were informed that the MCRL database was not-

utilized as the official restraint list because it was difficult to use and the information in the

database did not include all of the mode restraints,

in response to the inspectors' observations, the licensee reinttiated an effort to improve

the identification and tracking of mode restraints._ Nevertheless, the inspectors -

considered the inability to implement actions to improve the cumbersome processes of

tracking mode restraints an example of the licensee's continued inability to implement

effective corrective actions. Improvements in the corrective action program are being

reviewed as part of the NRC's oversight of improvement initiatives at the facility,

c. Conclusions

Several problems were identified involving the mode restraint tracking system which

included: condition reports and engineering evaluations which were not identified as

mode restraints, condition reports and engineering evaluations which were classified as

mode restraints but not trackert on a mode restraint list ineffective implementation of

corrective actions for previously identified mode restraint issues, and multiple

departmental tracking systems for mode restraints.

01.3 Transfer of Shut Down Coolina Systems (71707)

- On December 17,1997, the inspectors observed control room operators transfer

shutdown cooling from RHR Train B to RHR Train A. Operations personnel appropriately .

'

referenced procedures, acknowledged annunciators, and performed the transfer without

a

any significant complications.-

=01A Non Licensed Operator Tour (71707)

On January S,1998, the inspectors accompanied a rion-licensed operator on tours of the

containment, fuel, control, and auxiliary buildings during the performance of Procedure

CPS 3800.02C001, "C-Area Daily Rounds." The auxiliary operator was knowledgeable of

systems contained within the C-Area and provided good responses to questions asked by

the inspectors involving equipment operation.

13

. _ _ _ _ _ _ - _ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - .

4

. 02 Operational Status of Foollities and Equipment

02.1 Walkdown of Backuo Control Room Ventilation Fans

a. Inspection Scope (71707)

The inspectors performed a walkdown of the altomate source of main control room

ventilation which is utilized in the event of a station blackout,

b. Ooservations and Findinos

On December 3,1997, the inspectors performed a walkdown of the altemate source of -

main control room ventilation. The altemate source requires the installation of prestc.ged

gasoline powered fans and ducting and the repositioning of MCR doors in accordance

'

with Procedure CPS 4200.01C001,"MCR Cooling During a SBO." The altemate

ventilation source was originally rsquired to maintain MCR temperature betow 107"F at

the end of a S80 event. However, during a subsequent engineering review in

January 1996, the licensee determined that the altemate source would not be required

and revised CPS Procedure 4200.01 to place gasoline powered fans in service only if

temperatum reaches 107*F.

The inspectors noted the foisowing discrepancies during the walkdown: (1) the incorrect

- revision of Procedure 4200.010002, "DC Load Shedding During a 880" was located in -

the 800' Turbine Building locker, (2) an uncontrolled copy of the vendor manual for the

gasoline engines was located in the 800' Turbine Building locker, and (3) the vendor

preventive maintenance recommendations for the gasoline engine were not being

implemented.

, The licensee initiated CRs 1-g7-12-087 and 197-12114, replaced the incorrect revision

of CPS Procedure 4200.01C002, and commenced a review of the vendor recommended

preventive maintenance items. The inspectors noted that the discrepancies were typical

of previous NRC findings and that corrective actions were been developed as part of

several restart initiatives to address concems with procedure quality, vendor manuals,

and implementation of preventive maintenance items describe in technical manuals,

c. Conclusions

Several discrepancies were noted during a walkdown of the attemate source of control

room ventilation including; incorrect revisions of proceduies, uncantrolled vendor

'

manuals, and a lack of implementation of vendor recommended preventive maintenance

items.

,

)

14

- - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ -

II. Maintenance

M1 Conduct of Maintenance

M1.1 General Comments (62707 and 61726)

The inspectors observed or reviewed the following maintenance and surveillance

activities:

CPS Procedure #"3.40 Division til 4.16 KV Bus Under Voltage Relay (Degraded

Voltage) Functional Test"

CPS Procedi w  ; ,. 12 Neutron Monitor Detector testing

CPS Procedure 9061.03 VR!VQ Valve Operability

.

Various MWRs involving 480 VAC Motor inspections

M1.2 Division 1114.16 KV Bus Under Voltaae Relev (Dearaded Voltaae) Functional Test (61726)

The inspectors observed the Division ill 4.16 KV Bus under voltage relay functional test

and concluded that maintenance personnel demonstrated good procedure usage in that

they reviewed each step prior to performance, exhibited good independent verification

techniques, were aware of the purpose of the surveillance test, and understood problems

which could be encountered if the surveillance was not successfully completed.

M1.3 Fix-It-Now Team ,

a. Insoection Scope (62707)

The inspectors reviewed the licensee's implementation of the Fix-It-Now (FIN) process.

This included a review of applicable procedur3s and the Updated Safety Analysis Report

(USAR), interviews with various FIN team members, and observations of work performed

by the FIN team. The FIN team consisted of personnel from Operations, Clerical,

Maintenance Planning, Radiation Protection, Control and Instrumentation, Electrical

Maintenance, and Mechanical Maintenance departments,

b. Observations and Findinas

The licensee implemented the FIN team in accordance with CPS Procedure 1029.03,

" Implementation of the FIN Process." One d;fference between the FIN team process and

the description in the procedure involved the experience of the FIN team leader (FTL).

CPS Procedure 1029.03 required the FTL to have experience as an on-shift senior

reactor operator, however, the current FTL had no such experience. The licensee had

submitted a request for a procedure change, however, the procedure revision had not

occurred since there was also a USAR change pending which regarded the FIN team.

The USAR stated that the FTL would report to the maintenance planning supervisor. The

USAR change would remove the responsibilities of FIN team oversight from the

15

_ _ _ _ _ _ _ _ _ - - - _ _ - - . _

,

,

maintenance planning supervisor and add them to the maintenance improvement team

leader. Once this change request w'.s accepted, the procedure could be updated, and 3

the FIN team would be adequately described in licensee documents. The inspectors

verified that the licensea had submitted the appropriate revisions,

c. Conclusions

The FIN team's work process was in accordance s ith licensee procedures.

M1.4 480 Volt Motor inspections

a. Inspection Scope (62707)

The inspectors reviewed the licensee's plans and implementation of the plans for

480VAC motor removal, inspection, and reinstallation. The inspectors interviewed

various personnelinvolved with the planning and implementation of these activities,

reviewed various documents, and performed inspections of some of the motors after they

had been disassembled.

b. Observations and Findinas

On November 8,1997, the operations department declared all 480VAC motors inoperable

when they determined that the motors could be degraded due to potential over greasing

during maintenance activities. Excessive grease on the motor windings could result in

motor damage from heat degradation. The licensee decided that 96 480V motors would

be inspected for signs of over greasing. The scope of these inspections included

disassembly, inspection, cleaning of each motor, replacing the bearings, and reinstalling

the motor.

On November 21, the licensee initiated work on the first motor,1VH01CA S.utdown

Service Water Pump Room A Supply Fan) on an "at risk" basis. The licensee considered

the activity to be "at risk" because several issues necessary to support motor reassembly

had not been resolved. Specifically, replacement bearings had not been received, the

bearii g supplier did not have an approved quality assurance program, and the initial

lubrication method had not been estelished. The bearing parts were received on

5 November 24, the review of the beanng suppliers QA program was completed on

December 1, and the initiallubrication method was approved on December 5.

The inspectors were concamed that the licensee started work on a component without

having appropriate reassembly instructions or the necessary parts. The inspectors

cqnsidered the licensee's decision to begin work on equipment needed to support

availability of the Divis;on i Shutdown Service Water Pump without having appropriate

instructions or the necessary parts an example of non-conservative decision making. The

inspectors noted that a delay in reassembly of the motor and restoring the pump to an

operable status would have occurred had it not been for the identification of

discrepancies requiring shipment of the motor to the vendor for inspection.

16

_ _ _ _ _ _ - _ _ _ _ .

c. Conclusions

The inspectors noted that the licensee had not effectively planned work activities for the

initial 480 volt motor inspection. Specifically, the licensee began work on the 1VH01CA

motor without having the appropriate parts on site, without having all parts aporoved

through an accredited quality assurance plogram, and without having a method for

greasing the motor bearings prior to installation.

]

M1.5 SRM Current to Voltece Testina

a. insoection Scope (62701)

The inspectors reviewed the results of C&l maintenance activities on SRM A performed in

accordame with CPS Procedure 8731.12, " Neutron Monitoring Detector Testing."

b. Observations and Findinas

On December 2,1997, during the performance of current to voltage (t/V) testing on SRM

A, C&l technicians stopped work to rearrange measuring and test equipment (M&TE).

The last measurement taken prior to rearranging the test equipment was an input voltage

of 300V, output voltage of 12mV, and output amperage 0.12 microamps.

The C&l technicians unknowingly reconnected the test me,ter to a 120VAC power supply

without installing an isolation transformer. The isolation transformer is used when

connecting to an AC source to prevent ground noise from impacting the test results. The

T st measurement taken after resuming testing indicated an approximate 50 fold increase

'h an input voltage of 450, the output voltage was 575mV, and output amperage was

b. d microamps). The C&l technicians performing the test did not question the significant

rise in parameters and as such, did not note that the M&TE was improperty installed. The

insoectors determined that the C&l technicians demonstrated a poor questioning attitude

by . et determining the cause of the significant increase in parameters following the

resumption of the maintenance activity. The inspectors noted that the licensee did not

question the significant rise in parameters during their review of the event.

When the C&l technicians raised the input voltage to 1000V, the control room indication

for SRMs B, C, and D increased causing a short period alarm. The C&l technicians

responded th t they were not the cause of the short period alarm when questioned by

operations anc res umed testing. The C&l technicians increased voltage a second time

and once again, the short period alarm annunciated in the main control room. The C&l

technicians responded that they did not believe they were responsible and had operations

personnel monitor SRM indication while they increased the input voltage a third time.

Once again, SRM indication increased. Following the third increase operators dir6::ted

that C&l technicians cease the maintenance activity. The inspectors determined that the

C&l technicians demonstrated a second example of a poor questioning attitude b; not

determining the cause of the increase in SRM B, C, and D, indications prior to resuming

the maintenance activity.

17

. _

_ _ ____ __ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ -

_ . .

-

_ _

.

On December 12, engineering personnel determined that the increase in indication on

SRMs B, C, and D was attributed to the failure to install an isolation transformer between

the test meter and the 120VAC power supply. The lack of the isolation transformer

allowed noise generation from the ground path to be radiated from the unshielded

portions of the SRM A detector ceble to the other unshielded SRM detector cables.

CPS Procedure 8713.12, Section 8.3.3, "l/V Plot for SRMs," requires, in part, that an

isolation transformer be used if the test meter is powered from an AC source. The failure

to install the isolation transformer when connecting the test meter to a AC source is

considered a violation of TS 5.4.1. This licensee identified and corrected violation is

being treated as a non-cited violation consistent with Section Vll.B.1 of the NRC

Enforcement Policy (NCV 50 461/97025-03).

c. Conclusions

_ One example of a failure to follow procedures involving the installation of an isolation

transformer during testing of SRMs was identified. Two examples of a poor questioning -

attitude were identified which involved the continuance of a maintenance activity even

though there was an unexplained increase in test parameters and an unexplained

increase in main control room SRM indications.

M7 Quality Assurance in Maintenance Activities

M7.1 Material Manaaement and Procurement / Materials Quality Assurance Audit (62707) -

The licensee's quality assurance department performed an audit (Q38-97-15) of the 7

Material Management department and the Procurement / Materials department from

October 20, through November 7,1997. The inspectors noted that Quality Assurance

(QA) performed a thorough audit based on findings involving inadequacies in the receipt

inspection process and shelf life detemlinations. The inspectors determined that the

audit findings were indicative of improved performance in QA audits.

M8' Miscellaneous Maintenance issues (92902)

- M8.1 (Closed) Licensee Event Report No. 50-461/96-008: Loose term!nal connection causes

reactor recirculation pumps to trip from fast to slow resulting in a manual scram. On

June 13,1996, control room operators received alarms indicating that both reactor

recirculation (RR) pumps had downshifted to slow speed due to sensing a falso Level 3 ,

signal on two RR low level trip units. The licensee initially developed corrective actions to

install special lugs at certain terminal points to allow easy installation of temporary

electrical test equipment. After further investigation, the licensee changed the corrective

actions to a revision of preventive maintenance work documents and briefings to

maintenance personnel. The inspectors considered the corrective actions appropriate for

this issue.

M8.2- (Closed) Notice of Violation No. 50-461/97011-08: Failure h complete an impact matrix.

On May 14,1997, a C&l technician improperly lifted the leads between terminals

associated with the feedwater low trip unit and caused an unexpected run back of the "A"

RR flow control valve. The licensee evaluated the task, technical specification

surveillance procedures, and other PM tasks for systems which could significantly impact

18

s

. .. . . _ _ _

.

. .

.

_

plant operations. These procedures were annotated with waming statements which

indicated the !mpact on plant systems should steps in the procedure be deviated.

Training was performed for Cal technicians to ensure they understood the importance of

procedure adherence. Finally, the licensee installed electrical test and monitoring

equipment on certain electrical terminal points to ease the completion of preventive

maintenance. Th inspectors considered the corrective actions appropriate for this issue.

. M8.3 (Closed) Licangp.e Event Report 97013-00: Failure to adequately verify no trips exist

during surveillance test results in inadvertent actuation of standby gas treatment system.

On May 8,1997, operations and maintenance personnel failed to establish and verify that

plant protective logic was in the appropriate condition, resulting in an inadvertent

actuation of the standby gas treatment system during a channel functional test c( process -

radiation Monitor PR006A. Corrective actions included revisions to plant procedures to

- require notifications to supervision if incorrect switch positions were observed and to

improve procedure clarity. The inspectors determined that the corrective actions were

sopropriate for this issue.

M8.4 (Closed) Notice of Violation No. 50-461/97011-06: This violation was closed during

review of LER 97013.

M8.5 (Closed) Notice of Violation No. 50-461/96009-07: Untimely Completion of Use History

Analysis (UHA). The inspectors reviewed Procedure CPS No.1512.01, " Calibration and

Control of Measuring and Test Equipment," and determined that the licensee had

incorporated the criterion to generate a condition report for any UHAs which are not

s generated in 21 dasys. A report of UHA's status was compiled weekly by a C&l technician,

with a copy provided to the C&l group leader for review. Yhe inspectors reviewed UHAs

which were required to be completed from January through November 1997, and noted

- that the majority of the UHAs were completed within 21 days, and those which were not

ccmpleted were documented in a condition report.

Quartetty assessments of UHAs were performed by C&I technicians. These

assessments constituted intemal audits of the measurement and test equipment (M&TE}

program, including a ininimum requirement to review completed UHA forms for accuracy

and completeness and to review a sample of completed MWRs for proper documentation

and M&TE usage. From these units, the licensee determined whether a supervisory

evaluation or a condition report needs to be issued. The inspectors considered the

- corrective actions appropriate for this issue.

M8.6 (Closed) Notice of Violation No. 50 461/97011-09: Preconditioning of breakers. The

inspectors verified that procedures had been revised to ensure that field installed molded

case circuit breakers are not preconditioned prior to functional testing. The inspectors

considered the corrective actions appropriate for this issue.

.

19

.

.

- _ _ _ _ _ _ _ _ _ _ _ _

--__-- _______ - __ - __ ____-__

-

- -

Ill. Ennineerina

E8- Miscellaneous Engineering issues

E8.1 -(Closed) Notice of Violation No. 50-461/95003-01a: Failure of Division 111 Emergency

Diesel Generator Bearing Due to inadequate Lubrication, As part of the licensee's -

corrective actions to prevent recurrence, Plant Manager's Standing Order (PMSO)- 078,

" Plant Component Oil Consumption," was developed to track oil consumption for

- permanent plant components between scheduled maintenance intervals to ensure that

any chronic oil leaks or excessive oil consumption were identified and tracked.

- The inspectors reviewed the implementation of PMSO-078 and determined that current

practices for tracking and trending oil consumption were not meeting the intent of the -

c corrective action. For example, PMSO-078 directs that an oil consumption form be

-

completed any time oil is added to a plant component outside of a scheduled -

maintenance interval. The inspectors interviewed engineering and maintenance

personnel and determined that the oil consumption forms were only being utilized by the

operations department. Although maintenance personnel were allowed to add oil to plant

components outside of a scheduled maintenance interval, they used a MWR or activated

'

a PM task to perform the oil addition. Due to the maintenance department's use of

MWRs and PMs to add oil, the oil consumption form included in PMSO-078 was not

completed. Engineering personnel stated that they were unsure how oil added via a PM

or MWR was tracked but believed that the system engineers tracked the performance or

PMs and MWRs for their respective systems.

The inspectors were concemed that having two means of tracking oil consumption which

were not all inclusive could result in the mis-identification of a chronic oil leak or

excessive oil consumption. The inspectors discussed their concem with licensee :

- management and were informed that changes would be made to ensure that any addition

6f oil to a component would be tracked to verify there was not an increase in oil

consumption.- Deficiencies in the licensee's equipment trending program have been

- identified in previous NRC Inspection Reports and licensee asussments, improvements

' in the trending program will be reviewed as part of the NRC's oversight of licensee

improvement initiatives.

E8.2 (Closed) Notice of Violation No. 50-461/96015-05a: Failure to have appropriate ECCS

response time testing acceptance criteria. The inspectors reviewed the safety evaluation

and USAR change package developed in response to this violation and had no further

concems.

E8.3 (Closed) Notice of Violation No. 50-461/96015-05b: Failure to have safety evaluation for

-

manual operation of the component cooling water (CCW) expansion tank. The inspectors

reviewed safety evaluation 96-082 which documented the manual operation of the CCW

expansion tank and had no concems. The licensee's co Tective actions for improving the

10 CFR Part 50.56 safety evaluation program appeared appropriate.

20

__ _ _ _ _ _ _ _ _ _ _ _ _

f

.

IV. Plant Support

R4 Staff Knowledge and Performance in RP&C

R4.1 : Imoroner Use of the Exit Portal MonbgIn

a. losendon Scope (71750)

The inspectors performed routine observations of radiation worker practices upon _ ogress

from radiologically controlled areas.  ;

b. ObseNations and Findidas

On December g, igg 7, prior to entering the control room from the radiologically controlled

area (RCA), the inspectors observed a non-licensed operator (NLO) processing through

the PCM-18. : The inspectors noted that the PCM-13 unit had a trouble light illuminated >

with a contaminated detector indication. The individual processed through the PCM-1B

and received the " count clear-you may pass" signal. The NLO noted the inspectors

obsewing the top of the detector, tsoticed the contaminated detector indication, but

assumed that since the PCM 1B indicated that he was not contaminated, he could exit

the radiologically controlled area (RCA). The inspectors contacted the radiation 1

protection (RP) desk to determine whether individuals could process through tt,e PCM-1B

with a contaminated detector. RP stated that the PCM-1B could not be used when a

trouble light was illuminated.

- The technician contacted the operations shift supervisor who discussed the improper use

of the PCM-1B during the operations shift briefing. The NLO identified himself to the shift

supervisor as the indivioual who had incorrectly processed through the monitor. - The - ,

inspectors interviewed the NLO and noted that he did not recall receiving training on

appropriate actions for processing through a PCM 1B when it indicated a contaminated

detector. Through a review of the Control of Radioactive Material Handbook, the

inspectors noted that on Page 7-25, Step 2, under personnel contamination monitors,

were the instructions, "Do not use the PCM if the TROUBLE light is illuminated." While

this information was relayed to the NLO during radiation worker training, the individual did

not recall loaming this information. The inspectors considered processing through a

PCM-1B with a contaminated detector annunciator an example of a poor questioning

attitude and poor awareness of plant indications by operations personnel.

,

c. Conclusions

Processing through a PCM-1B with a contaminated detector annunciator was an example

of a poor questioning attitude and poor awareness of plant indications ty operations

personnel.

82 Status of Security Facilities and Equipment

S2.1 - Liahtina Tour of Protect Area (71750)

No lighting deficiencies were noted during a tour of the protected area on December 29,

.1997.

21

s

.. _ _ _ _ _ _ _ . _ _ . . - -

-

j 4

.

V. Manaaement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on January 22,1998. The licensee acknowledged the findings

presented. The inspectors asked the licensee whether any materials examined during the ,

'

inspection should be considered proprietary. No proprietary information was identified.

X3- Management Meeting Summary

On January 8,1998, NRC members of the Clinton Restart Panel met with lilinois Power

management to discuss the development of the Plan For Excellence and engineering design

reviews.

K

22

.

PERSONS CONTACTED

Licensee

W. MacFarland IV Chief Nuclear Officer

__

G. Baker, Manager - Quality Assurance

J - W. Bousquet, Director - Plant Support and Services

J. Gruber, Director Corrective Action

} J. Hale, Director - Flanning & Scheduling

B. Joyce, Assistant Plant Manager- Maintenance

M. Lyon, Assistant Plant Manager- Operations

R. Phares, Manager - Nuclear Safety and Performance improvement

J. Place, Director- Plant Radiation and Chemistry

W. Romberg, Assistant Vice President

J. Sipek, Manager - Regulatory interface

L. Wigley, Manager- Nuclear Station Engineering Department d

I

.

O

23

- _ _ _ _

INSPECTION PROCEDURES USED

IP 37551: Engineering Observations

IP 61726: Survelilance Observations

IP 62707: Maintenance Observations ,

IP 71707: Plant Operations

IP 71750: Plant Support

IP 92902: Follow up . Mair.tenance

IP 92903: Follow-up Engineering

ITEMS OPENtiD, CLOSED, AND DISCUSSED

Opentd

97025-01 VIO Failure to implement required Tc actions for maintaining secondary

containment isolation capablF,.

2 97025-02 VIO Failure to implement required TS actions for maintaining either the i

Division I or ilinverters.

97025-03 NCV Failure to install test meter isolation transformer.

Closed

96 008-00 LER Loose terminal connection causes reactor recirculation F.u.nps to trip from

fast to slow resulting in operation in the restricted zone and manual scram.

96006-07 VIO Untimely Completion of Use History Analysis.

9701106 VIO Restoration of caution tag.

9701108 VIO Failure to complete an impact rnatrix.

9701109 VIO Pr(conditionirig of breakers.

97013-00 LER Failure to adequately verify no trips exist during surveillance test results in

inadvertent actuation cf standby gas treatment system.

95003 01a V'" Failure of Division lli EDG bearing due to inadequate lubrication,

96015-05a VIO Failure to have appropriate ECCS response time testing acceptance

criteria.

96015 05b VIO Failure to hr.ve safety evaluation for manual operation of the CCW

expansion tank.

, 97025-03 NCV Failure to install test meter isolation transformer.

_ _ _ _ . =

24

.

t

i

LIST OF ACRONYMS USED

CAL Confirmatory Action Letter

CCW Component Cooling Water

CFR Code of Federal Regulations

C&l - Controls and Instrumentat!on

CPS Clinton Power Station

, CR Cor.dition Rorort

FIN Fix It Now

FTL FIN Team Leeder

1/V Current to Voltage

LCO Limiting Condition for Operation

LER Licensee Event Report .

MCR Main control Room

MCRL Mode Change Restrain List

MWR Maintenance Work Request

M&TE Measurement and Test Equipment

NLO Non Licensed Operator

NRC Nuclear Regulatory Commission

NSED Nuclear Station Engineering Department

PMSO Plant Managers Standing Order -

'

RCA Radiologially Controlled Area

RHR Residual Heat Removal

RP Radiation Protection

SBO Station Blackout

SRM Source Range Monitor

F. TS- Technical Specification

UHA . Use History Analysis

URI Unresolved item .

USAR Updated Safety Anatysis Report

VF Fuel Building Ventilation

- = _.. == =_

25

t-

m.m. m.. .. .__.__._____a- _ _ _ . - _ _ _ _ __ _ _ _ . . _ _