ML073100335: Difference between revisions

From kanterella
Jump to navigation Jump to search
Created page by program invented by StriderTol
Created page by program invented by StriderTol
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:November 6, 2007Mr. Christopher M. CranePresident and Chief Nuclear Officer
{{#Wiki_filter:November 6, 2007
Mr. Christopher M. Crane
President and Chief Nuclear Officer
Exelon Nuclear
Exelon Nuclear
Exelon Generation Company, LLC
Exelon Generation Company, LLC
4300 Winfield Road
4300 Winfield Road
Warrenville, IL 60555SUBJECT:CLINTON POWER STATIONNRC INTEGRATED INSPECTION REPORT 05000461/2007004Dear Mr. Crane:
Warrenville, IL 60555
On September 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed anintegrated inspection at your Clinton Power Station. The enclosed report documents the
SUBJECT:       CLINTON POWER STATION
                NRC INTEGRATED INSPECTION REPORT 05000461/2007004
Dear Mr. Crane:
On September 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an
integrated inspection at your Clinton Power Station. The enclosed report documents the
inspection results, which were discussed on October 4, 2007, with Mr. F.A. Kearney and other
inspection results, which were discussed on October 4, 2007, with Mr. F.A. Kearney and other
members of your staff.This inspection examined activities conducted under your license as they relate to safety and tocompliance with the Commission's rules and regulations and with the conditions of your license.  
members of your staff.
This inspection examined activities conducted under your license as they relate to safety and to
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.Based on the results of this inspection, three self-revealed findings of very low safetysignificance (Green) were identified. All of these issues involved violations of NRC
personnel.
requirements. However, because of the very low safety significance and because they were
Based on the results of this inspection, three self-revealed findings of very low safety
significance (Green) were identified. All of these issues involved violations of NRC
requirements. However, because of the very low safety significance and because they were
entered into your corrective action program, the NRC is treating these violations as Non-Cited
entered into your corrective action program, the NRC is treating these violations as Non-Cited
Violations consistent with Section VI.A.1. of the NRC Enforcement Policy.If you contest the subject or severity of a Non-Cited Violation, you should provide a responsewithin 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Violations consistent with Section VI.A.1. of the NRC Enforcement Policy.
If you contest the subject or severity of a Non-Cited Violation, you should provide a response
within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555-0001; with copies to the Regional Administrator, Region III, 2443 Warrenv
20555-0001; with copies to the Regional Administrator, Region III, 2443 Warrenville Road,
ille Road,Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory
Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Clinton
Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Clinton
Power Station.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure, and your response (if any) will be available electronically for public inspection in the
Power Station.
C. Crane-2-NRC Public Document Room or from the Publicly Available Records (PARS) component ofNRC's document system (ADAMS), accessible from the NRC Web site at
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Sincerely,/RA/Mark A. Ring, ChiefBranch 1
enclosure, and your response (if any) will be available electronically for public inspection in the
Division of Reactor ProjectsDocket No. 50-461License No. NPF-62Enclosure:Inspection Report No. 05000461/2007004 w/Attachment: Supplemental Informationcc w/encl:Site Vice President - Clinton Power StationPlant Manager - Clinton Power Station
 
Regulatory Assurance Manager - Clinton Power Station
C. Crane                                     -2-
Chief Operating Officer
NRC Public Document Room or from the Publicly Available Records (PARS) component of
Senior Vice President - Nuclear Services
NRCs document system (ADAMS), accessible from the NRC Web site at
Vice President - Operations Support
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Vice President - Licensing and Regulatory Affairs
                                              Sincerely,
Manager Licensing - Clinton Power Station
                                              /RA/
Senior Counsel, Nuclear, Mid-West Regional Operating Group
                                              Mark A. Ring, Chief
Document Control Desk - Licensing
                                              Branch 1
Assistant Attorney General
                                              Division of Reactor Projects
Illinois Emergency Management Agency
Docket No. 50-461
State Liaison Officer, State of Illinois
License No. NPF-62
Chairman, Illinois Commerce Commission  
Enclosure:     Inspection Report No. 05000461/2007004
C. Crane-2-NRC Public Document Room or from the Publicly Available Records (PARS) component ofNRC's document system (ADAMS), accessible from the NRC Web site at
                w/Attachment: Supplemental Information
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Sincerely,/RA/Mark A. Ring, ChiefBranch 1
cc w/encl:     Site Vice President - Clinton Power Station
Division of Reactor ProjectsDocket No. 50-461License No. NPF-62Enclosure:Inspection Report No. 05000461/2007004 w/Attachment: Supplemental Informationcc w/encl:Site Vice President - Clinton Power StationPlant Manager - Clinton Power Station
              Plant Manager - Clinton Power Station
Regulatory Assurance Manager - Clinton Power Station
              Regulatory Assurance Manager - Clinton Power Station
Chief Operating Officer
              Chief Operating Officer
Senior Vice President - Nuclear Services
              Senior Vice President - Nuclear Services
Vice President - Operations Support
              Vice President - Operations Support
Vice President - Licensing and Regulatory Affairs
              Vice President - Licensing and Regulatory Affairs
Manager Licensing - Clinton Power Station
              Manager Licensing - Clinton Power Station
Senior Counsel, Nuclear, Mid-West Regional Operating Group
              Senior Counsel, Nuclear, Mid-West Regional Operating Group
Document Control Desk - Licensing
              Document Control Desk - Licensing
Assistant Attorney General
              Assistant Attorney General
Illinois Emergency Management Agency
              Illinois Emergency Management Agency
State Liaison Officer, State of Illinois
              State Liaison Officer, State of Illinois
Chairman, Illinois Commerce CommissionDOCUMENT NAME:C:\FileNet\ML073100335.wpd
              Chairman, Illinois Commerce Commission
G Publicly Available
 
G Non-Publicly Available
C. Crane                                                                 -2-
G Sensitive
NRC Public Document Room or from the Publicly Available Records (PARS) component of
G Non-SensitiveTo receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copyOFFICERIIIRIIIRIIIRIIINAMEM. Ring for B. DicksonM. RingDATE11/05/200711/06/2007OFFICIAL RECORD COPY  
NRCs document system (ADAMS), accessible from the NRC Web site at
Letter to C. Crane from M. Ring dated November 6, 2007SUBJECT:CLINTON POWER STATIONNRC INTEGRATED INSPECTION REPORT 05000461/2007004DISTRIBUTION
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
:TEB
                                                                          Sincerely,
                                                                          /RA/
                                                                          Mark A. Ring, Chief
                                                                          Branch 1
                                                                          Division of Reactor Projects
Docket No. 50-461
License No. NPF-62
Enclosure:               Inspection Report No. 05000461/2007004
                            w/Attachment: Supplemental Information
cc w/encl:               Site Vice President - Clinton Power Station
                          Plant Manager - Clinton Power Station
                          Regulatory Assurance Manager - Clinton Power Station
                          Chief Operating Officer
                          Senior Vice President - Nuclear Services
                          Vice President - Operations Support
                          Vice President - Licensing and Regulatory Affairs
                          Manager Licensing - Clinton Power Station
                          Senior Counsel, Nuclear, Mid-West Regional Operating Group
                          Document Control Desk - Licensing
                          Assistant Attorney General
                          Illinois Emergency Management Agency
                          State Liaison Officer, State of Illinois
                          Chairman, Illinois Commerce Commission
DOCUMENT NAME:C:\FileNet\ML073100335.wpd
G Publicly Available                       G Non-Publicly Available                 G Sensitive             G Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE            RIII                                RIII                          RIII                                RIII
NAME              M. Ring for                         M. Ring
                    B. Dickson
DATE              11/05/2007                          11/06/2007
                                                          OFFICIAL RECORD COPY
 
Letter to C. Crane from M. Ring dated November 6, 2007
SUBJECT:       CLINTON POWER STATION
              NRC INTEGRATED INSPECTION REPORT 05000461/2007004
DISTRIBUTION:
TEB
RAG1
RAG1
SPS1
SPS1
MMT
MMT
RidsNrrDirsIrib
RidsNrrDirsIrib
MAS
MAS
KGO
KGO
JKH3
JKH3
RML2
RML2
SAM9
SAM9
SRI Clinton  
SRI Clinton
 
CAA1
CAA1
LSL (electronic IR's only)
LSL (electronic IRs only)
C. Pederson, DRP (hard copy - IR's only)
C. Pederson, DRP (hard copy - IRs only)
DRSIII
DRSIII
DRPIII
DRPIII
PLB1
PLB1
TXN
TXN
ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)  
ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)
EnclosureU.S. NUCLEAR REGULATORY COMMISSIONREGION IIIDocket No:50-461License No:NPF-62Report No:05000461/2007004
 
Licensee:AmerGen Energy Company, LLC
          U.S. NUCLEAR REGULATORY COMMISSION
Facility:Clinton Power Station
                        REGION III
Location:Route 54 WestClinton, IL 61727Dates:July 1 through September 30, 2007
Docket No:               50-461
Inspectors:B. C. Dickson, Senior Resident InspectorD. Tharp, Resident Inspector
License No:             NPF-62
A. Barker, Senior Project Engineer
Report No:               05000461/2007004
J. McGhee, Reactor Engineer
Licensee:               AmerGen Energy Company, LLC
A. Koonce, Reactor Engineer
Facility:               Clinton Power Station
D. Melendez, Reactor Engineer
Location:               Route 54 West
M. Mitchell, Health PhysicistApproved by:Mark Ring, ChiefBranch 1
                        Clinton, IL 61727
Division of Reactor Projects  
Dates:                   July 1 through September 30, 2007
Enclosure 1SUMMARY OF FINDINGSIR 05000461/2007004, AmerGen Energy Company LLC, on 07/01/07 - 09/30/2007 ClintonPower Station, Event Follow-up.This report covers a three month period of baseline resident inspection and announcedbaseline inspection on radiation protection. The inspection was conducted by Region III
Inspectors:             B. C. Dickson, Senior Resident Inspector
inspectors and the resident inspectors. Three Green findings, involving Non-Cited Violations,
                        D. Tharp, Resident Inspector
were identified. The significance of most findings is indicated by their color (Green, White,
                        A. Barker, Senior Project Engineer
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination
                        J. McGhee, Reactor Engineer
Process" (SDP). Findings for which the SDP does not apply may be "Green" or be assigned a
                        A. Koonce, Reactor Engineer
severity level after NRC management review. The NRC's program for overseeing the safe
                        D. Melendez, Reactor Engineer
operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor
                        M. Mitchell, Health Physicist
Oversight Process," Revision 3, dated July 2000.
Approved by:             Mark Ring, Chief
A.Inspector-Identified and Self Revealing FindingsCornerstone: Barrier Integrity*Green. A performance deficiency involving a Non-Cited Violation of 10 CFR Part 50,Appendix B, Criterion IV, "Procurement Document Control," was self revealed following
                        Branch 1
receipt of laboratory results that showed that Division 1 control room ventilation system
                        Division of Reactor Projects
charcoal filter penetration values were higher than allowed by Clinton's Technical
                                                                  Enclosure
Specifications. This issue occurred because the licensee failed to establish properpurchase specifications for charcoal used in the control room ventilation system.  
 
Additionally, this issue led to Division 1 control room ventilation subsystem being
                                      SUMMARY OF FINDINGS
inoperable from May 9 through May 16, 2005, concurrent with the Division 2 control
IR 05000461/2007004, AmerGen Energy Company LLC, on 07/01/07 - 09/30/2007 Clinton
room ventilation subsystem being inoperable due to planned maintenance from
Power Station, Event Follow-up.
May 9 through May 14, 2005. Licensee corrective actions included entering the issue
This report covers a three month period of baseline resident inspection and announced
into the corrective action program, revising the charcoal purchase specifications, and
baseline inspection on radiation protection. The inspection was conducted by Region III
adding limitations to work orders to prevent scheduling work that could impact the
inspectors and the resident inspectors. Three Green findings, involving Non-Cited Violations,
operability of redundant systems.This issue was more than minor because it affected the objective of the Barrier Integritycornerstone of assuring that physical design barriers protect the public from radionuclide
were identified. The significance of most findings is indicated by their color (Green, White,
releases caused by accidents or events. Additionally, this issue is associated with the
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination
barrier performance attribute of maintaining Radiological Barrier functionality of the
Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a
control room. Failure to ensure adequate purchase specifications resulted in there
severity level after NRC management review. The NRCs program for overseeing the safe
being a period where both trains of control room ventilation were inoperable without the
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
knowledge of the operators. The issue was of very low safety significance because it
Oversight Process, Revision 3, dated July 2000.
only represented a degradation of the radiological barrier function provided for the
A.     Inspector-Identified and Self Revealing Findings
control room. (Section 4OA3.1)*Green. The inspectors identified a performance deficiency involving a Non-CitedViolation of Technical Specifications when the licensee failed to meet the required
        Cornerstone: Barrier Integrity
completion time for an action statement in Technical Specification 3.4.5. Specifically,
*       Green. A performance deficiency involving a Non-Cited Violation of 10 CFR Part 50,
Technical Specification 3.4.5 does not allow reactor coolant system pressure boundary
        Appendix B, Criterion IV, Procurement Document Control, was self revealed following
leakage and requires a shutdown to Mode 3 within 12 hours if pressure boundary  
        receipt of laboratory results that showed that Division 1 control room ventilation system
Enclosure 2leakage is discovered. Upon entry into the drywell following a shutdown of the reactoron June 19, 2007, the licensee discovered the existence of reactor coolant system
        charcoal filter penetration values were higher than allowed by Clintons Technical
pressure boundary leakage. Indications of the leakage had been discovered at 0433 on
        Specifications. This issue occurred because the licensee failed to establish proper
June 18, 2007, but the plant was not placed in Mode 3 until approximately 31 hours later
        purchase specifications for charcoal used in the control room ventilation system.
at 1125 on June 19, 2007. Licensee corrective actions included replacing the leaking
        Additionally, this issue led to Division 1 control room ventilation subsystem being
flexible hose, scheduling replacement of other flexible hoses, and establishing a
        inoperable from May 9 through May 16, 2005, concurrent with the Division 2 control
preventive maintenance replacement frequency for the flexible hoses.This issue was more than minor because operating with a degraded pressure boundaryaffected the reactor coolant system equipment and barrier performance attribute of the
        room ventilation subsystem being inoperable due to planned maintenance from
Barrier Integrity cornerstone, in that, reactor coolant system pressure boundary leakage
        May 9 through May 14, 2005. Licensee corrective actions included entering the issue
results in a reduction in the reasonable assurance that physical design barriers protect
        into the corrective action program, revising the charcoal purchase specifications, and
the public from radionuclide releases caused by accidents or events. The issue was of
        adding limitations to work orders to prevent scheduling work that could impact the
very low safety significance because the potential maximum size of the leak was well
        operability of redundant systems.
within the capability of the available mitigating equipment. The finding is related to the
        This issue was more than minor because it affected the objective of the Barrier Integrity
cross-cutting area of Human Performance (Decision Making) in that operators had
        cornerstone of assuring that physical design barriers protect the public from radionuclide
initially entered TS 3.4.5 for pressure boundary leakage, but later chose not to treat the
        releases caused by accidents or events. Additionally, this issue is associated with the
leakage as pressure boundary leakage, and treat it as unidentified leakage until the
        barrier performance attribute of maintaining Radiological Barrier functionality of the
actual location could be determined (H.1(b)). (Section 4OA3.2)*Green. A performance deficiency involving a Non-Cited Violation of 10 CFR Part 50Appendix B, Criteria V, "Instructions, Procedures, and Drawings," was self-revealed
        control room. Failure to ensure adequate purchase specifications resulted in there
following an event on August 17, 2007, where a spent fuel bundle being moved to a
        being a period where both trains of control room ventilation were inoperable without the
temporary storage location came in contact with and rested upon another fuel bundle
        knowledge of the operators. The issue was of very low safety significance because it
seated in its storage location. The licensee procedure that governs spent fuel pool
        only represented a degradation of the radiological barrier function provided for the
movement failed to provide adequate guidance on how high to lift the fuel bundle prior to
        control room. (Section 4OA3.1)
traversing across the spent fuel pool. Licensee corrective actions included revising the
*       Green. The inspectors identified a performance deficiency involving a Non-Cited
fuel handling procedure to provide specific instructions regarding how high to lift a fuel
        Violation of Technical Specifications when the licensee failed to meet the required
bundle during spent fuel pool movements.This issue was more than minor because it affected the barrier integrity objective ofassuring that physical design barriers protect the public from radionuclide releases
        completion time for an action statement in Technical Specification 3.4.5. Specifically,
caused by accidents or events. The inspectors determined that this issue only degraded
        Technical Specification 3.4.5 does not allow reactor coolant system pressure boundary
the Fuel Cladding Barrier and its associated cornerstone, therefore, this issue was of
        leakage and requires a shutdown to Mode 3 within 12 hours if pressure boundary
very low safety significance. This finding is related to the cross-cutting area of Human
                                                  1                                      Enclosure
Performance (Resources) because the licensee did not provide complete and accurate
 
procedures. Specifically, the procedure relied on the skills of the operator, did not
  leakage is discovered. Upon entry into the drywell following a shutdown of the reactor
provided specific values on how high to lift a fuel bundle, and did not require
  on June 19, 2007, the licensee discovered the existence of reactor coolant system
independent verification (H.2(c)). (Section 4OA3.3)B.Licensee-Identified ViolationsNo findings of significance were identified.  
  pressure boundary leakage. Indications of the leakage had been discovered at 0433 on
Enclosure 3REPORT DETAILSSummary of Plant StatusThe plant was operated at approximately 96 to 97 percent rated thermal power (maintaining100 percent electrical output) throughout the inspection period with several derates of
  June 18, 2007, but the plant was not placed in Mode 3 until approximately 31 hours later
approximately 2-3 percent at the requests of the grid operator. The grid operator made those
  at 1125 on June 19, 2007. Licensee corrective actions included replacing the leaking
requests due to concerns regarding grid stability.Exceptions to relatively steady state operation occurred on July 1, 2007, when operatorslowered reactor power to approximately 82 percent to make repairs to an electrohydraulic
  flexible hose, scheduling replacement of other flexible hoses, and establishing a
  preventive maintenance replacement frequency for the flexible hoses.
  This issue was more than minor because operating with a degraded pressure boundary
  affected the reactor coolant system equipment and barrier performance attribute of the
  Barrier Integrity cornerstone, in that, reactor coolant system pressure boundary leakage
  results in a reduction in the reasonable assurance that physical design barriers protect
  the public from radionuclide releases caused by accidents or events. The issue was of
  very low safety significance because the potential maximum size of the leak was well
  within the capability of the available mitigating equipment. The finding is related to the
  cross-cutting area of Human Performance (Decision Making) in that operators had
  initially entered TS 3.4.5 for pressure boundary leakage, but later chose not to treat the
  leakage as pressure boundary leakage, and treat it as unidentified leakage until the
  actual location could be determined (H.1(b)). (Section 4OA3.2)
* Green. A performance deficiency involving a Non-Cited Violation of 10 CFR Part 50
  Appendix B, Criteria V, Instructions, Procedures, and Drawings, was self-revealed
  following an event on August 17, 2007, where a spent fuel bundle being moved to a
  temporary storage location came in contact with and rested upon another fuel bundle
  seated in its storage location. The licensee procedure that governs spent fuel pool
  movement failed to provide adequate guidance on how high to lift the fuel bundle prior to
  traversing across the spent fuel pool. Licensee corrective actions included revising the
  fuel handling procedure to provide specific instructions regarding how high to lift a fuel
  bundle during spent fuel pool movements.
  This issue was more than minor because it affected the barrier integrity objective of
  assuring that physical design barriers protect the public from radionuclide releases
  caused by accidents or events. The inspectors determined that this issue only degraded
  the Fuel Cladding Barrier and its associated cornerstone, therefore, this issue was of
  very low safety significance. This finding is related to the cross-cutting area of Human
  Performance (Resources) because the licensee did not provide complete and accurate
  procedures. Specifically, the procedure relied on the skills of the operator, did not
  provided specific values on how high to lift a fuel bundle, and did not require
  independent verification (H.2(c)). (Section 4OA3.3)
B. Licensee-Identified Violations
  No findings of significance were identified.
                                              2                                      Enclosure
 
                                        REPORT DETAILS
Summary of Plant Status
The plant was operated at approximately 96 to 97 percent rated thermal power (maintaining
100 percent electrical output) throughout the inspection period with several derates of
approximately 2-3 percent at the requests of the grid operator. The grid operator made those
requests due to concerns regarding grid stability.
Exceptions to relatively steady state operation occurred on July 1, 2007, when operators
lowered reactor power to approximately 82 percent to make repairs to an electrohydraulic
control system leak on the #4 main turbine control valve and on September 9, 2007, when
control system leak on the #4 main turbine control valve and on September 9, 2007, when
operators lowered reactor power of approximately 75 percent to perform control rod pattern
operators lowered reactor power of approximately 75 percent to perform control rod pattern
adjustments, quarterly main turbine valve testing and main steam isolation valve testing.1. REACTOR SAFETYCornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather Protection (71111.01)a.Inspection ScopeThe inspectors evaluated site readiness for severe thunderstorms prior to arrival of weather fronts associated with severe thunderstorms, high winds and rain that resulted
adjustments, quarterly main turbine valve testing and main steam isolation valve testing.
in severe thunderstorm and tornado watches being identified. On each occasion
1.     REACTOR SAFETY
operation's shift manning was verified to be adequate and in accordance with site
        Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity
procedures. Site walkdowns were performed to evaluate potential vulnerabilities for
1R01 Adverse Weather Protection (71111.01)
missile generation during high winds or tornados and to assess the implementation of
a.     Inspection Scope
the site procedures. The communications protocol between the control room and the
        The inspectors evaluated site readiness for severe thunderstorms prior to arrival of
transmission system operator was also reviewed during the inspections and examples of
        weather fronts associated with severe thunderstorms, high winds and rain that resulted
the quality of communication were observed due to severe weather conditions during
        in severe thunderstorm and tornado watches being identified. On each occasion
the inspection.This review represented two inspection samples of review prior to impending weatherconditions. b.FindingsNo findings of significance were identified.1R04Equipment Alignments (71111.04Q) a.Inspection ScopeThe inspectors performed partial walkdowns of accessible portions of divisions ofrisk-significant mitigating systems equipment during times when the divisions were of
        operations shift manning was verified to be adequate and in accordance with site
increased importance due to redundant divisions or other related equipment being  
        procedures. Site walkdowns were performed to evaluate potential vulnerabilities for
Enclosure 4unavailable. The inspectors utilized the valve and electric breaker checklists listed atthe end of this report to verify that the components were properly positioned and that
        missile generation during high winds or tornados and to assess the implementation of
support systems were lined up as needed. The inspectors also examined the material
        the site procedures. The communications protocol between the control room and the
condition of the components and observed operating parameters of equipment to verify
        transmission system operator was also reviewed during the inspections and examples of
that there were no obvious deficiencies. The inspectors reviewed outstanding work
        the quality of communication were observed due to severe weather conditions during
orders and issue reports (IRs) associated with the divisions to verify that those
        the inspection.
documents did not reveal issues that could affect division function. The inspectors used
        This review represented two inspection samples of review prior to impending weather
the information in the appropriate sections of the Updated Safety Analysis Report
        conditions.
(USAR) to determine the functional requirements of the systems. The documents listed
b.     Findings
at the end of this report were also used by the inspectors to evaluate this area.The inspectors performed two samples by verifying the alignment of the reactor coreisolation cooling system and the Division 1 standby gas treatment system while
        No findings of significance were identified.
Division 2 was out of service. b.FindingsNo findings of significance were identified.1R05Fire Protection (71111.05Q) a.Inspection ScopeThe inspectors conducted fire protection walkdowns which were focused on availability,accessibility, and the condition of fire fighting equipment, the control of transient
1R04 Equipment Alignments (71111.04Q)
combustibles and ignition sources, and on the condition and operating status of installed
a.     Inspection Scope
fire barriers. The inspectors selected fire areas for inspection based on their overall
        The inspectors performed partial walkdowns of accessible portions of divisions of
contribution to internal fire risk, as documented in the individual plant examination ofexternal events with later additional insights, and their potential to impact equipment
        risk-significant mitigating systems equipment during times when the divisions were of
which could cause a plant transient, to verify that fire hoses and extinguishers were in
        increased importance due to redundant divisions or other related equipment being
their designated locations and available for immediate use, that fire detectors and
                                                  3                                    Enclosure
sprinklers were not obstructed, that transient material loading was within the analyzed
 
limits, and that fire doors, dampers, and penetration seals appeared to be in satisfactory
    unavailable. The inspectors utilized the valve and electric breaker checklists listed at
condition. The inspectors verified that minor issues identified during the inspection were
    the end of this report to verify that the components were properly positioned and that
entered into the licensee's corrective action program.The inspectors reviewed portions of the licensee's fire protection evaluation report andthe USAR to verify consistency in the documented analysis with installed fire protection
    support systems were lined up as needed. The inspectors also examined the material
equipment at the station.The inspectors completed seven samples by inspection of the following areas:
    condition of the components and observed operating parameters of equipment to verify
*Fire Area D-5d, Division 1 diesel generator room;*Fire Area A-2b, Division 1 residual heat removal pump and heat exchangerroom;*Fire Area A-1, 707' auxiliary building, general access area;
    that there were no obvious deficiencies. The inspectors reviewed outstanding work
*Fire Area CB-1c, 719' control building, heating ventilation and air conditioningequipment area;*Fire loading and associated fire hazard permits in approved storage area;  
    orders and issue reports (IRs) associated with the divisions to verify that those
Enclosure 5*Fire Area A-2 and Fire Zone A-2a, reactor core isolation cooling pump room; and*Fire Area D-6a, b, Division 2 diesel generator and day tank room. b.FindingsNo findings of significance were identified.1R06Flood Protection Measures (71111.06) a.Inspection ScopeThe inspectors observed the flood protection equipment in the B and C residual heatremoval pump rooms. The inspectors verified that flooding mitigation plans and
    documents did not reveal issues that could affect division function. The inspectors used
equipment were consistent with the design requirements and risk analysis assumptions.  
    the information in the appropriate sections of the Updated Safety Analysis Report
The inspectors reviewed USAR Section 3.4.1 for internal flooding protection measures,
    (USAR) to determine the functional requirements of the systems. The documents listed
reviewed the licensee's flooding mitigation procedures, and reviewed issue reports
    at the end of this report were also used by the inspectors to evaluate this area.
related to possible flood protection issues. Additionally, plant walkdowns were
    The inspectors performed two samples by verifying the alignment of the reactor core
performed to verify design barriers were properly maintained. Penetrations between
    isolation cooling system and the Division 1 standby gas treatment system while
rooms, watertight doors, electrical conduit seals and covers, and room drains were
    Division 2 was out of service.
inspected to verify material condition met design assumptions. The inspectors
b. Findings
performed a review of the station's maintenance database to verify preventative
    No findings of significance were identified.
maintenance was current and equipment deficiencies were being appropriately reported
1R05 Fire Protection (71111.05Q)
and resolved. Additionally, the inspectors reviewed the maintenance rule scoping and
a. Inspection Scope
performance criteria and determined that the function was being tracked appropriately.  
    The inspectors conducted fire protection walkdowns which were focused on availability,
The corrective action program was also reviewed for the past 12 months for issues
    accessibility, and the condition of fire fighting equipment, the control of transient
related to internal flood protection. The inspectors completed a one inspection sample
    combustibles and ignition sources, and on the condition and operating status of installed
by completing the internal flooding review of the 'B' residual heat removal pump and
    fire barriers. The inspectors selected fire areas for inspection based on their overall
heat exchanger room and the 'C' residual heat removal pump room. b.FindingsNo findings of significance were identified.1R07Heat Sink Performance (71111.07A) a.Inspection ScopeThe inspectors verified readiness and availability of the Division 3 emergency dieselgenerator heat exchanger by performing the following activities:*Observed in-progress eddy current testing and reviewed post-eddy currenttesting results;*Observed the condition of heat exchanger end bell and tube sheet duringwalkdown;*Reviewed the results of tube inspections and outage work packages todetermine whether maintenance was performed in accordance with the
    contribution to internal fire risk, as documented in the individual plant examination of
licensee's maintenance program for heat exchangers and reviewed issue
    external events with later additional insights, and their potential to impact equipment
reports to verify that deficiencies were identified and incorporated into the
    which could cause a plant transient, to verify that fire hoses and extinguishers were in
licensee's corrective action program;  
    their designated locations and available for immediate use, that fire detectors and
Enclosure 6*Reviewed the evaluation and corrective actions for Action Request 678934,"Div III DG HX (1DG13A) Chemistry Results,"*Reviewed the evaluation and corrective actions for Action Request 675035,"Excessive Erosion Discovered on the Flange Faces 1VH03A," and*Verified the heat exchanger was properly classified under the MaintenanceRule and identified issues received appropriate program reviews.This inspection represented the completion of one annual sample. b.FindingsNo findings of significance were identified.1R11Licensed Operator Requalification (71111.11) a.Inspection ScopeThe inspectors observed an evaluation of an operating crew on September 19, 2007.
    sprinklers were not obstructed, that transient material loading was within the analyzed
The scenario (ESG LOR Exam 87d) consisted of a failure of the 'A' reactor recirculationflow control valve, a failure to scram using the manual pushbuttons, unisolable flooding
    limits, and that fire doors, dampers, and penetration seals appeared to be in satisfactory
in emergency core cooling system pump room and an emergency depressurization.The inspectors reviewed licensed-operator requalification training to evaluate operatorperformance in mitigating the consequences of a simulated event, particularly in the
    condition. The inspectors verified that minor issues identified during the inspection were
areas of Human Performance. The inspectors evaluated operator performance
    entered into the licensees corrective action program.
attributes which included communication clarity and formality, timely performance of
    The inspectors reviewed portions of the licensees fire protection evaluation report and
appropriate operator actions, appropriate alarm response, proper procedure use and
    the USAR to verify consistency in the documented analysis with installed fire protection
adherence, and senior reactor operator oversight and command and control.  
    equipment at the station.
Additionally, simulator physical fidelity and training department actions to incorporate
    The inspectors completed seven samples by inspection of the following areas:
current plant deficiencies and annunciators were evaluated.The inspectors also assessed the performance of the training staff evaluations involvedin the requalification process. For any weaknesses identified during the session, the
    *       Fire Area D-5d, Division 1 diesel generator room;
inspectors observed that the licensee evaluators also noted the issues and discussed
    *       Fire Area A-2b, Division 1 residual heat removal pump and heat exchanger
them in the critique at the end of the session. Discrepancies were reviewed with the
              room;
training staff. The inspectors verified that all issues were captured in the training
    *       Fire Area A-1, 707' auxiliary building, general access area;
program and licensee corrective action program.These activities completed one inspection sample. b.FindingsNo findings of significance were identified.  
    *       Fire Area CB-1c, 719' control building, heating ventilation and air conditioning
Enclosure 71R12Maintenance Effectiveness (71111.12)a.Inspection ScopeThe inspectors reviewed the effectiveness of the licensee's maintenance efforts inimplementing 10 CFR Part 50.65 (the maintenance rule (MR)) requirements, including a
              equipment area;
review of scoping, goal-setting, performance monitoring, short and long-term corrective
    *       Fire loading and associated fire hazard permits in approved storage area;
actions, and current equipment performance problems. These systems were selected
                                                4                                      Enclosure
based on their designation as risk-significant under the maintenance rule. The
 
inspectors also reviewed issue reports and associated documents for appropriate
    *       Fire Area A-2 and Fire Zone A-2a, reactor core isolation cooling pump room; and
identification of problems, entry into the corrective action system, and appropriateness
    *       Fire Area D-6a, b, Division 2 diesel generator and day tank room.
of planned or completed actions. The inspectors completed three samples by reviewing
b. Findings
the following:*Division 1 DC Battery and DC distribution;*Containment and reactor vessel isolation system and
    No findings of significance were identified.
*Reactor core isolation cooling system primary containment isolation valves.1R13Maintenance Risk Assessments and Emergent Work Control (71111.13) a.Inspection ScopeThe inspectors observed the licensee's risk assessment processes and considerationsused to plan and schedule maintenance activities on safety-related structures, systems,
1R06 Flood Protection Measures (71111.06)
and components particularly to ensure that maintenance risk and emergent work
  a. Inspection Scope
contingencies had been identified and resolved. The inspectors completed five  
    The inspectors observed the flood protection equipment in the B and C residual heat
samples by assessing the effectiveness of risk management activities for the following
    removal pump rooms. The inspectors verified that flooding mitigation plans and
work activities or work weeks:*Reviewed licensee risk assessment and subsequent area operator staging associated with standby liquid control system pump and valve quarterly
    equipment were consistent with the design requirements and risk analysis assumptions.
operability run;*Reviewed licensee's risk assessment and detailed work plan for reserve auxiliarytransformer static VAR compensator prior to the removal of test equipment;*Reviewed licensee risk assessment for planned surveillance on high pressurecore spray system;*Reviewed licensee risk assessment associated with six-year preventativemaintenance of the Division 3 diesel generator (including walkdown of risk
    The inspectors reviewed USAR Section 3.4.1 for internal flooding protection measures,
sensitive area to ensure proper flagging);*Reviewed the licensee's risk assessment of 138 kv line work by Ameren IP andsubsequent emergency reserve auxiliary transformer outage. b.FindingsNo findings of significance were identified.  
    reviewed the licensees flooding mitigation procedures, and reviewed issue reports
Enclosure 81R15Operability Evaluations (71111.15) a.Inspection ScopeThe inspectors reviewed the following operability determinations and evaluationsaffecting mitigating systems to determine whether operability was properly justified and
    related to possible flood protection issues. Additionally, plant walkdowns were
the component or system remained available such that no unrecognized risk increase
    performed to verify design barriers were properly maintained. Penetrations between
had occurred. The inspectors completed four samples of operability determinations and
    rooms, watertight doors, electrical conduit seals and covers, and room drains were
evaluations by reviewing the following:*Operability Evaluation 655836: Residual heat removal water leg pump supplycheck valves (1E12F084A and 1E12F085A) failure to close;*Operability Evaluation 630815-03: Division 1, 2, and 3 shutdown service watervalves (1SX025A, 1SX025B, and 1SX025C) exceed the vendor allowable
    inspected to verify material condition met design assumptions. The inspectors
deflection;*Action Request 667663: Through body leak of shutdown service water valve(1SX019B);*Action Request 660299: Type C Integrated leakage rate testing for test linesgoing through containment penetration 1MC-152 not being performed; *Operability Evaluation 664280: Through wall leak on shutdown service water line(1SX20AB); and *Operability Evaluation 671001: Division 3 essential switchgear/shutdown servicewater piping wall thickness below minimum screening criteria. b.FindingsNo findings of significance were identified.1R19Post-Maintenance Testing (71111.19) a.Inspection ScopeThe inspectors reviewed the post maintenance testing activities associated withmaintenance or modification of important mitigating, barrier integrity, and support
    performed a review of the stations maintenance database to verify preventative
systems that were identified as risk significant in the licensee's risk analysis. The
    maintenance was current and equipment deficiencies were being appropriately reported
inspectors reviewed these activities to verify that the post maintenance testing was
    and resolved. Additionally, the inspectors reviewed the maintenance rule scoping and
performed adequately, demonstrated that the maintenance was successful, and that
    performance criteria and determined that the function was being tracked appropriately.
operability was restored. During this inspection activity, the inspectors interviewed
    The corrective action program was also reviewed for the past 12 months for issues
maintenance and engineering department personnel and reviewed the completed post
    related to internal flood protection. The inspectors completed a one inspection sample
maintenance testing documentation. The inspectors used the appropriate sections of
    by completing the internal flooding review of the B residual heat removal pump and
the Technical Specifications (TS) and USAR, as well as the documents listed at the end
    heat exchanger room and the C residual heat removal pump room.
of this report, to evaluate this area.Testing subsequent to the following activities was observed and evaluated:
b. Findings
*Work Order 00318466: Troubleshooting and repair of Division 2, 250 Voltbattery charger (1DC07E);*Work Order 01048964-03: Post maintenance testing for optical isolator pair(manual scram push button) P664-A-A81-A313/A305;  
    No findings of significance were identified.
Enclosure 9*Work Order 00914954-03: Replacement of 1SX-303A;*Work Order 00909977-04: Replacement of standby gas treatment systempressure switches;*Work Order 00909977-02: Replacement of combustible gas control systempressure switch;*Work Order 00969911: Replacement of Division 1 main control room ventilationsupply fan; and*Reviewed post maintenance testing of Division 3 emergency diesel generatorfollowing six year maintenance.Performance of this review comprised seven samples. b.FindingsNo findings of significance were identified.1R22Surveillance Testing (71111.22) a.Inspection ScopeThe inspectors witnessed selected surveillance testing and/or reviewed test data toverify that the equipment tested using the surveillance procedures met the TS, the
1R07 Heat Sink Performance (71111.07A)
Technical requirements Manual (TRM), the USAR, and licensee procedural
  a. Inspection Scope
requirements, and demonstrated that the equipment was capable of performing its
    The inspectors verified readiness and availability of the Division 3 emergency diesel
intended safety functions. The activities were selected based on their importance in
    generator heat exchanger by performing the following activities:
verifying mitigating systems capability and barrier integrity. The inspectors used the
    *       Observed in-progress eddy current testing and reviewed post-eddy current
documents listed at the end of this report to verify that the testing met the frequency
            testing results;
requirements; that the tests were conducted in accordance with the procedures,
    *       Observed the condition of heat exchanger end bell and tube sheet during
including establishing the proper plant conditions and prerequisites; that the test
            walkdown;
acceptance criteria were met; and that the results of the tests were properly reviewed
    *       Reviewed the results of tube inspections and outage work packages to
and recorded. In addition, the inspectors interviewed operations, maintenance, and
            determine whether maintenance was performed in accordance with the
engineering department personnel regarding the tests and test results.Seven samples were completed.
            licensees maintenance program for heat exchangers and reviewed issue
The inspectors evaluated the following surveillance tests:
            reports to verify that deficiencies were identified and incorporated into the
*CPS 9069.01, Shutdown service water operability test pump 'B';*CPS 9000.01, Control room surveillance log and CPS 3315.02 Leak detection;
            licensees corrective action program;
*CPS 9051.01, High pressure core spray and water leg pump operability;
                                                5                                      Enclosure
*CPS 9052.01, Low pressure core spray and residual heat removal 'A' pumpswater leg pump operability;*CPS 9052.04, Low pressure core spray and residual heat removal 'A' vent andfill;*CPS 9054.01, Reactor core isolation cooling operability; and
 
*CPS 9080.02, Diesel generator '1B' operability - manual and quick startoperability.  
    *       Reviewed the evaluation and corrective actions for Action Request 678934,
Enclosure 10These tests included three in-service testing (IST) surveillance samples and one reactorcoolant system leakage detection surveillance sample. b.FindingsNo findings of significance were identified.1R23Temporary Plant Modifications (7111.23)The inspectors reviewed and evaluated the following temporary plant modification onrisk significant equipment to verify that the instructions were consistent with applicable
            Div III DG HX (1DG13A) Chemistry Results,
design modification documents and that the modifications did not adversely impact
    *       Reviewed the evaluation and corrective actions for Action Request 675035,
system operability or availability. The inspectors interviewed operations, engineering
            Excessive Erosion Discovered on the Flange Faces 1VH03A, and
and maintenance personnel, as appropriate, and reviewed the design modification
    *       Verified the heat exchanger was properly classified under the Maintenance
documents and the 10 CFR 50.59 evaluations against the applicable portions of the
            Rule and identified issues received appropriate program reviews.
USAR. The documents listed at the end of the report were also used by the inspectors
    This inspection represented the completion of one annual sample.
to evaluate this area. The inspectors reviewed the issues that the licensee entered into
b. Findings
its corrective action program to verify that identified temporary modification problems
    No findings of significance were identified.
were being entered into the program with the appropriate characterization and
1R11 Licensed Operator Requalification (71111.11)
significance. The inspectors also reviewed the licensee's corrective actions for
  a. Inspection Scope
temporary modification related issues documented in selected condition reports. The
    The inspectors observed an evaluation of an operating crew on September 19, 2007.
condition reports are specified in the List of Documents Reviewed.The inspectors completed one inspection sample by reviewing the following temporarymodification:*Defeating Inclined fuel transfer system upender/fuel handling platform Interlock,Revision 0. b.FindingsNo findings of significance were identified.2.EMERGENCY PREPAREDNESS
    The scenario (ESG LOR Exam 87d) consisted of a failure of the A reactor recirculation
1EP6Drill Evaluation (71114.06)a.Inspection ScopeThe inspectors observed the emergency response activities associated with the drillconducted on August 9, 2007. Specifically, the inspectors verified that the emergency
    flow control valve, a failure to scram using the manual pushbuttons, unisolable flooding
classification and simulated notifications were properly completed, and that the licensee
    in emergency core cooling system pump room and an emergency depressurization.
adequately critiqued the training. Additionally, the inspectors observed licensee
    The inspectors reviewed licensed-operator requalification training to evaluate operator
activities during the drill in the simulated control room and the Technical Support Center
    performance in mitigating the consequences of a simulated event, particularly in the
(TSC).The drill included an explosion in the Division 2 emergency diesel generator and asubsequent anticipated transient without a scram.  
    areas of Human Performance. The inspectors evaluated operator performance
Enclosure 11 b.FindingsNo findings of significance were identified.2.RADIATION SAFETYCornerstone: Occupational Radiation Safety2OS1Access Control to Radiologically Significant Areas (71121.01).1Review of Licensee Performance Indicators for the Occupational Exposure Cornerstone a.Inspection ScopeThe inspectors reviewed the licensee's Occupational Exposure Control cornerstoneperformance indicators (PIs) to determine whether or not the conditions surrounding the
    attributes which included communication clarity and formality, timely performance of
PIs had been evaluated, and identified problems had been entered into the corrective
    appropriate operator actions, appropriate alarm response, proper procedure use and
action program for resolution. These reviews represented one inspection sample. b.FindingsNo findings of significance were identified..2Plant Walkdowns and Radiation Work Permit Reviews a.Inspection ScopeThe inspectors reviewed licensee controls and surveys in the following two radiologicallysignificant work areas within radiation areas, high radiation areas and airborne
    adherence, and senior reactor operator oversight and command and control.
radioactivity areas in the plant and reviewed work packages which included associated
    Additionally, simulator physical fidelity and training department actions to incorporate
licensee controls and surveys of these areas to determine if radiological controls
    current plant deficiencies and annunciators were evaluated.
including surveys, postings and barricades were acceptable:*Spent fuel pool re-rack project; and*Phase separator resin transfer.These reviews represented one inspection sample.
    The inspectors also assessed the performance of the training staff evaluations involved
The inspectors reviewed the radiation work permits (RWP) and work packages used toaccess these two areas and other high radiation work areas to identify the work control
    in the requalification process. For any weaknesses identified during the session, the
instructions and control barriers that had been specified. Electronic dosimeter alarm set
    inspectors observed that the licensee evaluators also noted the issues and discussed
points for both integrated dose and dose rate were evaluated for conformity with survey
    them in the critique at the end of the session. Discrepancies were reviewed with the
indications and plant policy. Workers were interviewed to verify that they were aware of
    training staff. The inspectors verified that all issues were captured in the training
the actions required when their electronic dosimeters noticeably malfunctioned or
    program and licensee corrective action program.
alarmed. These reviews represented one inspection sample.The inspectors walked down and surveyed (using an NRC survey meter) these twoareas to verify that the prescribed radiation work permit, procedure, and engineering  
    These activities completed one inspection sample.
Enclosure 12controls were in place, that licensee surveys and postings were complete and accurate,and that air samplers were properly located. These reviews represented one inspection
  b. Findings
    No findings of significance were identified.
                                                6                                      Enclosure
 
1R12 Maintenance Effectiveness (71111.12)
a.   Inspection Scope
    The inspectors reviewed the effectiveness of the licensees maintenance efforts in
    implementing 10 CFR Part 50.65 (the maintenance rule (MR)) requirements, including a
    review of scoping, goal-setting, performance monitoring, short and long-term corrective
    actions, and current equipment performance problems. These systems were selected
    based on their designation as risk-significant under the maintenance rule. The
    inspectors also reviewed issue reports and associated documents for appropriate
    identification of problems, entry into the corrective action system, and appropriateness
    of planned or completed actions. The inspectors completed three samples by reviewing
    the following:
    *       Division 1 DC Battery and DC distribution;
    *       Containment and reactor vessel isolation system and
    *       Reactor core isolation cooling system primary containment isolation valves.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
  a. Inspection Scope
    The inspectors observed the licensees risk assessment processes and considerations
    used to plan and schedule maintenance activities on safety-related structures, systems,
    and components particularly to ensure that maintenance risk and emergent work
    contingencies had been identified and resolved. The inspectors completed five
    samples by assessing the effectiveness of risk management activities for the following
    work activities or work weeks:
    *       Reviewed licensee risk assessment and subsequent area operator staging
              associated with standby liquid control system pump and valve quarterly
              operability run;
    *       Reviewed licensees risk assessment and detailed work plan for reserve auxiliary
              transformer static VAR compensator prior to the removal of test equipment;
    *       Reviewed licensee risk assessment for planned surveillance on high pressure
              core spray system;
    *       Reviewed licensee risk assessment associated with six-year preventative
              maintenance of the Division 3 diesel generator (including walkdown of risk
              sensitive area to ensure proper flagging);
    *       Reviewed the licensees risk assessment of 138 kv line work by Ameren IP and
              subsequent emergency reserve auxiliary transformer outage.
b. Findings
    No findings of significance were identified.
                                                7                                    Enclosure
 
1R15 Operability Evaluations (71111.15)
  a. Inspection Scope
    The inspectors reviewed the following operability determinations and evaluations
    affecting mitigating systems to determine whether operability was properly justified and
    the component or system remained available such that no unrecognized risk increase
    had occurred. The inspectors completed four samples of operability determinations and
    evaluations by reviewing the following:
    *       Operability Evaluation 655836: Residual heat removal water leg pump supply
              check valves (1E12F084A and 1E12F085A) failure to close;
    *       Operability Evaluation 630815-03: Division 1, 2, and 3 shutdown service water
              valves (1SX025A, 1SX025B, and 1SX025C) exceed the vendor allowable
              deflection;
    *       Action Request 667663: Through body leak of shutdown service water valve
              (1SX019B);
    *       Action Request 660299: Type C Integrated leakage rate testing for test lines
              going through containment penetration 1MC-152 not being performed;
    *       Operability Evaluation 664280: Through wall leak on shutdown service water line
              (1SX20AB); and
    *       Operability Evaluation 671001: Division 3 essential switchgear/shutdown service
              water piping wall thickness below minimum screening criteria.
b.   Findings
    No findings of significance were identified.
1R19 Post-Maintenance Testing (71111.19)
a. Inspection Scope
    The inspectors reviewed the post maintenance testing activities associated with
    maintenance or modification of important mitigating, barrier integrity, and support
    systems that were identified as risk significant in the licensees risk analysis. The
    inspectors reviewed these activities to verify that the post maintenance testing was
    performed adequately, demonstrated that the maintenance was successful, and that
    operability was restored. During this inspection activity, the inspectors interviewed
    maintenance and engineering department personnel and reviewed the completed post
    maintenance testing documentation. The inspectors used the appropriate sections of
    the Technical Specifications (TS) and USAR, as well as the documents listed at the end
    of this report, to evaluate this area.
    Testing subsequent to the following activities was observed and evaluated:
    *       Work Order 00318466: Troubleshooting and repair of Division 2, 250 Volt
              battery charger (1DC07E);
    *       Work Order 01048964-03: Post maintenance testing for optical isolator pair
              (manual scram push button) P664-A-A81-A313/A305;
                                              8                                        Enclosure
 
    *       Work Order 00914954-03: Replacement of 1SX-303A;
    *       Work Order 00909977-04: Replacement of standby gas treatment system
              pressure switches;
    *       Work Order 00909977-02: Replacement of combustible gas control system
              pressure switch;
    *       Work Order 00969911: Replacement of Division 1 main control room ventilation
              supply fan; and
    *       Reviewed post maintenance testing of Division 3 emergency diesel generator
              following six year maintenance.
    Performance of this review comprised seven samples.
b. Findings
    No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
    The inspectors witnessed selected surveillance testing and/or reviewed test data to
    verify that the equipment tested using the surveillance procedures met the TS, the
    Technical requirements Manual (TRM), the USAR, and licensee procedural
    requirements, and demonstrated that the equipment was capable of performing its
    intended safety functions. The activities were selected based on their importance in
    verifying mitigating systems capability and barrier integrity. The inspectors used the
    documents listed at the end of this report to verify that the testing met the frequency
    requirements; that the tests were conducted in accordance with the procedures,
    including establishing the proper plant conditions and prerequisites; that the test
    acceptance criteria were met; and that the results of the tests were properly reviewed
    and recorded. In addition, the inspectors interviewed operations, maintenance, and
    engineering department personnel regarding the tests and test results.
    Seven samples were completed.
    The inspectors evaluated the following surveillance tests:
    *       CPS 9069.01, Shutdown service water operability test pump B;
    *       CPS 9000.01, Control room surveillance log and CPS 3315.02 Leak detection;
    *       CPS 9051.01, High pressure core spray and water leg pump operability;
    *       CPS 9052.01, Low pressure core spray and residual heat removal A pumps
              water leg pump operability;
    *       CPS 9052.04, Low pressure core spray and residual heat removal A vent and
              fill;
    *       CPS 9054.01, Reactor core isolation cooling operability; and
    *       CPS 9080.02, Diesel generator 1B operability - manual and quick start
              operability.
                                              9                                      Enclosure
 
    These tests included three in-service testing (IST) surveillance samples and one reactor
    coolant system leakage detection surveillance sample.
b. Findings
    No findings of significance were identified.
1R23 Temporary Plant Modifications (7111.23)
    The inspectors reviewed and evaluated the following temporary plant modification on
    risk significant equipment to verify that the instructions were consistent with applicable
    design modification documents and that the modifications did not adversely impact
    system operability or availability. The inspectors interviewed operations, engineering
    and maintenance personnel, as appropriate, and reviewed the design modification
    documents and the 10 CFR 50.59 evaluations against the applicable portions of the
    USAR. The documents listed at the end of the report were also used by the inspectors
    to evaluate this area. The inspectors reviewed the issues that the licensee entered into
    its corrective action program to verify that identified temporary modification problems
    were being entered into the program with the appropriate characterization and
    significance. The inspectors also reviewed the licensees corrective actions for
    temporary modification related issues documented in selected condition reports. The
    condition reports are specified in the List of Documents Reviewed.
    The inspectors completed one inspection sample by reviewing the following temporary
    modification:
    *       Defeating Inclined fuel transfer system upender/fuel handling platform Interlock,
              Revision 0.
  b. Findings
    No findings of significance were identified.
2.   EMERGENCY PREPAREDNESS
1EP6 Drill Evaluation (71114.06)
a.   Inspection Scope
    The inspectors observed the emergency response activities associated with the drill
    conducted on August 9, 2007. Specifically, the inspectors verified that the emergency
    classification and simulated notifications were properly completed, and that the licensee
    adequately critiqued the training. Additionally, the inspectors observed licensee
    activities during the drill in the simulated control room and the Technical Support Center
    (TSC).
    The drill included an explosion in the Division 2 emergency diesel generator and a
    subsequent anticipated transient without a scram.
                                                10                                    Enclosure
 
b. Findings
    No findings of significance were identified.
2.   RADIATION SAFETY
    Cornerstone: Occupational Radiation Safety
2OS1 Access Control to Radiologically Significant Areas (71121.01)
.1  Review of Licensee Performance Indicators for the Occupational Exposure Cornerstone
  a. Inspection Scope
    The inspectors reviewed the licensees Occupational Exposure Control cornerstone
    performance indicators (PIs) to determine whether or not the conditions surrounding the
    PIs had been evaluated, and identified problems had been entered into the corrective
    action program for resolution. These reviews represented one inspection sample.
  b. Findings
    No findings of significance were identified.
.2  Plant Walkdowns and Radiation Work Permit Reviews
  a. Inspection Scope
    The inspectors reviewed licensee controls and surveys in the following two radiologically
    significant work areas within radiation areas, high radiation areas and airborne
    radioactivity areas in the plant and reviewed work packages which included associated
    licensee controls and surveys of these areas to determine if radiological controls
    including surveys, postings and barricades were acceptable:
    *       Spent fuel pool re-rack project; and
    *       Phase separator resin transfer.
    These reviews represented one inspection sample.
    The inspectors reviewed the radiation work permits (RWP) and work packages used to
    access these two areas and other high radiation work areas to identify the work control
    instructions and control barriers that had been specified. Electronic dosimeter alarm set
    points for both integrated dose and dose rate were evaluated for conformity with survey
    indications and plant policy. Workers were interviewed to verify that they were aware of
    the actions required when their electronic dosimeters noticeably malfunctioned or
    alarmed. These reviews represented one inspection sample.
    The inspectors walked down and surveyed (using an NRC survey meter) these two
    areas to verify that the prescribed radiation work permit, procedure, and engineering
                                              11                                    Enclosure
 
    controls were in place, that licensee surveys and postings were complete and accurate,
    and that air samplers were properly located. These reviews represented one inspection
    sample.
    The inspectors reviewed RWPs for airborne radioactivity areas to verify barrier integrity
    and engineering controls performance (e.g., HEPA ventilation system operation) and to
    determine if there was a potential for individual worker internal exposures of greater
    than 50 millirem committed effective dose equivalent. No areas in the plant were
    airborne areas with a potential of greater than 5 millirem committed effective dose
    equivalent. Work areas having a history of, or the potential for, airborne transuranics
    were evaluated to verify that the licensee had considered the potential for transuranic
    isotopes and provided appropriate worker protection. The license has not had a history
    of transuranic contamination. These reviews represented one inspection sample.
    The adequacy of the licensees internal dose assessment process for internal exposures
    greater than 50 millirem committed effective dose equivalent was assessed. These
    reviews represented one inspection sample.
    The inspectors also reviewed the licensees physical and programmatic controls for
    highly activated and/or contaminated materials (non-fuel) stored within spent fuel or
    other storage pools. These reviews represented one inspection sample.
  b. Findings
    No findings of significance were identified.
.3  Problem Identification and Resolution
  a. Inspection Scope
    The inspectors reviewed the licensees self-assessments, audits, Licensee Event
    Reports, and Special Reports related to the access control program to verify that
    identified problems were entered into the corrective action program for resolution.
    These reviews represented one inspection sample.
    The inspectors reviewed seven corrective action reports related to access controls and
    high radiation area radiological incidents when available (non-PIs identified by the
    licensee in high radiation areas greater than 1R/hr). Staff members were interviewed
    and corrective action documents were reviewed to verify that follow-up activities were
    being conducted in an effective and timely manner commensurate with their importance
    to safety and risk based on the following:
    *        Initial problem identification, characterization, and tracking;
    *        Disposition of operability/reportability issues;
    *        Evaluation of safety significance/risk and priority for resolution;
    *        Identification of repetitive problems;
    *        Identification of contributing causes;
    *        Identification and implementation of effective corrective actions;
                                                12                                  Enclosure
 
    *      Resolution of Non-Cited Violations (NCVs) tracked in the corrective action
            system; and
    *      Implementation/consideration of risk significant operational experience feedback.
    These reviews represented one inspection sample.
    The inspectors evaluated the licensees process for problem identification,
    characterization, and prioritization and verified that problems were entered into the
    corrective action program and resolved. For repetitive deficiencies and/or significant
    individual deficiencies in problem identification and resolution, the inspectors verified
    that the licensees self-assessment activities were capable of identifying and addressing
    these deficiencies. These reviews represented one inspection sample.
    The inspectors reviewed licensee documentation packages for all PI events occurring
    since the last inspection to determine if any of these PI events involved dose rates
    greater than 25 R/hr at 30 centimeters or greater than 500 R/hr at 1 meter. Barriers
    were evaluated for failure and to determine if there were any barriers left to prevent
    personnel access. Unintended exposures greater than 100 millirem total effective dose
    equivalent (or greater than 5 rem shallow dose equivalent or greater than 1.5 rem lens
    dose equivalent), were evaluated to determine if there were any regulatory
    overexposures or if there was a substantial potential for an overexposure. There were
    no unintended exposures approaching 100 millirem. These reviews represented one
    inspection sample.
  b. Findings
    No findings of significance were identified.
.4  Job-In-Progress Reviews
  a. Inspection Scope
    The inspectors observed the following two work activities that were being performed in
    radiation areas, airborne radioactivity areas, or high radiation areas that presented the
    greatest radiological risk to workers:
    *      Spent fuel pool re-rack project; and
    *      Phase separator resin transfer.
    The inspectors reviewed radiological job requirements for these two activities including
    RWP requirements and work procedure requirements, and attended
    As-Low-As-Reasonably-Achievable (ALARA) job briefings. These reviews represented
    one inspection sample.
    Job performance was observed with respect to these requirements to verify that
    radiological conditions in the work area were adequately communicated to workers
    through pre-job briefings and postings. The inspectors also verified the adequacy of
    radiological controls including required radiation and contamination surveys; radiation
                                              13                                      Enclosure
 
    protection job coverage; and contamination controls. These reviews represented one
    inspection sample.
    Radiological work in high radiation work areas having significant dose rate gradients
    was reviewed to evaluate the application of dosimetry to effectively monitor exposure to
    personnel and to verify that licensee controls were adequate. These work areas
    involved areas where the dose rate gradients were severe (diving activities in the fuel
    pool re-rack project) which increased the necessity of providing multiple dosimeters.
    These reviews represented one-inspection sample.
  b. Findings
    No findings of significance were identified.
.5  High Risk Significant, High Dose Rate (HRA), and Very High Radiation Area Controls
  a. Inspection Scope
    The inspectors held discussions with the acting Radiation Protection Manager
    concerning high dose rate/high radiation area and very high radiation area controls and
    procedures, including procedural changes that had occurred since the last inspection, in
    order to verify that any procedure modifications did not substantially reduce the
    effectiveness and level of worker protection. These reviews represented one inspection
    sample.
    The inspectors discussed with RP supervisors the controls that were in place for special
    areas that had the potential to become very high radiation areas during certain plant
    operations, to determine if these plant operations required communication beforehand
    with the RP group, so as to allow corresponding timely actions to properly post and
    control the radiation hazards. These reviews represented one inspection sample.
    The inspectors conducted plant walkdowns to verify the posting and locking of
    entrances to high dose rate HRAs, and very high radiation. These reviews represented
    one inspection sample.
  b. Findings
    No findings of significance were identified.
.6  Radiation Worker Performance
  a. Inspection Scope
    During job performance observations, the inspectors evaluated radiation worker
    performance with respect to stated radiation protection work requirements and
    evaluated whether workers were aware of the significant radiological conditions in their
    workplace, the RWP controls and limits in place, and that their performance had
    accounted for the level of radiological hazards present. These reviews represented one
    inspection sample.
                                              14                                      Enclosure
 
    The inspectors reviewed radiological problem reports which found that the cause of the
    event was due to radiation worker errors to determine if there was an observable pattern
    traceable to a similar cause, and to determine if this perspective matched the corrective
    action approach taken by the licensee to resolve the reported problems. These
    problems, along with planned and taken corrective actions were discussed with the
    acting Radiation Protection Manager. These reviews represented one inspection
    sample.
  b. Findings
    No findings of significance were identified.
.7  Radiation Protection Technician Proficiency
  a. Inspection Scope
    During job performance observations, the inspectors evaluated Radiation Protection
    Technician (RPT) performance with respect to radiation protection work requirements
    and evaluated whether they were aware of the radiological conditions in their workplace,
    the RWP controls and limits in place, and if their performance was consistent with their
    training and qualifications with respect to the radiological hazards and work activities.
    These reviews represented one inspection sample.
    The inspectors reviewed radiological problem reports which found that the cause of the
    event was radiation protection technician error to determine if there was an observable
    pattern traceable to a similar cause, and to determine if this perspective matched the
    corrective action approach taken by the licensee to resolve the reported problems.
    These reviews represented one inspection sample.
  b. Findings
    No findings of significance were identified.
    Cornerstone: Public Radiation Safety
2PS2 Radioactive Material Processing and Transportation (71122.02)
.1  Radioactive Waste System
  a. Inspection Scope
    The inspectors reviewed the liquid and solid radioactive waste system descriptions in
    the Updated Final Safety Analysis Report (UFSAR), and the 2006 Annual Radioactive
    Effluent Release Report for information on the types and amounts of radioactive waste
    (radwaste) generated and disposed. The inspectors reviewed the scope of the
    licensees audit/self-assessment activities, with regard to radioactive material processing
    and transportation programs to determine if those activities satisfied the requirements of
                                              15                                      Enclosure
 
    10 CFR 20.1101(c) and the quality assurance audit requirements of Appendix G to
    10 CFR Part 20 and of 10 CFR 71.137, as applicable.
    These reviews represented one inspection sample.
  b. Findings
    No findings of significance were identified.
.2  Radioactive Waste System Walkdowns
  a. Inspection Scope
    The inspectors walked down portions of the liquid and solid radwaste processing
    systems to verify that these systems were consistent with the descriptions in the UFSAR
    and in the Process Control Program and to assess the material condition and operability
    of those systems. The inspectors reviewed the status of radioactive waste process
    equipment that was not operational and/or was abandoned in place. The inspectors
    discussed with the licensee the administrative and/or physical controls preventing the
    inadvertent use of this equipment to ensure that the equipment would not contribute to
    an unmonitored release path or be a source of unnecessary personnel exposure.
    The inspectors reviewed changes to the waste processing system to verify the changes
    were reviewed and documented in accordance with 10 CFR 50.59 and to assess the
    impact of the changes on radiation dose to members of the public. The inspectors
    reviewed the licensees processes for transferring waste resin into shipping containers
    to determine if appropriate waste stream mixing and sampling was performed so as to
    obtain representative waste stream samples for analysis. The inspector also reviewed
    the methodologies for waste concentration averaging to determine if representative
    samples of the waste product were provided for the purposes of waste classification in
    accordance with 10 CFR 61.55.
    These reviews represented one inspection sample.
  b. Findings
    No findings of significance were identified.
.3  Waste Characterization and Classification
  a. Inspection Scope
    The inspectors reviewed the licensees methods and procedures for determining the
    classification of radioactive waste shipments including the use of scaling factors to
    quantify difficult-to-measure radionuclides. The inspectors reviewed the licensees most
    recent radiochemical sample analysis results for each of the licensees waste streams,
    and the associated calculations used to account for difficult-to-measure radionuclides.
    These waste streams consisted of radwaste demineralizer resins, various filter media,
    and dry active waste (DAW). The inspectors also reviewed the licensees use of scaling
                                              16                                      Enclosure
 
    factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting
    radionuclides). The reviews were conducted to verify that the licensees program
    assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G
    of 10 CFR Part 20. The inspectors also reviewed the licensees waste characterization
    and classification program to determine if reactor coolant chemistry data was
    periodically evaluated to account for changing operational parameters that could
    potentially affect waste stream classification and thus validate the continued use of
    existing scaling factors between sample analysis updates.
    These reviews represented one inspection sample.
  b. Findings
    No findings of significance were identified.
.4  Shipment Preparation and Records
  a. Inspection Scope
    The inspectors reviewed the documentation of shipment packaging, surveying, package
    labeling and marking, vehicle inspections and placarding, emergency instructions, and
    licensee verification of shipment readiness for six selected non-excepted radioactive
    material and radwaste shipments, made between March 2006 and January 2007. The
    shipment documentation reviewed included:
    *    Equipment in a B-25 Box Shipped as Low Specific Activity (LSA);
    *    Two Spent Resins Shipped as Type A;
    *    Two Phase Separator Resins Shipped as Type A; and
    *    Part 61 Resin Samples Shipped as LSA.
    For each shipment, the inspectors determined if the requirements of 10 CFR Parts 20
    and 61 and those of the Department of Transportation (DOT) in 49 CFR Parts 170-189
    were met. Specifically, records were reviewed, and staff involved in shipment activities
    were interviewed to determine if packages were labeled and marked properly, if
    packages and transport vehicle surveys were performed with appropriate
    instrumentation, whether survey results satisfied DOT requirements, and if the quantity
    and type of radionuclides in each shipment were determined accurately. The inspectors
    also determined whether shipment manifests were completed in accordance with DOT
    and NRC requirements, if they included the required emergency response information, if
    the recipient was authorized to receive the shipment, and if shipments were tracked as
    required by 10 CFR Part 20.
    Selected staff involved in shipment activities were interviewed by the inspectors to
    determine if they had adequate skills to accomplish shipment related tasks and to
    determine if the shippers were knowledgeable of the applicable regulations to satisfy
    package preparation requirements for public transport with respect to NRC
    Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial.
    Also, the inspectors reviewed the transportation specific training for the authorized
    shippers to assure that they met the requirements of 49 CFR Part 172, Subpart H.
                                              17                                      Enclosure
 
      These reviews represented two inspection samples.
  b.  Findings
  (1) Shipment Total Quantity Re-characterized After Shipping
      A shipment of phase separator resins was shipped from Clinton Power Station
      September 30, 2005, and delivered to a vendor on October 1, 2005. The total curie
      quantity in the shipment was in excess of the vendors Agreement State license limits.
      The vendor communicated this discrepancy to shipping personnel at Clinton Power
      Station on October 3, 2005. The shipper then re-characterized the total quantity of the
      shipment by reviewing dose rate survey data and applying a dose to curie
      methodology. Contrary to Clinton procedure, the re-characterization was not reviewed
      by other Clinton personnel and new paperwork for the shipment, including a new NRC
      Form 541 was generated and transferred to the recipient.
      This event remains under review by the NRC and is categorized as an Unresolved Item
      (URI) (URI 05000461/2007004-01).
.5    Identification and Resolution of Problems for Radwaste Processing and Transportation
  a.  Inspection Scope
      The inspectors reviewed selected condition reports, self-assessment and audit reports,
      along with field observation reports that addressed the radioactive waste and radioactive
      materials shipping program, since the last inspection to determine if the licensee had
      effectively implemented the corrective action program and if problems were identified,
      characterized, prioritized, and corrected. The inspectors also determined whether the
      licensee's self-assessment program was capable of identifying repetitive deficiencies, or
      significant individual deficiencies in problem identification and resolution.
      The inspectors also selectively reviewed other corrective action program reports
      generated since the previous inspection that dealt with the radioactive material or
      radwaste shipping program, interviewed staff, and reviewed documents to determine if
      the following activities were being conducted in an effective and timely manner,
      commensurate with their importance to safety and risk:
      *    Initial problem identification, characterization, and tracking;
      *    Disposition of operability/reportability issues;
      *    Evaluation of safety significance/risk and priority for resolution;
      *    Identification of repetitive problems;
      *    Identification of contributing causes;
      *    Identification and implementation of effective corrective actions;
      *    Resolution of Non-Cited Violations tracked in corrective action system(s); and
      *    Implementation/consideration of risk significant operational experience feedback.
      These reviews represented one inspection sample.
                                                18                                    Enclosure
 
  b. Findings
    No findings of significance were identified.
4.  OTHER ACTIVITIES (OA)
4OA1 Performance Indicator Verification (71151)
    To perform a periodic review of performance indicator (PI) data to determine its
    accuracy and completeness.
    Cornerstones: Mitigation Systems
1.  Mitigating Systems Performance Indicators (MSPI)
a.  Inspection Scope
    The inspectors sampled the licensees submittals for performance indicators for the
    period of July 2006 through June 2007. The inspectors used performance indicator
    definitions and guidance contained in revision 5 of Nuclear Energy Institute (NEI)
    document 99-02, Regulatory Assessment Performance Indicator Guideline, to verify
    the accuracy of the performance indicator data. The inspectors performed three
    samples by reviewing the following:
    *    MSPI Emergency AC;
    *    MSPI Residual heat removal and
    *    MSPI Shutdown service water.
b.  Issues and Findings
    No findings of significance were identified.
2.  Safety System Functional Failures Performance Indicator
  a. Inspection Scope
    The inspectors reviewed, at a minimum, the most recent 24 months of Licensee Event
    Reports, licensee data reported to the NRC, plant logs, issue reports, and NRC
    inspection reports to verify the following performance indicators reported by the
    licensee for the 2nd Quarter of 2007 for Safety System Functional Failures.
    The inspectors verified that the licensee accurately reported performance as defined by
    the applicable revision of Nuclear Energy Institute Document 99-02, Regulatory
    Assessment Performance Indicator Guideline.
    This performance indicator review constituted one inspection sample.
                                              19                                    Enclosure


sample.The inspectors reviewed RWPs for airborne radioactivity areas to verify barrier integrityand engineering controls performance (e.g., HEPA ventilation system operation) and to
  b. Findings
determine if there was a potential for individual worker internal exposures of greater
    No findings of significance were identified.
than 50 millirem committed effective dose equivalent. No areas in the plant were
    Cornerstones: Public Radiation Safety and Barrier Integrity
airborne areas with a potential of greater than 5 millirem committed effective dose
  a. Inspection Scope
equivalent.  Work areas having a history of, or the potential for, airborne transuranics
    The inspectors reviewed the licensees determination of PIs for the Public Radiation
were evaluated to verify that the licensee had considered the potential for transuranic
    Safety Performance Indicator (Radiological Environmental Technical
isotopes and provided appropriate worker protection.  The license has not had a history
    Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences) and
of transuranic contamination.  These reviews represented one inspection sample.The adequacy of the licensee's internal dose assessment process for internal exposuresgreater than 50 millirem committed effective dose equivalent was assessed.  These
    Barrier Integrity Performance Indicator (Reactor Coolant System Specific Activity) to
reviews represented one inspection sample.The inspectors also reviewed the licensee's physical and programmatic controls forhighly activated and/or contaminated materials (non-fuel) stored within spent fuel or
    determine if the licensee accurately determined these performance indicators and had
other storage pools. These reviews represented one inspection sample. b.FindingsNo findings of significance were identified..3Problem Identification and Resolution  a.Inspection ScopeThe inspectors reviewed the licensee's self-assessments, audits, Licensee EventReports, and Special Reports related to the access control program to verify that
    identified all occurrences. Specifically, the inspectors reviewed the licensees
identified problems were entered into the corrective action program for resolution.
    corrective action program documents for the 4th quarter of CY 2006 and the 1st, 2nd, and
These reviews represented one inspection sample.The inspectors reviewed seven corrective action reports related to access controls andhigh radiation area radiological incidents when available (non-PIs identified by thelicensee in high radiation areas greater than 1R/hr).  Staff members were interviewed
    3rd quarters of CY 2007 and Public Radiation Safety and Barrier Integrity Performance
and corrective action documents were reviewed to verify that follow-up activities were
    Indicator data to ensure that there were no PI occurrences that were not identified by
being conducted in an effective and timely manner commensurate with their importance
    the licensee. In addition to record reviews, the inspectors observed a chemistry
to safety and risk based on the following:*Initial problem identification, characterization, and tracking;*Disposition of operability/reportability issues;
    technician obtain and analyze a reactor coolant system sample. The inspectors
*Evaluation of safety significance/risk and priority for resolution;
    interviewed members of the licensees staff who were responsible for performance
*Identification of repetitive problems;
    indicator data acquisition, verification and reporting, to determine if their review and
*Identification of contributing causes;
    assessment of the data was adequate.
*Identification and implementation of effective corrective actions;
    These reviews represented two inspection samples.
Enclosure 13*Resolution of Non-Cited Violations (NCVs) tracked in the corrective actionsystem; and*Implementation/consideration of risk significant operational experience feedback.These reviews represented one inspection sample.
  b. Findings
The inspectors evaluated the licensee's process for problem identification,characterization, and prioritization and verified that problems were entered into the
    No findings of significance were identified.
corrective action program and resolved. For repetitive deficiencies and/or significant
4OA2 Identification and Resolution of Problems (71152)
individual deficiencies in problem identification and resolution, the inspectors verified
  a. Inspection Scope
that the licensee's self-assessment activities were capable of identifying and addressing
    As discussed in previous sections of this report, the inspectors routinely reviewed
these deficiencies.  These reviews represented one inspection sample.The inspectors reviewed licensee documentation packages for all PI events occurringsince the last inspection to determine if any of these PI events involved dose rates
    issues during baseline inspection activities and plant status reviews to verify that they
greater than 25 R/hr at 30 centimeters or greater than 500 R/hr at 1 meter. Barriers
    were being entered into the licensees corrective action system at an appropriate
were evaluated for failure and to determine if there were any barriers left to prevent
    threshold, that adequate attention was being given to timely corrective actions, and that
personnel accessUnintended exposures greater than 100 millirem total effective dose
    adverse trends were identified and addressed. In addition, the inspectors reviewed the
equivalent (or greater than 5 rem shallow dose equivalent or greater than 1.5 rem lens
    following issue:
dose equivalent), were evaluated to determine if there were any regulatory
  bFindings
overexposures or if there was a substantial potential for an overexposure.  There were
    There were no findings of significance identified. The inspectors reviewed procedure
no unintended exposures approaching 100 millirem.  These reviews represented one
    OP-AA-102-103, Operator Work-Around Program, and the issues being tracked for
inspection sample.  b.FindingsNo findings of significance were identified..4Job-In-Progress Reviews  a.Inspection ScopeThe inspectors observed the following two work activities that were being performed inradiation areas, airborne radioactivity areas, or high radiation areas that presented the
    program resolution. As of July 23, 2007, there were two operator workarounds that
greatest radiological risk to workers:*Spent fuel pool re-rack project; and*Phase separator resin transfer.The inspectors reviewed radiological job requirements for these two activities includingRWP requirements and work procedure requirements, and attended
    were being tracked for resolution. The inspectors review determined that the issues
As-Low-As-Reasonably-Achievable (ALARA) job briefings.  These reviews represented
    were appropriately characterized as operator workarounds.
one inspection sample.Job performance was observed with respect to these requirements to verify thatradiological conditions in the work area were adequately communicated to workers
                                              20                                        Enclosure
through pre-job briefings and postings.  The inspectors also verified the adequacy of
radiological controls including required radiation and contamination surveys; radiation
Enclosure 14protection job coverage; and contamination controls. These reviews represented oneinspection sample.Radiological work in high radiation work areas having significant dose rate gradientswas reviewed to evaluate the application of dosimetry to effectively monitor exposure to
personnel and to verify that licensee controls were adequate.  These work areas
involved areas where the dose rate gradients were severe (diving activities in the fuel
pool re-rack project) which increased the necessity of providing multiple dosimeters.  
These reviews represented one-inspection sample.  b.FindingsNo findings of significance were identified..5High Risk Significant, High Dose Rate (HRA), and Very High Radiation Area Controls  a.Inspection ScopeThe inspectors held discussions with the acting Radiation Protection Managerconcerning high dose rate/high radiation area and very high radiation area controls and
procedures, including procedural changes that had occurred since the last inspection, in
order to verify that any procedure modifications did not substantially reduce the
effectiveness and level of worker protection.  These reviews represented one inspection


sample.The inspectors discussed with RP supervisors the controls that were in place for specialareas that had the potential to become very high radiation areas during certain plant
    The inspectors also reviewed selected operations department concerns and out of
operations, to determine if these plant operations required communication beforehand
    tolerance items that were identified in operations narrative logs to identify potential
with the RP group, so as to allow corresponding timely actions to properly post and
    operator workarounds that were not in the program. The inspectors concluded that
control the radiation hazards. These reviews represented one inspection sample.The inspectors conducted plant walkdowns to verify the posting and locking ofentrances to high dose rate HRAs, and very high radiation.  These reviews represented
    there were no additional workarounds identified from the sources reviewed.
one inspection sample. b.FindingsNo findings of significance were identified..6Radiation Worker Performance  a.Inspection ScopeDuring job performance observations, the inspectors evaluated radiation workerperformance with respect to stated radiation protection work requirements and
    On August 2, 2007, the inspector attended a WorkAround Board (WAB) meeting. One
evaluated whether workers were aware of the significant radiological conditions in their
    of the items under review that was identified during forced outage C1F049 and
workplace, the RWP controls and limits in place, and that their performance had
    documented by IR 642141, was the operation of 1E12-F009, residual heat removal
accounted for the level of radiological hazards present.  These reviews represented one
    shutdown cooling inboard isolation valve, from the main control room. The valve would
inspection sample.
    not open or close electrically (i.e., mechanically bound). An operator workaround
Enclosure 15The inspectors reviewed radiological problem reports which found that the cause of theevent was due to radiation worker errors to determine if there was an observable pattern
    program review was not requested by IR 642141. The resident inspectors questioned
traceable to a similar cause, and to determine if this perspective matched the corrective
    the licensee on the appropriateness of not conducting an operator workaround program
action approach taken by the licensee to resolve the reported problems. These
    review. This resulted in the August 2 review of this condition. In addition, the licensee
problems, along with planned and taken corrective actions were discussed with the
    generated IR 656515 on the missed opportunity to conduct an operator workaround
acting Radiation Protection Manager. These reviews represented one inspection
    program review of 1E12-F009 valve operation. On August 2, 2007, the WAB approved
    1E12-F009 valve operation as an operator workaround. The WAB member dialogue
    on the issues that were reviewed on August 2, 2007, was at the appropriate level of
    detail, and considered operator compensatory actions required to comply with plant
    procedures, design requirements and technical specifications.
4OA3 Event Follow-up (71153)
.1  (Closed) LER 05000461/2005-001-00. Inadequate Procurement Specification for
    Charcoal Results in Inoperable Control Room Ventilation Subsystem.
    Introduction: A performance deficiency involving a Non-Cited Violation of
    10 CFR Part 50, Appendix B, Criterion IV, Procurement Document Control, was self
    revealed following receipt of results that showed that Division 1 control room ventilation
    (VC) system charcoal filter penetration values were higher than allowed by Clintons
    Technical Specifications. This issue occurred because the licensee failed to establish
    proper purchase specifications for charcoal used in the VC system. Additionally, this
    issue led to Division 1 VC subsystems being inoperable from May 9 through
    May 16, 2005, concurrent with Division 2 VC subsystems being inoperable due to
    planned maintenance from May 9 through May 14, 2005.
    Description: On May 4, 2005, the licensee took charcoal absorber samples from the
    Division 1 VC recirculation charcoal bed filter in order to perform charcoal penetration
    testing as required by VC system Technical Specification surveillance requirement
    3.7.3.3. On May 9, 2005, planned maintenance was performed on the Division 2
    emergency diesel generator resulting in it becoming inoperable. The licensee also
    declared the Division 2 VC subsystem inoperable because of the diesel inoperability.
    The Division 2 emergency diesel generator and the Division 2 VC system were
    declared operable on May 14, 2005, following completion of planned maintenance on
    the emergency diesel generator. On May 16, 2005, the licensee received the
    Division 1 charcoal sample analysis results which showed that after applying a
    correction factor, the charcoal penetration value was 8.168. This charcoal penetration
    was higher than the charcoal penetration operability value of 6.0 contained in Clintons
    Technical Specifications.
                                              21                                      Enclosure


sample.  b.FindingsNo findings of significance were identified..7Radiation Protection Technician Proficiency  a.Inspection ScopeDuring job performance observations, the inspectors evaluated Radiation ProtectionTechnician (RPT) performance with respect to radiation protection work requirements
Because of the unsatisfactory results, the licensee concluded that the seven day
and evaluated whether they were aware of the radiological conditions in their workplace,
required action completion time to restore an inoperable VC subsystem was not met,
the RWP controls and limits in place, and if their performance was consistent with their
nor was the required action to be in Mode 3 and Mode 4 per Clintons Technical
training and qualifications with respect to the radiological hazards and work activities.
Specifications. Additionally, the Division 2 VC subsystem was inoperable from
These reviews represented one inspection sample.The inspectors reviewed radiological problem reports which found that the cause of theevent was radiation protection technician error to determine if there was an observable
pattern traceable to a similar cause, and to determine if this perspective matched the
corrective action approach taken by the licensee to resolve the reported problems.
These reviews represented one inspection sample.  b.FindingsNo findings of significance were identified.Cornerstone:  Public Radiation Safety 2PS2Radioactive Material Processing and Transportation (71122.02).1Radioactive Waste System  a.Inspection ScopeThe inspectors reviewed the liquid and solid radioactive waste system descriptions inthe Updated Final Safety Analysis Report (UFSAR), and the 2006 Annual RadioactiveEffluent Release Report for information on the types and amounts of radioactive waste
(radwaste) generated and disposed.  The inspectors reviewed the scope of the
licensee's audit/self-assessment activities, with regard to radioactive material processing
and transportation programs to determine if those activities satisfied the requirements of
Enclosure 1610 CFR 20.1101(c) and the quality assurance audit requirements of Appendix G to10 CFR Part 20 and of 10 CFR 71.137, as applicable.These reviews represented one inspection sample.  b.FindingsNo findings of significance were identified..2Radioactive Waste System Walkdowns  a.Inspection ScopeThe inspectors walked down portions of the liquid and solid radwaste processingsystems to verify that these systems were consistent with the descriptions in the UFSAR
and in the Process Control Program and to assess the material condition and operability
of those systems.  The inspectors reviewed the status of radioactive waste process
equipment that was not operational and/or was abandoned in place.  The inspectors
discussed with the licensee the administrative and/or physical controls preventing the
inadvertent use of this equipment to ensure that the equipment would not contribute to
an unmonitored release path or be a source of unnecessary personnel exposure.The inspectors reviewed changes to the waste processing system to verify the changeswere reviewed and documented in accordance with 10 CFR 50.59 and to assess the
impact of the changes on radiation dose to members of the public.  The inspectors
reviewed the licensee's processes for transferring waste resin into shipping containers
to determine if appropriate waste stream mixing and sampling was performed so as to
obtain representative waste stream samples for analysis.  The inspector also reviewed
the methodologies for waste concentration averaging to determine if representative
samples of the waste product were provided for the purposes of waste classification in
accordance with 10 CFR 61.55.These reviews represented one inspection sample.  b.FindingsNo findings of significance were identified..3Waste Characterization and Classification  a.Inspection ScopeThe inspectors reviewed the licensee's methods and procedures for determining theclassification of radioactive waste shipments including the use of scaling factors to
quantify difficult-to-measure radionuclides.  The inspectors reviewed the licensee's most
recent radiochemical sample analysis results for each of the licensee's waste streams,
and the associated calculations used to account for difficult-to-measure radionuclides.
These waste streams consisted of radwaste demineralizer resins, various filter media,
and dry active waste (DAW).  The inspectors also reviewed the licensee's use of scaling
Enclosure 17factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emittingradionuclides).  The reviews were conducted to verify that the licensee's program
assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G
of 10 CFR Part 20.  The inspectors also reviewed the licensee's waste characterization
and classification program to determine if reactor coolant chemistry data was
periodically evaluated to account for changing operational parameters that could
potentially affect waste stream classification and thus validate the continued use of
existing scaling factors between sample analysis updates.These reviews represented one inspection sample.  b.FindingsNo findings of significance were identified..4Shipment Preparation and Records  a.Inspection ScopeThe inspectors reviewed the documentation of shipment packaging, surveying, packagelabeling and marking, vehicle inspections and placarding, emergency instructions, and
licensee verification of shipment readiness for six selected non-excepted radioactive
material and radwaste shipments, made between March 2006 and January 2007.  The
shipment documentation reviewed included:*Equipment in a B-25 Box Shipped as Low Specific Activity (LSA);*Two Spent Resins Shipped as Type A;
*Two Phase Separator Resins Shipped as Type A; and
*Part 61 Resin Samples Shipped as LSA.For each shipment, the inspectors determined if the requirements of 10 CFR Parts 20and 61 and those of the Department of Transportation (DOT) in 49 CFR Parts 170-189
were met.  Specifically, records were reviewed, and staff involved in shipment activities
were interviewed to determine if packages were labeled and marked properly, if
packages and transport vehicle surveys were performed with appropriate
instrumentation, whether survey results satisfied DOT requirements, and if the quantity
and type of radionuclides in each shipment were determined accurately.  The inspectors
also determined whether shipment manifests were completed in accordance with DOT
and NRC requirements, if they included the required emergency response information, if
the recipient was authorized to receive the shipment, and if shipments were tracked as
required by 10 CFR Part 20.Selected staff involved in shipment activities were interviewed by the inspectors todetermine if they had adequate skills to accomplish shipment related tasks and to
determine if the shippers were knowledgeable of the applicable regulations to satisfy
package preparation requirements for public transport with respect to NRC
Bulletin 79-19, "Packaging of Low-Level Radioactive Waste for Transport and Burial."
Also, the inspectors reviewed the transportation specific training for the authorized
shippers to assure that they met the requirements of 49 CFR Part 172, Subpart H. 
Enclosure 18These reviews represented two inspection samples.  b.Findings  (1)Shipment Total Quantity Re-characterized After ShippingA shipment of phase separator resins was shipped from Clinton Power StationSeptember 30, 2005, and delivered to a vendor on October 1, 2005.  The total curie
quantity in the shipment was in excess of the vendor's Agreement State license limits.
The vendor communicated this discrepancy to shipping personnel at Clinton Power
Station on October 3, 2005.  The shipper then re-characterized the total quantity of the
shipment by reviewing dose rate survey data and applying a "dose to curie"
methodology.  Contrary to Clinton procedure, the re-characterization was not reviewed
by other Clinton personnel and new paperwork for the shipment, including a new NRC
Form 541 was generated and transferred to the recipient.This event remains under review by the NRC and is categorized as an Unresolved Item(URI) (URI 05000461/2007004-01)
..5Identification and Resolution of Problems for Radwaste Processing and Transportation  a.Inspection ScopeThe inspectors reviewed selected condition reports, self-assessment and audit reports,along with field observation reports that addressed the radioactive waste and radioactive
materials shipping program, since the last inspection to determine if the licensee had
effectively implemented the corrective action program and if problems were identified,
characterized, prioritized, and corrected.  The inspectors also determined whether the
licensee's self-assessment program was capable of identifying repetitive deficiencies, or
significant individual deficiencies in problem identification and resolution.The inspectors also selectively reviewed other corrective action program reportsgenerated since the previous inspection that dealt with the radioactive material or
radwaste shipping program, interviewed staff, and reviewed documents to determine if
the following activities were being conducted in an effective and timely manner,
commensurate with their importance to safety and risk:*Initial problem identification, characterization, and tracking;*Disposition of operability/reportability issues;
*Evaluation of safety significance/risk and priority for resolution;
*Identification of repetitive problems;
*Identification of contributing causes;
*Identification and implementation of effective corrective actions;
*Resolution of Non-Cited Violations tracked in corrective action system(s); and
*Implementation/consideration of risk significant operational experience feedback.These reviews represented one inspection sample.
Enclosure 19  b.FindingsNo findings of significance were identified.4.OTHER ACTIVITIES (OA)4OA1Performance Indicator Verification (71151)To perform a periodic review of performance indicator (PI) data to determine itsaccuracy and completeness.Cornerstones:  Mitigation Systems 1.Mitigating Systems Performance Indicators (MSPI) a.Inspection ScopeThe inspectors sampled the licensee's submittals for performance indicators for theperiod of July 2006 through June 2007. The inspectors used performance indicator
definitions and guidance contained in revision 5 of Nuclear Energy Institute (NEI)
document 99-02, "Regulatory Assessment Performance Indicator Guideline," to verify
the accuracy of the performance indicator data. The inspectors performed three
samples by reviewing the following:*MSPI Emergency AC;*MSPI Residual heat removal and
*MSPI Shutdown service water. b.Issues and FindingsNo findings of significance were identified.2.Safety System Functional Failures Performance Indicator  a.Inspection ScopeThe inspectors reviewed, at a minimum, the most recent 24 months of Licensee EventReports, licensee data reported to the NRC, plant logs, issue reports, and NRC
inspection reports to verify the following performance indicators reported by the
licensee for the 2
nd Quarter of 2007 for Safety System Functional Failures.The inspectors verified that the licensee accurately reported performance as defined bythe applicable revision of Nuclear Energy Institute Document 99-02, "Regulatory
Assessment Performance Indicator Guideline."This performance indicator review constituted one inspection sample.
Enclosure 20  b.FindingsNo findings of significance were identified.Cornerstones:  Public Radiation Safety and Barrier
Integrity  a.Inspection ScopeThe inspectors reviewed the licensee's determination of PIs for the Public RadiationSafety Performance Indicator (Radiological Environmental Technical
Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences) andBarrier Integrity Performance Indicator (Reactor Coolant System Specific Activity) to
determine if the licensee accurately determined these performance indicators and had
identified all occurrences.  Specifically, the inspectors reviewed the licensee'scorrective action program documents for the 4
th quarter of CY 2006 and the 1
st , 2 nd, and 3 rd quarters of CY 2007 and Public Radiation Safety and Barrier Integrity PerformanceIndicator data to ensure that there were no PI occurrences that were not identified by
the licensee.  In addition to record reviews, the inspectors observed a chemistry
technician obtain and analyze a reactor coolant system sample.  The inspectors
interviewed members of the licensee's staff who were responsible for performance
indicator data acquisition, verification and reporting, to determine if their review and
assessment of the data was adequate.These reviews represented two inspection samples.  b.FindingsNo findings of significance were identified.4OA2Identification and Resolution of Problems (71152) a.Inspection ScopeAs discussed in previous sections of this report, the inspectors routinely reviewedissues during baseline inspection activities and plant status reviews to verify that they
were being entered into the licensee's corrective action system at an appropriate
threshold, that adequate attention was being given to timely corrective actions, and that
adverse trends were identified and addressed.  In addition, the inspectors reviewed the
following issue: b.FindingsThere were no findings of significance identified.  The inspectors reviewed procedureOP-AA-102-103, "Operator Work-Around Program," and the issues being tracked for
program resolution.  As of July 23, 2007, there were two operator workarounds that
were being tracked for resolution.  The inspectors' review determined that the issues
were appropriately characterized as operator workarounds.
Enclosure 21The inspectors also reviewed selected operations department concerns and out oftolerance items that were identified in operations narrative logs to identify potential
operator workarounds that were not in the program.  The inspectors concluded that
there were no additional workarounds identified from the sources reviewed.On August 2, 2007, the inspector attended a WorkAround Board (WAB) meeting.  Oneof the items under review that was identified during forced outage C1F049 and
documented by IR 642141, was the operation of 1E12-F009, residual heat removal
shutdown cooling inboard isolation valve, from the main control room.  The valve would
not open or close electrically (i.e., mechanically bound).  An operator workaround
program review was not requested by IR 642141.  The resident inspectors questioned
the licensee on the appropriateness of not conducting an operator workaround program
review.  This resulted in the August 2 review of this condition.  In addition, the licensee
generated IR 656515 on the missed opportunity to conduct an operator workaround
program review of 1E12-F009 valve operation.  On August 2, 2007, the WAB approved
1E12-F009 valve operation as an operator workaround.  The WAB member dialogue
on the issues that were reviewed on August 2, 2007, was at the appropriate level of
detail, and considered operator compensatory actions required to comply with plant
procedures, design requirements and technical specifications.4OA3Event Follow-up (71153).1(Closed) LER 05000461/2005-001-00.  Inadequate Procurement Specification forCharcoal Results in Inoperable Control Room Ventilation Subsystem.Introduction:  A performance deficiency involving a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion IV, "Procurement Document Control," was self
revealed following receipt of results that showed that Division 1 control room ventilation
(VC) system charcoal filter penetration values were higher than allowed by Clinton's
Technical Specifications.  This issue occurred because the licensee failed to establishproper purchase specifications for charcoal used in the VC system.  Additionally, this
issue led to Division 1 VC subsystems being inoperable from May 9 through
May 16, 2005, concurrent with Division 2 VC subsystems being inoperable due to
planned maintenance from May 9 through May 14, 2005.Description:  On May 4, 2005, the licensee took charcoal absorber samples from theDivision 1 VC recirculation charcoal bed filter in order to perform charcoal penetration
testing as required by VC system Technical Specification surveillance requirement
3.7.3.3.  On May 9, 2005, planned maintenance was performed on the Division 2
emergency diesel generator resulting in it becoming inoperable.  The licensee also
declared the Division 2 VC subsystem inoperable because of the diesel inoperability.
The Division 2 emergency diesel generator and the Division 2 VC system were
declared operable on May 14, 2005, following completion of planned maintenance on
the emergency diesel generator.  On May 16, 2005, the licensee received the
Division 1 charcoal sample analysis results which showed that after applying a
correction factor, the charcoal penetration value was 8.168.  This charcoal penetration
was higher than the charcoal penetration operability value of 6.0 contained in Clinton's
Technical Specifications.
Enclosure 22Because of the unsatisfactory results, the licensee concluded that the seven dayrequired action completion time to restore an inoperable VC subsystem was not met,
nor was the required action to be in Mode 3 and Mode 4 per Clinton's Technical
Specifications. Additionally, the Division 2 VC subsystem was inoperable from
May 9 to May 14, 2005, due to the Division 2 emergency diesel generator maintenance
May 9 to May 14, 2005, due to the Division 2 emergency diesel generator maintenance
outage. The licensee concluded that the station was in Technical Specification
outage. The licensee concluded that the station was in Technical Specification
(TS) 3.7.3 required action D.1, requiring entry into TS limiting condition for operation
(TS) 3.7.3 required action D.1, requiring entry into TS limiting condition for operation
(LCO) 3.0.3. The licensee did not enter the TS 3.7.3 required action and LCO 3.0.3,
(LCO) 3.0.3. The licensee did not enter the TS 3.7.3 required action and LCO 3.0.3,
since the sample results were not known during the emergency diesel generator
since the sample results were not known during the emergency diesel generator
outage.A licensee investigation concluded that the cause of this event was that charcoalpurchasing requirements were inadequate for the unique application at Clinton. The
outage.
A licensee investigation concluded that the cause of this event was that charcoal
purchasing requirements were inadequate for the unique application at Clinton. The
licensee purchased the charcoal installed in the Division 1 VC system to
licensee purchased the charcoal installed in the Division 1 VC system to
ANSI/ASME N509-1980, "Nuclear Power Plant Air Cleaning Units and Components.
ANSI/ASME N509-1980, Nuclear Power Plant Air Cleaning Units and Components.
According to the licensee, this industry standard had no limit on as-manufactured
According to the licensee, this industry standard had no limit on as-manufactured
moisture levels. The licensee concluded that the Clinton VC system's unique design
moisture levels. The licensee concluded that the Clinton VC systems unique design
attributes, which included higher than normal airflow velocity, thin charcoal beds, and
attributes, which included higher than normal airflow velocity, thin charcoal beds, and
no airflow heaters coupled with high as-manufactured moisture levels significantly
no airflow heaters coupled with high as-manufactured moisture levels significantly
reduced the charcoal residence time and increased the penetration levels. The
reduced the charcoal residence time and increased the penetration levels. The
licensee investigation also concluded that 10 percent of the charcoal contained in the
licensee investigation also concluded that 10 percent of the charcoal contained in the
failed filter was caked after 17 months of operations. The licensee stated that this
failed filter was caked after 17 months of operations. The licensee stated that this
caking was again proof of high as-manufactured moisture content.The failed charcoal bed filter contained coal from lot 55, batch 68. The licensee's extentof condition review determined that this event was limited to the VC 'A' recirculation
caking was again proof of high as-manufactured moisture content.
charcoal bed filter. The bases of this conclusion were that penetration tests results
The failed charcoal bed filter contained coal from lot 55, batch 68. The licensees extent
of condition review determined that this event was limited to the VC A recirculation
charcoal bed filter. The bases of this conclusion were that penetration tests results
were satisfactory for the other beds in the VC system and no lot 55, batch 68, charcoal
were satisfactory for the other beds in the VC system and no lot 55, batch 68, charcoal
was in storage. The licensee investigation also determined that the charcoal in lot 55,
was in storage. The licensee investigation also determined that the charcoal in lot 55,
batch 68, had as-manufactured high moisture content of at least 12 percent by weight.  
batch 68, had as-manufactured high moisture content of at least 12 percent by weight.
All charcoal currently in storage was confirmed to have a moisture content of less than
All charcoal currently in storage was confirmed to have a moisture content of less than
eight percent.The inspectors were concerned that the licensee maintenance scheduling processwould allow for the redundant VC subsystem to be made inoperable without knowing
eight percent.
the results of the Technical Specification required sample analysis. The inspectors
The inspectors were concerned that the licensee maintenance scheduling process
would allow for the redundant VC subsystem to be made inoperable without knowing
the results of the Technical Specification required sample analysis. The inspectors
concluded poor scheduling of work contributed to both VC subsystems becoming
concluded poor scheduling of work contributed to both VC subsystems becoming
inoperable per the licensee's Technical Specifications. The licensee did not address
inoperable per the licensees Technical Specifications. The licensee did not address
this issue in the root cause report. In response to the inspectors' questions in this area,
this issue in the root cause report. In response to the inspectors questions in this area,
the licensee provided issue report 340314, "Enhancement to Manage Risk of Charcoal
the licensee provided issue report 340314, Enhancement to Manage Risk of Charcoal
Samples.This issue report addressed the inspectors' concern, in that, it incorporated
Samples. This issue report addressed the inspectors concern, in that, it incorporated
corrective actions that implemented an administrative trigger using model work orders
corrective actions that implemented an administrative trigger using model work orders
to ensure that no work would be scheduled for the next work week that would cause an
to ensure that no work would be scheduled for the next work week that would cause an
inoperability of the opposite train or its support systems. This administrative trigger
inoperability of the opposite train or its support systems. This administrative trigger
was placed into model work orders for all VC system and standby gas treatment
was placed into model work orders for all VC system and standby gas treatment
system predefined activities.Analysis: The inspectors determined that the licensee's failure to provide adequatepurchase specifications to satisfy the requirements for the Clinton unique VC system  
system predefined activities.
Enclosure 23was a performance deficiency warranting a significance evaluation. The inspectorsconcluded that the finding was more than minor in accordance with IMC 0612, "Power
Analysis: The inspectors determined that the licensees failure to provide adequate
Reactor Inspection Reports," Appendix B, because the finding affected the objective of
purchase specifications to satisfy the requirements for the Clinton unique VC system
                                          22                                      Enclosure
 
was a performance deficiency warranting a significance evaluation. The inspectors
concluded that the finding was more than minor in accordance with IMC 0612, Power
Reactor Inspection Reports, Appendix B, because the finding affected the objective of
the Barrier Integrity cornerstone of assuring that physical design barriers protect the
the Barrier Integrity cornerstone of assuring that physical design barriers protect the
public from radionuclide releases caused by accidents or events. Additionally, this
public from radionuclide releases caused by accidents or events. Additionally, this
issue is associated with the barrier performance attribute of maintaining Radiological
issue is associated with the barrier performance attribute of maintaining Radiological
Barrier functionality of the control room. Failure to ensure adequate purchase
Barrier functionality of the control room. Failure to ensure adequate purchase
specifications resulted in there being a period where both trains of control room
specifications resulted in there being a period where both trains of control room
ventilation were inoperable without the knowledge of the operators.The inspectors completed a Phase 1 significance determination using IMC 0609,"Significance Determination Process," Appendix A, Attachment 1, dated
ventilation were inoperable without the knowledge of the operators.
March 23, 2007. Using IMC 0609 Appendix A, SDP Phase 1 screening worksheet, the
The inspectors completed a Phase 1 significance determination using IMC 0609,
inspectors determined that this issue degraded the Containment Barrier. The  
Significance Determination Process, Appendix A, Attachment 1, dated
inspectors answered 'Yes,' to whether the finding only represents a degradation of the
March 23, 2007. Using IMC 0609 Appendix A, SDP Phase 1 screening worksheet, the
inspectors determined that this issue degraded the Containment Barrier. The
inspectors answered Yes, to whether the finding only represents a degradation of the
radiological barrier function provided for the control room, or auxiliary building, or spent
radiological barrier function provided for the control room, or auxiliary building, or spent
fuel pool, or SBGT system (BWR). As a result, the Phase 1 Worksheets screened as
fuel pool, or SBGT system (BWR). As a result, the Phase 1 Worksheets screened as
Green.The finding is also related to the cross-cutting area of Human Performance as definedin IMC 0305, "Operating Reactor Assessment Program," specifically, the finding is
Green.
The finding is also related to the cross-cutting area of Human Performance as defined
in IMC 0305, Operating Reactor Assessment Program, specifically, the finding is
related to the resources and work control component because the licensee did not
related to the resources and work control component because the licensee did not
provide an adequate purchase specification reflective of the requirements for the VC
provide an adequate purchase specification reflective of the requirements for the VC
system. However, this issue was determined not to have a cross-cutting aspect
system. However, this issue was determined not to have a cross-cutting aspect
because it was over two years old and not reflective of current performance in this area
because it was over two years old and not reflective of current performance in this area
based on the inspector's review of the licensee's effectiveness review of corrective
based on the inspectors review of the licensees effectiveness review of corrective
actions established to prevent this issue from occurring again.Enforcement: 10 CFR Part 50, Appendix B, Criteria IV, "Procurement DocumentControl" states that measures shall be established to assure that applicable regulatory
actions established to prevent this issue from occurring again.
Enforcement: 10 CFR Part 50, Appendix B, Criteria IV, Procurement Document
Control states that measures shall be established to assure that applicable regulatory
requirements, design bases, and other requirements which are necessary to assure
requirements, design bases, and other requirements which are necessary to assure
adequate quality are suitably included or referenced in the documents for procurement
adequate quality are suitably included or referenced in the documents for procurement
of material, equipment, and services, whether purchased by the applicant or by its
of material, equipment, and services, whether purchased by the applicant or by its
contractors or subcontractors.Contrary to the above, Clinton Power Station failed to specify in a procurementdocument the moisture content for charcoal filters to be used in the VC system. This
contractors or subcontractors.
issue resulted in charcoal being used in the division 1 VC system that was outside thepenetration limits established by Technical Specification 3.7.3, from May 4 to
Contrary to the above, Clinton Power Station failed to specify in a procurement
May 16, 2007. This issue also resulted in both control room ventilation systems being
document the moisture content for charcoal filters to be used in the VC system. This
inoperable. The licensee entered this issue into the corrective action program (CAP)
issue resulted in charcoal being used in the division 1 VC system that was outside the
as issue reports 335698 and 340314. Corrective action for this issue included revising
penetration limits established by Technical Specification 3.7.3, from May 4 to
the charcoal purchase specifications to limit as-manufactured content of eight percentby weight. Additionally, the licensee added limitations to model work orders to prevent
May 16, 2007. This issue also resulted in both control room ventilation systems being
inoperable. The licensee entered this issue into the corrective action program (CAP)
as issue reports 335698 and 340314. Corrective action for this issue included revising
the charcoal purchase specifications to limit as-manufactured content of eight percent
by weight. Additionally, the licensee added limitations to model work orders to prevent
or limit the scheduling of work that could impact the operability of redundant systems
or limit the scheduling of work that could impact the operability of redundant systems
that contained charcoal. Because the licensee entered the issue into the CAP and the
that contained charcoal. Because the licensee entered the issue into the CAP and the
finding is of very low safety significance, this violation is being treated as an NCV,  
finding is of very low safety significance, this violation is being treated as an NCV,
Enclosure 24consistent with Section VI.A of the NRC Enforcement policy. (NCV 05000451/2007-004-01).2(Closed) LER 05000461/2007-003-00, IGSCC Causes RCS Pressure Boundary Leakand Reactor Shutdown a.Inspection ScopeThe inspectors observed the station response to a steam leak in the drywell on June 18, 2007. The inspectors arrived in the control room approximately two hours
                                        23                                        Enclosure
after the initial alarms and indications of a leak were received and discussed the
 
actions that had been taken with control room operators. The inspectors then
    consistent with Section VI.A of the NRC Enforcement policy.
proceeded to the outage control center, which had been manned for troubleshooting
    (NCV 05000451/2007-004-01)
and to support the control room in decision making, to discuss proposed actions with
.2 (Closed) LER 05000461/2007-003-00, IGSCC Causes RCS Pressure Boundary Leak
licensee management. The inspectors reviewed the licensee's troubleshooting
    and Reactor Shutdown
documents, equipment prompt investigation, root cause report, and LER 2007-003. b.FindingsIntroduction: A Non-Cited Violation of Technical Specifications (TS) having very lowsafety significance (Green), was self-revealed when the licensee failed to meet the
a. Inspection Scope
required completion time for an action statement in TS 3.4.5. Specifically, TS 3.4.5
    The inspectors observed the station response to a steam leak in the drywell on
does not allow reactor coolant system pressure boundary leakage and requires a
    June 18, 2007. The inspectors arrived in the control room approximately two hours
shutdown to Mode 3 within 12 hours if pressure boundary leakage is discovered. Upon
    after the initial alarms and indications of a leak were received and discussed the
entry into the drywell following a shutdown of the reactor on June 19, 2007, the
    actions that had been taken with control room operators. The inspectors then
licensee discovered the existence of reactor coolant system (RCS) pressure boundary
    proceeded to the outage control center, which had been manned for troubleshooting
leakage. Indications of the leakage had been discovered at 0433 on June 18, 2007,
    and to support the control room in decision making, to discuss proposed actions with
but the plant was not placed in Mode 3 until approximately 31 hours later at 1125 on
    licensee management. The inspectors reviewed the licensees troubleshooting
June 19, 2007.Description: At 0433 on June 18, 2007, plant operators responded to main controlroom alarms and other indications, and determined the presence of a steam leak in the
    documents, equipment prompt investigation, root cause report, and LER 2007-003.
drywell. The initial alarms included: Transient Test Alarm, Fission Product Particulate
b. Findings
High Radiation, and Fission Product Iodine High. Other indications included transienttest system trouble, channel 119, main steam line 'C' elbow tap differential pressure, an
    Introduction: A Non-Cited Violation of Technical Specifications (TS) having very low
increased trend in drywell pressure rise, and the fission product monitor particulate and
    safety significance (Green), was self-revealed when the licensee failed to meet the
iodine channels had taken a step change. The operators took appropriate actions in
    required completion time for an action statement in TS 3.4.5. Specifically, TS 3.4.5
accordance with station procedures for reactor coolant leakage and abnormal release
    does not allow reactor coolant system pressure boundary leakage and requires a
of airborne radioactivity. The operators noted that a spike in main steam line 'C' elbow
    shutdown to Mode 3 within 12 hours if pressure boundary leakage is discovered. Upon
tap differential pressure was an indication of a steam leak somewhere in the area of
    entry into the drywell following a shutdown of the reactor on June 19, 2007, the
the elbow tap. The 'C' main steam line elbow taps were located within the area
    licensee discovered the existence of reactor coolant system (RCS) pressure boundary
considered reactor coolant system pressure boundary. The operators entered TS 3.4.5
    leakage. Indications of the leakage had been discovered at 0433 on June 18, 2007,
actions C.1, be in Mode 3 in 12 hours, and C.2, be in Mode 4 in 36 hours.The licensee manned the outage control center at 0641. After further deliberations, thelicensee noted that there were other components (mechanical joints for flexi-hose) that
    but the plant was not placed in Mode 3 until approximately 31 hours later at 1125 on
are associated with the 'C' main steam line flow instrumentation that are not considered
    June 19, 2007.
pressure boundaries and, therefore, the increase in drywall leakage was not  
    Description: At 0433 on June 18, 2007, plant operators responded to main control
Enclosure 25necessarily pressure boundary leakage. Based on this, the licensee then decided toconsider the steam leak as unidentified leakage. With the change in classification to
    room alarms and other indications, and determined the presence of a steam leak in the
    drywell. The initial alarms included: Transient Test Alarm, Fission Product Particulate
    High Radiation, and Fission Product Iodine High. Other indications included transient
    test system trouble, channel 119, main steam line C elbow tap differential pressure, an
    increased trend in drywell pressure rise, and the fission product monitor particulate and
    iodine channels had taken a step change. The operators took appropriate actions in
    accordance with station procedures for reactor coolant leakage and abnormal release
    of airborne radioactivity. The operators noted that a spike in main steam line C elbow
    tap differential pressure was an indication of a steam leak somewhere in the area of
    the elbow tap. The C main steam line elbow taps were located within the area
    considered reactor coolant system pressure boundary. The operators entered TS 3.4.5
    actions C.1, be in Mode 3 in 12 hours, and C.2, be in Mode 4 in 36 hours.
    The licensee manned the outage control center at 0641. After further deliberations, the
    licensee noted that there were other components (mechanical joints for flexi-hose) that
    are associated with the C main steam line flow instrumentation that are not considered
    pressure boundaries and, therefore, the increase in drywall leakage was not
                                              24                                    Enclosure
 
necessarily pressure boundary leakage. Based on this, the licensee then decided to
consider the steam leak as unidentified leakage. With the change in classification to
unidentified leakage the leak rates did not meet any of the requirements for remaining
unidentified leakage the leak rates did not meet any of the requirements for remaining
in TS 3.4.5. The licensee exited action statements C.1 and C.2. However, although
in TS 3.4.5. The licensee exited action statements C.1 and C.2. However, although
small, the leakage continued to increase. Due to the steady increase in unidentified
small, the leakage continued to increase. Due to the steady increase in unidentified
leakage, operators commenced a normal plant shutdown at 2011 on June 18, 2007, to
leakage, operators commenced a normal plant shutdown at 2011 on June 18, 2007, to
enter the drywell and identify the actual location of the steam leak. At 0635 on
enter the drywell and identify the actual location of the steam leak. At 0635 on
June 19, 2007, maintenance personnel entered the drywell and found pressure
June 19, 2007, maintenance personnel entered the drywell and found pressure
boundary leakage on a one-inch diameter ASME Section III Class II stainless steelbraided flexible hose assembly on the "C" main steam line flow elbow tap. Operators
boundary leakage on a one-inch diameter ASME Section III Class II stainless steel
braided flexible hose assembly on the C main steam line flow elbow tap. Operators
once again entered the actions of TS 3.4.5 due to reactor coolant pressure boundary
once again entered the actions of TS 3.4.5 due to reactor coolant pressure boundary
leakage. The plant entered Mode 3 at 1125 on June 19, 2007, (approximately 31 hours
leakage. The plant entered Mode 3 at 1125 on June 19, 2007, (approximately 31 hours
after indication of pressure boundary leakage), and Mode 4 at 2300 on June 19, 2007.  
after indication of pressure boundary leakage), and Mode 4 at 2300 on June 19, 2007.
The licensee replaced the leaking flexible hose and initiated a root cause investigation.  
The licensee replaced the leaking flexible hose and initiated a root cause investigation.
The root cause determined that the leak was caused by intergranular stress corrosion
The root cause determined that the leak was caused by intergranular stress corrosion
cracking of the flexible hose.Analysis: The inspectors determined that failure to meet the required completion timesfor TS actions was a performance deficiency warranting a significance evaluation. The
cracking of the flexible hose.
Analysis: The inspectors determined that failure to meet the required completion times
for TS actions was a performance deficiency warranting a significance evaluation. The
inspectors determined that the finding was more than minor by using Inspection Manual
inspectors determined that the finding was more than minor by using Inspection Manual
Chapter 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening,"
Chapter 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening,
because operating with a degraded pressure boundary affected the reactor coolant
because operating with a degraded pressure boundary affected the reactor coolant
system (RCS) equipment and barrier performance attribute of the Barrier Integrity
system (RCS) equipment and barrier performance attribute of the Barrier Integrity
cornerstone, in that, RCS pressure boundary leakage results in a reduction in the
cornerstone, in that, RCS pressure boundary leakage results in a reduction in the
reasonable assurance that physical design barriers protect the public from radionuclide
reasonable assurance that physical design barriers protect the public from radionuclide
releases caused by accidents or events. The finding also affected the cross-cutting
releases caused by accidents or events. The finding also affected the cross-cutting
component of Decision Making in the area of Human Performance in that operators
component of Decision Making in the area of Human Performance in that operators
had initially entered TS 3.4.5 for pressure boundary leakage, but subsequently, the
had initially entered TS 3.4.5 for pressure boundary leakage, but subsequently, the
organization decided not to treat the leak as pressure boundary leakage, but rather as
organization decided not to treat the leak as pressure boundary leakage, but rather as
unidentified leakage until the actual location could be determined.The inspectors completed a significance determination using IMC 0609, "SignificanceDetermination Process.The Phase 1 worksheet directed the inspectors to consider
unidentified leakage until the actual location could be determined.
the reactor coolant system leakage under the Initiating Events Cornerstone column.  
The inspectors completed a significance determination using IMC 0609, Significance
The inspectors answered 'Yes' to question one under the Initiating Events cornerstone
Determination Process. The Phase 1 worksheet directed the inspectors to consider
the reactor coolant system leakage under the Initiating Events Cornerstone column.
The inspectors answered Yes to question one under the Initiating Events cornerstone
column stating that assuming worst case degradation, the finding would result in
column stating that assuming worst case degradation, the finding would result in
exceeding the TS limit for identified RCS leakage. The Phase 1 worksheet directed the
exceeding the TS limit for identified RCS leakage. The Phase 1 worksheet directed the
inspector to Phase II. For the Phase II screening, the inspectors used the table for asmall break loss of coolant accident, and conservatively set the initiating event
inspector to Phase II. For the Phase II screening, the inspectors used the table for a
small break loss of coolant accident, and conservatively set the initiating event
frequency to 1 (X=0), because the event was actually occurring in the form of the
frequency to 1 (X=0), because the event was actually occurring in the form of the
steam leak. Since all of the mitigating equipment was available, the finding was
steam leak. Since all of the mitigating equipment was available, the finding was
determined to be of very low safety significance (Green). The licensee established the
determined to be of very low safety significance (Green). The licensee established the
following corrective actions to address this issue: 1) replaced the leaking flexible hose,
following corrective actions to address this issue: 1) replaced the leaking flexible hose,
2) scheduled replacement of all other flexible hoses used on the main steam lines
2) scheduled replacement of all other flexible hoses used on the main steam lines
during the next refueling outage and 3) established a 16-year preventive maintenance
during the next refueling outage and 3) established a 16-year preventive maintenance
replacement frequency for the flexible hoses used on the main steam line.Enforcement: Technical Specification 3.4.5 a. limits RCS operational leakage to"No pressure boundary leakage," and states that if pressure boundary leakage is  
replacement frequency for the flexible hoses used on the main steam line.
Enclosure 26present, the plant is required to be in Mode 3 in 12 hours and Mode 4 in 36 hours. Contrary to the above, on June 18, 2007, pressure boundary leakage was present and
Enforcement: Technical Specification 3.4.5 a. limits RCS operational leakage to
the operators did not place the plant in Mode 3 for nearly 31 hours and Mode 4 for
No pressure boundary leakage, and states that if pressure boundary leakage is
approximately 42 hours. Because this violation was of very low safety significance and
                                        25                                      Enclosure
it was entered into the licensee's corrective action program as IR 641375, this violation
 
was treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy. The LER is closed. (NCV 05000461/2007004-02).3Spent Fuel Bundle Incident During Rerack ProjectIntroduction: A performance deficiency involving a Non-Cited Violation of 10 CFRPart 50 Appendix B, Criteria V, "Instructions, Procedures, and Drawings," was
  present, the plant is required to be in Mode 3 in 12 hours and Mode 4 in 36 hours.
self-revealed following an event on August 17, 2007, where a spent fuel bundle being
  Contrary to the above, on June 18, 2007, pressure boundary leakage was present and
moved to a temporary storage location came in contact with and rested upon another
  the operators did not place the plant in Mode 3 for nearly 31 hours and Mode 4 for
fuel bundle seated in its storage location. The licensee procedure that governs spent
  approximately 42 hours. Because this violation was of very low safety significance and
fuel pool movement failed to provide adequate guidance on how high to lift the fuel
  it was entered into the licensees corrective action program as IR 641375, this violation
bundle prior to traversing across the spent fuel pool.Description: During spent fuel moves on August 17, 2007, in support of the spent fuelpool re-rack project, a spent fuel bundle being moved by a spent fuel bridge operator
  was treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy.
came in contact with the bail handle of a spent fuel bundle seated in its storage
  The LER is closed. (NCV 05000461/2007004-02)
location. Upon recognition of this situation the spent fuel bridge operator immediately
.3 Spent Fuel Bundle Incident During Rerack Project
stopped. Immediately following the stoppage of the spent fuel bridge the licensee
  Introduction: A performance deficiency involving a Non-Cited Violation of 10 CFR
observed that the fuel bundle was leaning slightly and the grapple-engaged light was
  Part 50 Appendix B, Criteria V, Instructions, Procedures, and Drawings, was
no longer lit. The grapple-engage light being no longer lit was an indication that the
  self-revealed following an event on August 17, 2007, where a spent fuel bundle being
grapple switch was no longer engaged and that an interlock was in place that
  moved to a temporary storage location came in contact with and rested upon another
prevented the fuel bundle from being lifted vertically. Prior to resuming fuel movement,
  fuel bundle seated in its storage location. The licensee procedure that governs spent
the licensee verified that the grapple was indeed engaged by use of an underwater
  fuel pool movement failed to provide adequate guidance on how high to lift the fuel
camera. After this verification, the interlock associated with the grapple-engage light
  bundle prior to traversing across the spent fuel pool.
was bypassed. The spent fuel bundle was then raised and placed back in its original
  Description: During spent fuel moves on August 17, 2007, in support of the spent fuel
location.A situation where a fuel bundle comes in contact with and rests upon another fuelbundle is a concern because it challenges the integrity of the fuel cladding. The fuel
  pool re-rack project, a spent fuel bundle being moved by a spent fuel bridge operator
cladding is considered one of three physical barriers designed to separate the fuel from
  came in contact with the bail handle of a spent fuel bundle seated in its storage
the public and the environment.Upon review of procedure CPS 3703.02,"Fuel Handling Platform Operations," theinspectors concluded that the procedure failed to provide adequate guidance on how
  location. Upon recognition of this situation the spent fuel bridge operator immediately
high the bundle should be lifted prior to moving the bundle to a new location. This
  stopped. Immediately following the stoppage of the spent fuel bridge the licensee
procedure was the administrative procedure which governs the operation of the bridge
  observed that the fuel bundle was leaning slightly and the grapple-engaged light was
and is used by the bridge operators to perform spent fuel pool movement. For example
  no longer lit. The grapple-engage light being no longer lit was an indication that the
step 8.2.2.15 requires lifting the bundle or blade until the grapple "normal up" light is lit
  grapple switch was no longer engaged and that an interlock was in place that
if moving the fuel bundle into the inclined fuel transfer system upender. The "normal
  prevented the fuel bundle from being lifted vertically. Prior to resuming fuel movement,
up" indication occurs at a reference vertical position ("Z" coordinate) of 0 inches. As
  the licensee verified that the grapple was indeed engaged by use of an underwater
the fuel bundle is lowered from the normal up position, the "Z" coordinate increases.
  camera. After this verification, the interlock associated with the grapple-engage light
Appendix A of the CPS 3703.02, showed several minimum fuel grapple "Z" coordinates  
  was bypassed. The spent fuel bundle was then raised and placed back in its original
Enclosure 27for various movements. The appendix showed that the fuel bundle must be at or above'Z' position of 66 inches to enter the spent fuel pool racks.The inspectors noted that a caution prior to step 8.2.2.15 states, "it is not required toraise the main hoist to normal up prior to platform or trolley movement, however
  location.
adequate clearance shall exist.The inspectors concluded that this step does not
  A situation where a fuel bundle comes in contact with and rests upon another fuel
  bundle is a concern because it challenges the integrity of the fuel cladding. The fuel
  cladding is considered one of three physical barriers designed to separate the fuel from
  the public and the environment.
  Upon review of procedure CPS 3703.02,Fuel Handling Platform Operations, the
  inspectors concluded that the procedure failed to provide adequate guidance on how
  high the bundle should be lifted prior to moving the bundle to a new location. This
  procedure was the administrative procedure which governs the operation of the bridge
  and is used by the bridge operators to perform spent fuel pool movement. For example
  step 8.2.2.15 requires lifting the bundle or blade until the grapple normal up light is lit
  if moving the fuel bundle into the inclined fuel transfer system upender. The normal
  up indication occurs at a reference vertical position (Z coordinate) of 0 inches. As
  the fuel bundle is lowered from the normal up position, the Z coordinate increases.
  Appendix A of the CPS 3703.02, showed several minimum fuel grapple Z coordinates
                                            26                                        Enclosure
 
for various movements. The appendix showed that the fuel bundle must be at or above
Z position of 66 inches to enter the spent fuel pool racks.
The inspectors noted that a caution prior to step 8.2.2.15 states, it is not required to
raise the main hoist to normal up prior to platform or trolley movement, however
adequate clearance shall exist. The inspectors concluded that this step does not
contain adequate guidance on how high to lift the fuel bundle prior to moving it to
contain adequate guidance on how high to lift the fuel bundle prior to moving it to
another location in the spent fuel pool. The inspectors concluded that the lack of
another location in the spent fuel pool. The inspectors concluded that the lack of
specific guidance caused this event to occur. Additionally, the procedure did not
specific guidance caused this event to occur. Additionally, the procedure did not
require any form of verification or peer checks prior to fuel movement.Analysis: The inspectors determined that the licensee's failure to provided adequatedetails in the procedure was a performance deficiency warranting a significance
require any form of verification or peer checks prior to fuel movement.
evaluation. The inspectors concluded that the finding was more than minor in
Analysis: The inspectors determined that the licensees failure to provided adequate
accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, because
details in the procedure was a performance deficiency warranting a significance
evaluation. The inspectors concluded that the finding was more than minor in
accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, because
the finding affects the barrier integrity objective of assuring that physical design barriers
the finding affects the barrier integrity objective of assuring that physical design barriers
protect the public from radionuclide releases caused by accidents or events. The
protect the public from radionuclide releases caused by accidents or events. The
finding is associated with the procedure quality attribute of the Barrier Integrity
finding is associated with the procedure quality attribute of the Barrier Integrity
cornerstone because it challenged the functionality of the fuel cladding.The inspectors completed a Phase 1 significance determination using IMC 0609,"Significance Determination Process," Appendix A, Attachment 1, dated
cornerstone because it challenged the functionality of the fuel cladding.
March 23,2007. Using IMC 0609 Appendix A, SDP Phase 1 screening worksheet, the
The inspectors completed a Phase 1 significance determination using IMC 0609,
Significance Determination Process, Appendix A, Attachment 1, dated
March 23,2007. Using IMC 0609 Appendix A, SDP Phase 1 screening worksheet, the
inspectors determined that this issue degraded only the Fuel Cladding Barrier and its
inspectors determined that this issue degraded only the Fuel Cladding Barrier and its
associated cornerstone. Therefore, in accordance with the screening worksheet, this
associated cornerstone. Therefore, in accordance with the screening worksheet, this
issue screens directly as Green. This finding is related to a cross-cutting component  
issue screens directly as Green. This finding is related to a cross-cutting component
in the area of Human Performance associated with Resources (H.2(c)) because the
in the area of Human Performance associated with Resources (H.2(c)) because the
licensee did not provide complete and accurate procedures. Specifically, the
licensee did not provide complete and accurate procedures. Specifically, the
procedure relied on the skill of the operator and did not require independent
procedure relied on the skill of the operator and did not require independent
verification.Enforcement: 10 CFR Part 50, Appendix B, Criteria V, "Instructions, Procedures, andDrawings" states that activities affecting quality shall be prescribed by documented
verification.
Enforcement: 10 CFR Part 50, Appendix B, Criteria V, Instructions, Procedures, and
Drawings states that activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appropriate to the circumstances and
instructions, procedures, or drawings, of a type appropriate to the circumstances and
shall be accomplished in accordance with these instructions, procedures, or drawings.  
shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, Clinton Power Station (CPS) procedure 3703.02 failed to
Contrary to the above, Clinton Power Station (CPS) procedure 3703.02 failed to
provide adequate instructions for handling spent fuel bundles. This resulted in a spent
provide adequate instructions for handling spent fuel bundles. This resulted in a spent
fuel bundle that was being moved to a temporary storage location coming in contact
fuel bundle that was being moved to a temporary storage location coming in contact
with another fuel bundle seated in its storage location on August 17, 2007. This issue
with another fuel bundle seated in its storage location on August 17, 2007. This issue
was entered into the licensee's corrective action program as issue report 661918.  
was entered into the licensees corrective action program as issue report 661918.
Corrective action included revising the fuel handling procedure. Because this violation
Corrective action included revising the fuel handling procedure. Because this violation
was of very low safety significance and was entered into the licensee's CA program,
was of very low safety significance and was entered into the licensees CA program,
this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRCEnforcement Policy. (NCV 05000451/2007-004-03)  
this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC
Enclosure 284OA4Cross-Cutting Aspects of Findings.1A finding described in section 4OA3.2 of this report had, as its primary cause, a HumanPerformance deficiency, in that, licensee decision making in determining the source of
Enforcement Policy. (NCV 05000451/2007-004-03)
a steam leak in the drywell resulted in exceeding the TS allowed time for placing the
                                          27                                      Enclosure
plant in Modes 3 and 4 when RCS pressure boundary leakage was present..2A finding described in section 4OA3.3 of this report had, as its primary cause, a HumanPerformance deficiency, in that, the licensee failed to provide adequate procedural
 
guidance in regard to moving spent fuel in the spent fuel pool.4OA6Meetings.1Exit MeetingThe inspectors presented the inspection results to Mr. B Hanson and other members oflicensee management at the conclusion of the inspection on October 4, 2007. The
4OA4 Cross-Cutting Aspects of Findings
inspectors asked the licensee whether any materials examined during the inspection
.1  A finding described in section 4OA3.2 of this report had, as its primary cause, a Human
should be considered proprietary. No proprietary information was identified..2Interim Exit MeetingsInterim exit meetings were conducted for:
    Performance deficiency, in that, licensee decision making in determining the source of
*Occupational Radiation Safety program for radiation monitoringinstrumentation and protective equipment with Mr. F. Kearney, Plant Manager on
    a steam leak in the drywell resulted in exceeding the TS allowed time for placing the
August 10, 2007.*Radioactive Material Processing and Transportation program with Mr. B. Hansonon September 21, 2007.ATTACHMENT: SUPPLEMENTAL INFORMATION  
    plant in Modes 3 and 4 when RCS pressure boundary leakage was present.
Attachment
.2  A finding described in section 4OA3.3 of this report had, as its primary cause, a Human
1SUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACT
    Performance deficiency, in that, the licensee failed to provide adequate procedural
LicenseeB. Hanson, Site Vice PresidentR. Kearney, Plant Manager
    guidance in regard to moving spent fuel in the spent fuel pool.
4OA6 Meetings
.1  Exit Meeting
    The inspectors presented the inspection results to Mr. B Hanson and other members of
    licensee management at the conclusion of the inspection on October 4, 2007. The
    inspectors asked the licensee whether any materials examined during the inspection
    should be considered proprietary. No proprietary information was identified.
.2  Interim Exit Meetings
    Interim exit meetings were conducted for:
    *   Occupational Radiation Safety program for radiation monitoring
          instrumentation and protective equipment with Mr. F. Kearney, Plant Manager on
          August 10, 2007.
    *   Radioactive Material Processing and Transportation program with Mr. B. Hanson
          on September 21, 2007.
ATTACHMENT: SUPPLEMENTAL INFORMATION
                                            28                                      Enclosure
 
                              SUPPLEMENTAL INFORMATION
                                KEY POINTS OF CONTACT
Licensee
B. Hanson, Site Vice President
R. Kearney, Plant Manager
R. Schenck, Work Management Director
R. Schenck, Work Management Director
G. Vickers, Radiation Protection Director
G. Vickers, Radiation Protection Director
Line 723: Line 1,282:
C. Williamson, Security Manager
C. Williamson, Security Manager
R. Peak, Site Engineering Director
R. Peak, Site Engineering Director
T. Chalmers, Shift Operations SuperintendentLIST OF ITEMS OPENED, CLOSED AND DISCUSSEDOpened05000461/2007004-01URIShipment Total Quantity Re-characterized AfterShipping (Section 2PS2.3)05000451/2007-004-01NCVInadequate Procurement Specification forCharcoal Results in Inoperable Control Room
T. Chalmers, Shift Operations Superintendent
Ventilation Subsystem05000451/2007-004-02 NCVFailure to Comply with Technical Specification3.4.5 for RCS Pressure Boundary Leak05000451/2007-004-03 NCVInadequate Procedure Results in Spent FuelBundle Incident
                    LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Closed05000461/2007-003-00 LERIGSCC Causes RCS Pressure Boundary Leakand Reactor Shutdown05000461/2005-001-00LER  Inadequate Procurement Specification forCharcoal Results in Inoperable Control Room
Opened
Ventilation Subsystem  
05000461/2007004-01          URI        Shipment Total Quantity Re-characterized After
Attachment
                                          Shipping (Section 2PS2.3)
205000451/2007-004-01NCVInadequate Procurement Specification forCharcoal Results in Inoperable Control Room
05000451/2007-004-01          NCV        Inadequate Procurement Specification for
Ventilation Subsystem05000451/2007-004-02 NCVFailure to Comply with Technical Specification3.4.5 for RCS Pressure Boundary Leak 05000451/2007-004-03 NCVInadequate Procedure Results in Spent FuelBundle Incident
                                          Charcoal Results in Inoperable Control Room
Discussed None  
                                          Ventilation Subsystem
Attachment
05000451/2007-004-02         NCV        Failure to Comply with Technical Specification
3LIST OF DOCUMENTS REVIEWEDThe following is a list of documents reviewed during the inspection. Inclusion on this list doesnot imply that the NRC inspectors reviewed the documents in their entirety but rather that
                                          3.4.5 for RCS Pressure Boundary Leak
05000451/2007-004-03         NCV        Inadequate Procedure Results in Spent Fuel
                                          Bundle Incident
Closed
05000461/2007-003-00         LER        IGSCC Causes RCS Pressure Boundary Leak
                                          and Reactor Shutdown
05000461/2005-001-00          LER        Inadequate Procurement Specification for
                                          Charcoal Results in Inoperable Control Room
                                          Ventilation Subsystem
                                            1                                    Attachment
 
05000451/2007-004-01 NCV Inadequate Procurement Specification for
                        Charcoal Results in Inoperable Control Room
                        Ventilation Subsystem
05000451/2007-004-02 NCV Failure to Comply with Technical Specification
                        3.4.5 for RCS Pressure Boundary Leak
05000451/2007-004-03 NCV Inadequate Procedure Results in Spent Fuel
                        Bundle Incident
Discussed
None
                            2                                    Attachment
 
                                LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety but rather that
selected sections of portions of the documents were evaluated as part of the overall inspection
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
any part of it, unless this is stated in the body of the inspection report.
1R01Adverse WeatherOP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines; Revision 2OP-AA-102-102, General Area Checks and Operator Field Rounds; Revision 5
1R01 Adverse Weather
OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines; Revision 2
OP-AA-102-102, General Area Checks and Operator Field Rounds; Revision 5
WC-AA-107, Seasonal Readiness; Revision 3
WC-AA-107, Seasonal Readiness; Revision 3
CPS 1019.05, Transient Equipment/Materials; Revision 11
CPS 1019.05, Transient Equipment/Materials; Revision 11
CPS 4302.01, Tornado/High Winds; Revision 18e
CPS 4302.01, Tornado/High Winds; Revision 18e
1R04Equipment AlignmentsCPS 3319.01V001, Standby Gas Treatment Valve Lineup; Revision 8CPS 3319.01E001, Standby Gas Treatment Electrical Lineup; Revision 10c
1R04 Equipment Alignments
1R05Fire ProtectionCPS 1893.04M310, 719 Control: HVAC Equipment Area Pre-fire Plan; Revision 5aSection 3.2.1.2, "Fire Area A-2: Zone A-2a", Fire Protection Evaluation Report,
CPS 3319.01V001, Standby Gas Treatment Valve Lineup; Revision 8
CPS 3319.01E001, Standby Gas Treatment Electrical Lineup; Revision 10c
1R05 Fire Protection
CPS 1893.04M310, 719 Control: HVAC Equipment Area Pre-fire Plan; Revision 5a
Section 3.2.1.2, Fire Area A-2: Zone A-2a, Fire Protection Evaluation Report,
CPS 1893.01, Fire Protection Impairment Reporting, Revision 16a
CPS 1893.01, Fire Protection Impairment Reporting, Revision 16a
CPS Updated Final Safety Analysis Report, Fire Hazard Analysis
CPS Updated Final Safety Analysis Report, Fire Hazard Analysis
Line 754: Line 1,343:
on Containment Monitoring Test Lines
on Containment Monitoring Test Lines
IR 660299, Type C Testing for LLRT Test Lines
IR 660299, Type C Testing for LLRT Test Lines
1R06Flood ProtectionCPS 4304.01, "Flooding," Revision 4eIR 670686, "Setpoints For Maximum Normal Operating Water Level Switches"
1R06 Flood Protection
IR 670693, "Flood Water Level & Secondary Containment Temperature Instrumentation"
CPS 4304.01, Flooding, Revision 4e
IR 670429, "Max Safe Flood Alarm Out of Cal in RH [residual heat removal] A Room"
IR 670686, Setpoints For Maximum Normal Operating Water Level Switches
IR 670415, "Max Safe Flood Alarms Out of Cal in RI Pump Room"
IR 670693, Flood Water Level & Secondary Containment Temperature Instrumentation
1R07Heat Sink PerformanceWO 1005225, Open, Inspect, Boroscope, Eddy Current 100%, and Clean 1DG13AER-AA-340-1002, Service water heat exchanger and component inspection guide; Revision 3
IR 670429, Max Safe Flood Alarm Out of Cal in RH [residual heat removal] A Room
IR 670415, Max Safe Flood Alarms Out of Cal in RI Pump Room
1R07 Heat Sink Performance
WO 1005225, Open, Inspect, Boroscope, Eddy Current 100%, and Clean 1DG13A
ER-AA-340-1002, Service water heat exchanger and component inspection guide; Revision 3
IR 678934, Division three diesel generator heat exchanger chemistry results; October 2, 2007
IR 678934, Division three diesel generator heat exchanger chemistry results; October 2, 2007
IR 675035, Diesel generator jacket water cooler zinc modification execution impact;
IR 675035, Diesel generator jacket water cooler zinc modification execution impact;
September 24, 2007  
September 24, 2007
Attachment
                                                  3                                  Attachment
4IR 675091, Excessive erosion discovered on the flange faces of 1VH03A; September 25, 2007WO 01005225, Open, Inspect, Boroscope, Eddy Current 100%, and Clean
 
IR 675091, Excessive erosion discovered on the flange faces of 1VH03A; September 25, 2007
WO 01005225, Open, Inspect, Boroscope, Eddy Current 100%, and Clean
AR 00678934, Division II Diesel Generator HX (1DG13A) Chemistry Results
AR 00678934, Division II Diesel Generator HX (1DG13A) Chemistry Results
AR 00675035, Diesel Generator Jacket Water Cooler Zinc Mod Execution Impact
AR 00675035, Diesel Generator Jacket Water Cooler Zinc Mod Execution Impact
ER-AA-340-1002, Service Water Heat Exchanger and Component Inspection Guide,
ER-AA-340-1002, Service Water Heat Exchanger and Component Inspection Guide,
Revision 3
Revision 3
1R12Maintenance EffectivenessIR 518197, "NOS ID MSPI Basis Document Requires Revision"IR 519897, "Potential Air Leak on 1VQ002 or 1VQ005"
1R12 Maintenance Effectiveness
IR 520828, "CPS 4001.02C001 Setpoint Update Needed"
IR 518197, NOS ID MSPI Basis Document Requires Revision
IR 524365, "Automatic Reactor Scram on Reactor High Water Level"
IR 519897, Potential Air Leak on 1VQ002 or 1VQ005
IR 524768, "RCIC Isolation Troubleshooting Results"
IR 520828, CPS 4001.02C001 Setpoint Update Needed
IR 552156, "Condition Monitoring Failure - LD Inst 1E31N085A - RCIC Isolation"
IR 524365, Automatic Reactor Scram on Reactor High Water Level
IR 550868, "1SX01PA: Low Margin for Division I SX Design Flows"
IR 524768, RCIC Isolation Troubleshooting Results
IR 548493, "1C91P633: STS Failure, 5004-3H, RCIC Division 1 Card C-A14-A125"
IR 552156, Condition Monitoring Failure - LD Inst 1E31N085A - RCIC Isolation
IR 530970, "Invalid Assumption in Calculation"
IR 550868, 1SX01PA: Low Margin for Division I SX Design Flows
IR 556556, "Unexpected Annunciators during STS Summary Card B-A11-A111"
IR 548493, 1C91P633: STS Failure, 5004-3H, RCIC Division 1 Card C-A14-A125
IR 557804, "Evaluate Transmitter 1E31N085B Time Delay Settings"
IR 530970, Invalid Assumption in Calculation
IR 557809, "Received Annunciator 5004-3H, STS Failure"
IR 556556, Unexpected Annunciators during STS Summary Card B-A11-A111
IR 648094, "1E51-F054 RCIC Drain Pot Bypass Valve has Small Packing Leak"
IR 557804, Evaluate Transmitter 1E31N085B Time Delay Settings
IR 639727, "RCIC Pump Outboard Bearing Bubbler Crosshairs not @ 90 Degrees"
IR 557809, Received Annunciator 5004-3H, STS Failure
IR 631320, "NRC Question: Impact of EC 365827 Changes on Close Time Test"
IR 648094, 1E51-F054 RCIC Drain Pot Bypass Valve has Small Packing Leak
IR 589210, "RCIC Speed > 4600 RPM during Surveillance Testing"
IR 639727, RCIC Pump Outboard Bearing Bubbler Crosshairs not @ 90 Degrees
IR 589461, "Found RCIC Turbine & Governor Oil Below the Standby Band"
IR 631320, NRC Question: Impact of EC 365827 Changes on Close Time Test
IR 627033, "1E51-N590: New RGSC Card Cat ID 1148300-01 Failed Testing"
IR 589210, RCIC Speed > 4600 RPM during Surveillance Testing
IR 587482, "1E51F046 Potential MOV Over Thrust Risk"
IR 589461, Found RCIC Turbine & Governor Oil Below the Standby Band
IR 584757, "1E51N590: RCIC RGSC Module Replacement & Procedure Enhance"
IR 627033, 1E51-N590: New RGSC Card Cat ID 1148300-01 Failed Testing
IR 562400, "1 Foot Steam Plum Leak at Base of 1E51N010"
IR 587482, 1E51F046 Potential MOV Over Thrust Risk
IR 555469, "1E51N010: 5063-2C Turbine Stm Line Wtr Drain Trap Level High"
IR 584757, 1E51N590: RCIC RGSC Module Replacement & Procedure Enhance
IR 555312, "Crack Found in Housing for Level Switch during WO 924362"
IR 562400, 1 Foot Steam Plum Leak at Base of 1E51N010
IR 535878, "Minor Steam Leak under Insulation of RCIC Turbine 1E51-C002"
IR 555469, 1E51N010: 5063-2C Turbine Stm Line Wtr Drain Trap Level High
IR 531654, "RCIC Quick Start Surv CPS 9054.01C004"
IR 555312, Crack Found in Housing for Level Switch during WO 924362
IR 531065, "RCIC Turbine Stayed at Incorrect Speed during 9054.01C004"
IR 535878, Minor Steam Leak under Insulation of RCIC Turbine 1E51-C002
IR 529655, "NOS ID'D RCIC Restoration with out of Cal Pressure Transmi"
IR 531654, RCIC Quick Start Surv CPS 9054.01C004
IR 528901, "IMD Lessons Learned form 1E31N085A Replacement"
IR 531065, RCIC Turbine Stayed at Incorrect Speed during 9054.01C004
IR 524345, "RCIC Division 1 Isolated Following Scram"
IR 529655, NOS IDD RCIC Restoration with out of Cal Pressure Transmi
IR 517311, "Revise ARP's 5062-3D & 5063-2E and 3310.01"
IR 528901, IMD Lessons Learned form 1E31N085A Replacement
IR 517453, "New Fittings for RCIC Vortex Mod does not Match Design"
IR 524345, RCIC Division 1 Isolated Following Scram
IR 517558, "Mini-PM for RCIC Turbine 1E51-C002 - C1R11"
IR 517311, Revise ARPs 5062-3D & 5063-2E and 3310.01
IR 517768, "Feasibility Study for RPV Head Piping"
IR 517453, New Fittings for RCIC Vortex Mod does not Match Design
IR 517775, "Security Required for RCIC Tank Control Sooner than Planned"
IR 517558, Mini-PM for RCIC Turbine 1E51-C002 - C1R11
IR 517874, "TS 3.3.3.2, Remote Shutdown Instrumentation, Enhancement"
IR 517768, Feasibility Study for RPV Head Piping
IR 518522, "E51-N655F Failed Initial  
IR 517775, Security Required for RCIC Tank Control Sooner than Planned
+/- .25% Input/Output Comparison"IR 518849, "Heater Support Stands not secured to Tank"
IR 517874, TS 3.3.3.2, Remote Shutdown Instrumentation, Enhancement
IR 518932, "Free Release of Transmitters"
IR 518522, E51-N655F Failed Initial +/- .25% Input/Output Comparison
IR 519207, "Transposition Error for RPM Values - RCIC Turbine Speed"
IR 518849, Heater Support Stands not secured to Tank
IR 519208, "1TR-CM018 Points above Alarm Setpoint with no Alarm Leds Lit"
IR 518932, Free Release of Transmitters
IR 519566, "Items Discovered on Carts not Properly RAM Tagged/Controlled"
IR 519207, Transposition Error for RPM Values - RCIC Turbine Speed
Attachment
IR 519208, 1TR-CM018 Points above Alarm Setpoint with no Alarm Leds Lit
5IR 519776, "Red Hose Found by RCIC Tank"IR 520032, "NOS ID - Unavailability Baseline Data Errors in MSPI Basis Doc"
IR 519566, Items Discovered on Carts not Properly RAM Tagged/Controlled
IR 520069, "Work Week Preps Did Not Identify Issues"
                                              4                              Attachment
IR 520293, "NRC Question on MSPI Implementation"
 
IR 520803, "Contamination Found on Floor in RCIC Tank Valve Room"
IR 519776, Red Hose Found by RCIC Tank
IR 520906, "TS LCO 3.3.5.1/3.3.5.2 Logical Connections Need Indenting"
IR 520032, NOS ID - Unavailability Baseline Data Errors in MSPI Basis Doc
IR 522049, "NSRB Issue - Unsecured Cables at Contaminated Area Boundary"
IR 520069, Work Week Preps Did Not Identify Issues
IR 522119, "NOS ID - Deficiencies Found During NSRB Tour"
IR 520293, NRC Question on MSPI Implementation
IR 523330, "NRC Identified MSPI Basis Document Error for HP"
IR 520803, Contamination Found on Floor in RCIC Tank Valve Room
IR 524547, "Possible Training Process Problem"
IR 520906, TS LCO 3.3.5.1/3.3.5.2 Logical Connections Need Indenting
IR 524893, "Poor Decision Making in PORC Meeting"
IR 522049, NSRB Issue - Unsecured Cables at Contaminated Area Boundary
IR 525078, "Actions Required RCIC High Steam Flow Time Delay EC 362261"
IR 522119, NOS ID - Deficiencies Found During NSRB Tour
IR 526991, "Correction Needed for IR 518932 Response"
IR 523330, NRC Identified MSPI Basis Document Error for HP
IR 528013, "New Card Received Damaged from Stores"
IR 524547, Possible Training Process Problem
IR 528655, "NOS ID Line Not Properly Controlled"
IR 524893, Poor Decision Making in PORC Meeting
IR 528787, "RP Work Practices Need Improvement"
IR 525078, Actions Required RCIC High Steam Flow Time Delay EC 362261
IR 529288, "Enhancements to RCIC Restoration Procedure"
IR 526991, Correction Needed for IR 518932 Response
IR 529423, "NOS ID Technical Rigor Weakness for RCIC OpEval 524768-02"
IR 528013, New Card Received Damaged from Stores
IR 529475, "Revise Tornado Missile Hazard Analysis"
IR 528655, NOS ID Line Not Properly Controlled
IR 529411, "Change to 9054.01C004, RCIC Quick Start Surveillance"
IR 528787, RP Work Practices Need Improvement
IR 529718, "Process Improvements in Status Control"
IR 529288, Enhancements to RCIC Restoration Procedure
IR 531090, "Enhancements: Clarify Tech Spec Bases for LCO 3.5.3 "RCIC""
IR 529423, NOS ID Technical Rigor Weakness for RCIC OpEval 524768-02
IR 531215, "RCIC Procedure Lacks Steam Line Draining Steps"
IR 529475, Revise Tornado Missile Hazard Analysis
IR 531392, "Ramp Generator Card Received with Jumper not used at CPS"
IR 529411, Change to 9054.01C004, RCIC Quick Start Surveillance
IR 531410, "FLS Provided Inaccurate Estimate for First Time Performance"
IR 529718, Process Improvements in Status Control
IR 531412, "RCIC Ramp Generator Card in Repair Program"
IR 531090, Enhancements: Clarify Tech Spec Bases for LCO 3.5.3 RCIC
IR 537945, "Support for Estimating Flows for Mitigating Strategies"
IR 531215, RCIC Procedure Lacks Steam Line Draining Steps
IR 539389, "Trng: Simulator: Simulator Responses to Evaluated Scenario"
IR 531392, Ramp Generator Card Received with Jumper not used at CPS
IR 541955, "RCIC Isolations Incorrectly Referenced in CPS 9532.16"
IR 531410, FLS Provided Inaccurate Estimate for First Time Performance
IR 543371, "Potential Trend in Equipment Failure Cause Identification"
IR 531412, RCIC Ramp Generator Card in Repair Program
IR 543520, "Evaluate Common Causes of RCIC System Issues"
IR 537945, Support for Estimating Flows for Mitigating Strategies
IR 543638, "NOS-ID Appropriate Cause Evaluation not Assigned"
IR 539389, Trng: Simulator: Simulator Responses to Evaluated Scenario
IR 543661, "Enhancement IR to Revise 9080.23"
IR 541955, RCIC Isolations Incorrectly Referenced in CPS 9532.16
IR 546682, "Trng: Drawing Reference is Incorrect"
IR 543371, Potential Trend in Equipment Failure Cause Identification
IR 553475, "1LL59BP18E: Electrolyte Level below Plates on Two Cells"
IR 543520, Evaluate Common Causes of RCIC System Issues
IR 554669, "B.5.B Phase 2 and 3 Closure Actions"
IR 543638, NOS-ID Appropriate Cause Evaluation not Assigned
IR 555735, "Expectation not Met as Required by CPS Policy #54"
IR 543661, Enhancement IR to Revise 9080.23
IR 556474, "Ownership of 3209.01 Raw Water Treatment"
IR 546682, Trng: Drawing Reference is Incorrect
IR 557274, "E-2 Ready to Work Exceptions not in Goal for WW645"
IR 553475, 1LL59BP18E: Electrolyte Level below Plates on Two Cells
IR 557833, "RCIC Vent Pipe Leaks at Sampling Point with Sample Equipment"
IR 554669, B.5.B Phase 2 and 3 Closure Actions
IR 558269, "Fix RCIC Sampling"
IR 555735, Expectation not Met as Required by CPS Policy #54
IR 559377, "NOS ID Separation Criteria not Maintained During EC Install"
IR 556474, Ownership of 3209.01 Raw Water Treatment
IR 560786, "NOS ID'd Gaps in Technical Rigor Used in OP Determinations"
IR 557274, E-2 Ready to Work Exceptions not in Goal for WW645
IR 561779, "9030.01C034 & C035 Missing an Expected Alarm"
IR 557833, RCIC Vent Pipe Leaks at Sampling Point with Sample Equipment
IR 562215, "Security Tour Improvement Opportunities"
IR 558269, Fix RCIC Sampling
IR 562813, "Procedural Conflict for RCIC Instrument Valve Position"
IR 559377, NOS ID Separation Criteria not Maintained During EC Install
IR 563344, "1E51F378 has Minor Packing Leak"
IR 560786, NOS IDd Gaps in Technical Rigor Used in OP Determinations
IR 563348, "Minor Oil Leaks on Oil Sightglass & Govenor Assembly"
IR 561779, 9030.01C034 & C035 Missing an Expected Alarm
IR 563632, "Replace LD Transmitters to Prevent RCIC Isolation"
IR 562215, Security Tour Improvement Opportunities
Attachment
IR 562813, Procedural Conflict for RCIC Instrument Valve Position
6IR 563745, "Generate WO for LD Transmitter in Relation to CR-563632"IR 565444, "NRC Non-Cited Violation 2006-11-02, RCIC Suction Vortexing"
IR 563344, 1E51F378 has Minor Packing Leak
IR 567532, "RCIC Valve 1E51-337 with Lockwire"
IR 563348, Minor Oil Leaks on Oil Sightglass & Govenor Assembly
IR 569112, "ORM NTSP Value Incorrect for RCIC Storage Tank Level Low"
IR 563632, Replace LD Transmitters to Prevent RCIC Isolation
IR 570095, "NOS ID Project Plan for PI&R Inspection not Developed"
                                              5                            Attachment
IR 570783, "Cause Analysis for HPCS Vortex Issue"
 
IR 574514, "Inappropriate Assignment of Corrective Actions"
IR 563745, Generate WO for LD Transmitter in Relation to CR-563632
IR 579912, "C1R11 Surv Opt HIT - 9438.05 Enhancements"
IR 565444, NRC Non-Cited Violation 2006-11-02, RCIC Suction Vortexing
IR 582944, "Non-Oily Sheen on Top of Suppression Pool"
IR 567532, RCIC Valve 1E51-337 with Lockwire
IR 583348, "Clean Up of Cask Wash Down Pit"
IR 569112, ORM NTSP Value Incorrect for RCIC Storage Tank Level Low
IR 585490, "Black Marker Found Floating in Suppression Pool"
IR 570095, NOS ID Project Plan for PI&R Inspection not Developed
IR 588801, "Procedure Enhancement to 9030.01C34"
IR 570783, Cause Analysis for HPCS Vortex Issue
IR 588802, "Procedure Enhancement to 9030.01C035 RI MS Sup Press"
IR 574514, Inappropriate Assignment of Corrective Actions
IR 588886, "Enhance to 9054.02"
IR 579912, C1R11 Surv Opt HIT - 9438.05 Enhancements
IR 589228, "1RI01T: Notice of Violation (White Finding) Related to HPCS"
IR 582944, Non-Oily Sheen on Top of Suppression Pool
IR 590313, "Division 1 ADS Backup Air Bottles Losing 25-50 # per Day"
IR 583348, Clean Up of Cask Wash Down Pit
IR 596320, "Perform ISI/NDE and Provide Support Work Pre C1R11"
IR 585490, Black Marker Found Floating in Suppression Pool
IR 597183, "Trng - Revision Needed to Operations Strategies Document"
IR 588801, Procedure Enhancement to 9030.01C34
IR 599370, "Install Walkway across Berm at the RCIC Tank"
IR 588802, Procedure Enhancement to 9030.01C035 RI MS Sup Press
IR 599388, "Install Sidewalk to RCIC Tank"
IR 588886, Enhance to 9054.02
IR 599404, "Install Gate on Existing Walkway"
IR 589228, 1RI01T: Notice of Violation (White Finding) Related to HPCS
IR 599942, "Procedure Review/Enhancement for Remote Shutdown Actions"
IR 590313, Division 1 ADS Backup Air Bottles Losing 25-50 # per Day
IR 599989, "RCIC TTV Gimpel Valve Discontinuation Future Material"
IR 596320, Perform ISI/NDE and Provide Support Work Pre C1R11
IR 600927, "RCR Identifies Weakness in OP-AA-108-115/OP-AA-106-1006"
IR 597183, Trng - Revision Needed to Operations Strategies Document
IR 600993, "INPO CDE Website, MSPI PRA Data"
IR 599370, Install Walkway across Berm at the RCIC Tank
IR 603347, "NOS ID Post August 2006 Organization Weakness not Addressed"
IR 599388, Install Sidewalk to RCIC Tank
IR 603659, "NOS ID Inadequate Appl of Standards during Work Activities"
IR 599404, Install Gate on Existing Walkway
IR 604716, "1E51-N636A as Found DAC Values OOT"
IR 599942, Procedure Review/Enhancement for Remote Shutdown Actions
IR 608092, "Trng - Changes to Transient Mitigation Needed"
IR 599989, RCIC TTV Gimpel Valve Discontinuation Future Material
IR 608292, "2007 NRC PI&R Observation on Use of OPEX"
IR 600927, RCR Identifies Weakness in OP-AA-108-115/OP-AA-106-1006
IR 610762, "Work Orders Removed from Week 0719 Parts"
IR 600993, INPO CDE Website, MSPI PRA Data
IR 610943, "PMRQ for RV 1E12-F036 Specifies Incorrect Testing and Freque"
IR 603347, NOS ID Post August 2006 Organization Weakness not Addressed
IR 613782, "9027.01C007 Section 8.7.7 Challenges SX Loads"
IR 603659, NOS ID Inadequate Appl of Standards during Work Activities
IR 613800, "Work Orders Removed from Week 0719"
IR 604716, 1E51-N636A as Found DAC Values OOT
IR 615740, "NOS ID Stated Apparent Cause was not addressed in EOC"
IR 608092, Trng - Changes to Transient Mitigation Needed
IR 617461, "RCIC Isolation Bypass Switch Operations in not Crisp"
IR 608292, 2007 NRC PI&R Observation on Use of OPEX
IR 618123, "E-4 Clearance Indicator not at Goal of 100%"
IR 610762, Work Orders Removed from Week 0719 Parts
IR 602553, "RCIC Transmitters not Available for SOW"
IR 610943, PMRQ for RV 1E12-F036 Specifies Incorrect Testing and Freque
IR 602760, "Perform Inspection of Component Supports and Support"
IR 613782, 9027.01C007 Section 8.7.7 Challenges SX Loads
IR 602867, "Procedure Enhancement for Filling RCIC Storage Tank"
IR 613800, Work Orders Removed from Week 0719
IR 618251, "Fuse Missing form Interlock for Doors 329 and 330"
IR 615740, NOS ID Stated Apparent Cause was not addressed in EOC
IR 618423, "Trng - Enhancement to 3310.01 RCIC"
IR 617461, RCIC Isolation Bypass Switch Operations in not Crisp
IR 619749, "Tornado Missile Found in the RCIC Berm"
IR 618123, E-4 Clearance Indicator not at Goal of 100%
IR 621632, "NOS ID Trend Codes for CAP Products not Consistency Entered"
IR 602553, RCIC Transmitters not Available for SOW
IR 622636, "Enhancement to ECCS Availability Due to WL Pump Availability"
IR 602760, Perform Inspection of Component Supports and Support
IR 622674, "Missed Opportunity: Late Cancellation of a Work Order"
IR 602867, Procedure Enhancement for Filling RCIC Storage Tank
IR 623199, "RAT SVC Tripped Resulting in Unplnd Entry into 72 hr SD LCO"
IR 618251, Fuse Missing form Interlock for Doors 329 and 330
IR 623608, "RCIC System Outage Questions"
IR 618423, Trng - Enhancement to 3310.01 RCIC
IR 623611, "CDBI FASA Â*" Configured Design Specification not Updated"
IR 619749, Tornado Missile Found in the RCIC Berm
Attachment
IR 621632, NOS ID Trend Codes for CAP Products not Consistency Entered
7IR 624129, "Use of Admin Controls during RCIC Surveillance"IR 624937, "WO 19406 Removed from Week 0719 due to Parts"
IR 622636, Enhancement to ECCS Availability Due to WL Pump Availability
IR 625517, "MSPI Related Work Windows are not Consistently Scheduled"
IR 622674, Missed Opportunity: Late Cancellation of a Work Order
IR 626291, "A TDRFP Oil Leak at 1PSFW105"
IR 623199, RAT SVC Tripped Resulting in Unplnd Entry into 72 hr SD LCO
IR 626496, "RHR Unprojected Unavailability SSPI/MSPI Impact"
IR 623608, RCIC System Outage Questions
IR 626577, "Clearance Program Tag Font Remains Ambiguous/Unclear"
IR 623611, CDBI FASA Â Configured Design Specification not Updated
IR 626578, "Safety - Cannot Access Scaffold #5465 Safely"
                                              6                          Attachment
IR 627067, "1C88N2403: TT Point 30 Failed Calibration"
 
IR 627527, "1E51N003: Computer Point E51DA001 Out of Spec Low (OOT)"
IR 624129, Use of Admin Controls during RCIC Surveillance
IR 627710, "Enhancement to ARP 5063-2D"
IR 624937, WO 19406 Removed from Week 0719 due to Parts
IR 628094, "1C88K607: Received Spurious Trip of TTHMI Server Channel 119"
IR 625517, MSPI Related Work Windows are not Consistently Scheduled
IR 628259, "CDBI FASA Enhancement to Loss of AC Off Normal 4200.01"
IR 626291, A TDRFP Oil Leak at 1PSFW105
IR 629191, "CDBI FASA - Check Valve 1E22-F016 Not in ATLAS"
IR 626496, RHR Unprojected Unavailability SSPI/MSPI Impact
IR 630647, "1RIX-AR013 Alert Alarm due to Spike"
IR 626577, Clearance Program Tag Font Remains Ambiguous/Unclear
IR 632033, "PMS Requires Valve Cycling in D/W and STM Tunnel"
IR 626578, Safety - Cannot Access Scaffold #5465 Safely
IR 632043, "LL on LLRT Type C Test"
IR 627067, 1C88N2403: TT Point 30 Failed Calibration
IR 632321, "Enhancement to CPS 3315.02, Leak Detection (LD)"
IR 627527, 1E51N003: Computer Point E51DA001 Out of Spec Low (OOT)
IR 632785, "CDBI FASA: Leakage to RCIC Tank not Updated in Alt. ST Docs"
IR 627710, Enhancement to ARP 5063-2D
IR 634385, "Placement of Red/Green Dots in the MCR"
IR 628094, 1C88K607: Received Spurious Trip of TTHMI Server Channel 119
IR 634633, "INPO Walk Downs List of Discrepancies"
IR 628259, CDBI FASA Enhancement to Loss of AC Off Normal 4200.01
IR 635283, "1VX14S Air Gap Between Housing and Cooling Coils 1VX14AA/AB"
IR 629191, CDBI FASA - Check Valve 1E22-F016 Not in ATLAS
IR 636156, "NRC Performance Indicator for SSFFS in Action Region"
IR 630647, 1RIX-AR013 Alert Alarm due to Spike
IR 636753, "Chemistry Sample Results for 1VY04A RCIC Room Cooler"
IR 632033, PMS Requires Valve Cycling in D/W and STM Tunnel
IR 636859, "9030.01C007 Enhancement"
IR 632043, LL on LLRT Type C Test
IR 637549, "Trng - Procedure Enhancement 3310.01 RCIC"
IR 632321, Enhancement to CPS 3315.02, Leak Detection (LD)
IR 638917, "1C71S001C: Unexpected Alarms Division 3 NSPS Inverter"
IR 632785, CDBI FASA: Leakage to RCIC Tank not Updated in Alt. ST Docs
IR 641088, "No Engineered Test Points for Jumper/Test Leads in 9532.13"
IR 634385, Placement of Red/Green Dots in the MCR
IR 644916, "Set Test Condition for RI Min Flow Valve Therm. Overl. Test"
IR 634633, INPO Walk Downs List of Discrepancies
IR 647267, "1C91P633: Received 5004-3H STS Failure"
IR 635283, 1VX14S Air Gap Between Housing and Cooling Coils 1VX14AA/AB
IR 648508, "3220.01 Requires Revision to Support C1R11"
IR 636156, NRC Performance Indicator for SSFFS in Action Region
IR 649191, "Procedure Step Needs Revision Regarding Bypass Switch"
IR 636753, Chemistry Sample Results for 1VY04A RCIC Room Cooler
IR 652248, "CAPR not Implemented as Worded"
IR 636859, 9030.01C007 Enhancement
IR 654201, "NOS ID: Trending of PAR Data for Common Causes"
IR 637549, Trng - Procedure Enhancement 3310.01 RCIC
IR 616603, "1E51N052: Unexpected MCR Alarm During 9054.06"
IR 638917, 1C71S001C: Unexpected Alarms Division 3 NSPS Inverter
IR 654764, "NRC Questions RCIC Turbine Inboard Bearing Oil Level"
IR 641088, No Engineered Test Points for Jumper/Test Leads in 9532.13
IR 627562, "1E51F064: Abnormal Voltage Indicated During Surveillance"
IR 644916, Set Test Condition for RI Min Flow Valve Therm. Overl. Test
IR 627546, "9861.02D015 Test Set A had Leakage in Excess of 20,000 SCCM"
IR 647267, 1C91P633: Received 5004-3H STS Failure
ER-AA-310, "Implementation of the Maintenance Rule," Revision 6
IR 648508, 3220.01 Requires Revision to Support C1R11
ER-AA-310-1001, "Maintenance Rule - Scoping," Revision 3
IR 649191, Procedure Step Needs Revision Regarding Bypass Switch
ER-AA-310-1002, "Maintenance Rule - SSC Risk Significance Determination," Revision 2
IR 652248, CAPR not Implemented as Worded
ER-AA-310-1003, "Maintenance Rule - Performance Criteria Selection," Revision 3
IR 654201, NOS ID: Trending of PAR Data for Common Causes
ER-AA-310-1004, "Maintenance Rule - Performance Monitoring," Revision 5
IR 616603, 1E51N052: Unexpected MCR Alarm During 9054.06
ER-AA-310-1005, "Maintenance Rule - Dispositioning Between (a) (1) and (a) (2)," Revision 5
IR 654764, NRC Questions RCIC Turbine Inboard Bearing Oil Level
ER-AA-310-1006, "Maintenance Rule - Expert Panel Roles and Responsibilities," Revision 3
IR 627562, 1E51F064: Abnormal Voltage Indicated During Surveillance
ER-AA-310-1007, "Maintenance Rule - Periodic (a) (3) Assessment," Revision 4
IR 627546, 9861.02D015 Test Set A had Leakage in Excess of 20,000 SCCM
ER-AA-310, Implementation of the Maintenance Rule, Revision 6
ER-AA-310-1001, Maintenance Rule - Scoping, Revision 3
ER-AA-310-1002, Maintenance Rule - SSC Risk Significance Determination, Revision 2
ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 3
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 5
ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a) (1) and (a) (2), Revision 5
ER-AA-310-1006, Maintenance Rule - Expert Panel Roles and Responsibilities, Revision 3
ER-AA-310-1007, Maintenance Rule - Periodic (a) (3) Assessment, Revision 4
Performance Criteria Report for RI System
Performance Criteria Report for RI System
Failure Report for RI System
Failure Report for RI System
Scoping/Risk Significance Detailed Report for RI System  
Scoping/Risk Significance Detailed Report for RI System
Attachment
                                              7                                  Attachment
8Assessment of Maintenance Effectiveness; 10CFR50.65 (a) (3) Assessment; Clinton PowerStation; 3/1/2004 to 3/1/2006.
 
Assessment of Maintenance Effectiveness; 10CFR50.65 (a) (3) Assessment; Clinton Power
Station; 3/1/2004 to 3/1/2006.
CPS Technical Specifications: TS 3.8.4, 3.8.5, and 3.8.6 and associated bases
CPS Technical Specifications: TS 3.8.4, 3.8.5, and 3.8.6 and associated bases
USAR Section 8.3.2
USAR Section 8.3.2
Line 962: Line 1,567:
IR 651865, Potential Adverse Trend on Division 4 DC Bus Voltage
IR 651865, Potential Adverse Trend on Division 4 DC Bus Voltage
CPS System DC Equipment Failure Report for July 2005 to July 2007
CPS System DC Equipment Failure Report for July 2005 to July 2007
1R15Operability EvaluationsIR 671001, Essential switchgear cooling "C" shutdown service water line thickness belowminimum screening criteria; September 13, 2007
1R15 Operability Evaluations
IR 671001, Essential switchgear cooling C shutdown service water line thickness below
minimum screening criteria; September 13, 2007
EC 367363, Minimum wall calculation for reducer small ends for 3"X1.5" swg at valve
EC 367363, Minimum wall calculation for reducer small ends for 3"X1.5" swg at valve
1SX025C on line 1SX23AC-3", Revision 0
1SX025C on line 1SX23AC-3", Revision 0
Line 976: Line 1,583:
IR 668221, ASME code case N-513-1, augmented volumetric exam of 1SX23AC;
IR 668221, ASME code case N-513-1, augmented volumetric exam of 1SX23AC;
September 5, 2007
September 5, 2007
IR 668223, ASME code case N-513-1, augmented volumetric exam of 1SX04AC;  
IR 668223, ASME code case N-513-1, augmented volumetric exam of 1SX04AC;
September 5, 2007
September 5, 2007
IR 668304, Division 3 control room ventilation chiller shutdown service water supply/return
IR 668304, Division 3 control room ventilation chiller shutdown service water supply/return
Line 982: Line 1,589:
IR 670094, Division 3 shutdown service water ultrasonic testing results below screening
IR 670094, Division 3 shutdown service water ultrasonic testing results below screening
criteria; September 11, 2007
criteria; September 11, 2007
IR 670193, Essential switchgear cooling "A" shutdown service water piping ultrasonic testing
IR 670193, Essential switchgear cooling A shutdown service water piping ultrasonic testing
results below screening criteria; September 11, 2007
results below screening criteria; September 11, 2007
IR 670479, Isolated points on shutdown service water "A" piping less than minimum evaluation
IR 670479, Isolated points on shutdown service water A piping less than minimum evaluation
criteria; September 12, 2007
criteria; September 12, 2007
EC 367242, Temporary acceptance of pitting of the VC-B head pressure controller valve body,
EC 367242, Temporary acceptance of pitting of the VC-B head pressure controller valve body,
Line 990: Line 1,597:
IR 666899, 1SX019B: Cavitation damage found in valve body; August 31, 2007
IR 666899, 1SX019B: Cavitation damage found in valve body; August 31, 2007
IR 658234, NRC Questions on OPEVAL 655836-02; August 07, 2007
IR 658234, NRC Questions on OPEVAL 655836-02; August 07, 2007
1R19Post Maintenance TestingIR 671554, 0VC03CA fan replacement post job review - WW 0736; September 14, 2007EC 366835, Modification to replace supply fan 0VC03CA; Revision 0
1R19 Post Maintenance Testing
WO 969991, 0VC03CA -VC "A" Supply Fan Noise; September 9, 2007
IR 671554, 0VC03CA fan replacement post job review - WW 0736; September 14, 2007
EC 366835, Modification to replace supply fan 0VC03CA; Revision 0
WO 969991, 0VC03CA -VC A Supply Fan Noise; September 9, 2007
IR 675847, Cut O-ings; September 26, 2007
IR 675847, Cut O-ings; September 26, 2007
IR 675914, Division 3 emergency diesel generator turbocharger drain tubing missing;
IR 675914, Division 3 emergency diesel generator turbocharger drain tubing missing;
September 26, 2007
September 26, 2007
IR 676864, Out of specification parameters on Division 3 diesel generator during surveillance
IR 676864, Out of specification parameters on Division 3 diesel generator during surveillance
run; September 28, 2007  
run; September 28, 2007
Attachment
                                                8                                    Attachment
9IR 676905, K1 Lockout relay failed to trip emergency diesel generator; September 28, 2007WO 795653, Replace Normally deenergized relay 1E22S001B-8; September 28, 2007
 
IR 676905, K1 Lockout relay failed to trip emergency diesel generator; September 28, 2007
WO 795653, Replace Normally deenergized relay 1E22S001B-8; September 28, 2007
WO 1005265, Division 3 diesel generator six year maintenance: September 28, 2007
WO 1005265, Division 3 diesel generator six year maintenance: September 28, 2007
CPS 9080.03, Diesel generator 1C operability - Manual quick start operability; Revision 28e
CPS 9080.03, Diesel generator 1C operability - Manual quick start operability; Revision 28e
CPS 3316.01,  
CPS 3316.01,
CPS Operations Narrative Logs for August 14, 2007
CPS Operations Narrative Logs for August 14, 2007
WO 909977, Replace Rosemount Transmitter
WO 909977, Replace Rosemount Transmitter
WO 318466, EM Troubleshoot/Repair 1DC07E
WO 318466, EM Troubleshoot/Repair 1DC07E
1R22Surveillance Testing
1R22 Surveillance Testing
CPS 9054.01D002, "RCIC (1E51 - C001) High Pressure Operability Checks Checklist,"
CPS 9054.01D002, RCIC (1E51 - C001) High Pressure Operability Checks Checklist,
Revision 23a
Revision 23a
CPS 9054.01C002, "RCIC (1E51 - C001) High Pressure Operability Check," Revision 2b
CPS 9054.01C002, RCIC (1E51 - C001) High Pressure Operability Check, Revision 2b
CPS 9054.01, "RCIC System Operability Check," Revision 42e
CPS 9054.01, RCIC System Operability Check, Revision 42e
IR 657976, "Unexpected Alarm 5063 -1D RCIC Pump Suction Press"
IR 657976, Unexpected Alarm 5063 -1D RCIC Pump Suction Press
IR 658065, "1E51-F059 Limit switch Didn't Operate Properly During 9054.01"
IR 658065, 1E51-F059 Limit switch Didnt Operate Properly During 9054.01
IR 627527, "1E51N003: Computer Point E51DA001 Out of Spec Low (OOT)"
IR 627527, 1E51N003: Computer Point E51DA001 Out of Spec Low (OOT)
IR 658055, "RCIC Turbine Steam Disch Press Gauge Reads Zero #"
IR 658055, RCIC Turbine Steam Disch Press Gauge Reads Zero #
CPS 9052.01, LPCS/RHR A Pumps & LPCS/RHR A Water Leg Pump Operability, 09/13/06;
CPS 9052.01, LPCS/RHR A Pumps & LPCS/RHR A Water Leg Pump Operability, 09/13/06;
  Revision 43d,
  Revision 43d,
Line 1,030: Line 1,641:
CPS Technical Specification 3.7.1/3.7.2 and associated bases
CPS Technical Specification 3.7.1/3.7.2 and associated bases
CPS 9861.09D007, Leakage Test on Valve 1CC075B and 1CC076B, Revision 1a
CPS 9861.09D007, Leakage Test on Valve 1CC075B and 1CC076B, Revision 1a
2PS2Radioactive Material Processing and TransportationUSAR Chapter 11 Solid and Liquid Radwaste Management System, Revision 112006 Annual Radioactive Effluent Release Report; dated April 27, 2007
2PS2 Radioactive Material Processing and Transportation
AR 435702; Chemistry, Radwaste, Effluent and Environmental Monitoring Audit Report AuditNOSA-CPS-06-04; dated April 19, 2006
USAR Chapter 11 Solid and Liquid Radwaste Management System, Revision 11
2006 Annual Radioactive Effluent Release Report; dated April 27, 2007
AR 435702; Chemistry, Radwaste, Effluent and Environmental Monitoring Audit Report Audit
NOSA-CPS-06-04; dated April 19, 2006
AR 302506; Contamination Found in a Twenty Foot Sea Van; dated February 17, 2005
AR 302506; Contamination Found in a Twenty Foot Sea Van; dated February 17, 2005
AR 309873; Incorrect Dose Rate Listed in Waste Shipment Notification; dated March 8, 2005
AR 309873; Incorrect Dose Rate Listed in Waste Shipment Notification; dated March 8, 2005
Line 1,040: Line 1,654:
AR 451440; Incomplete Departure Survey Documentation; dated February 8, 2006
AR 451440; Incomplete Departure Survey Documentation; dated February 8, 2006
AR 476188; Radioactive Shipping Documentation Errors; dated April 7, 2006
AR 476188; Radioactive Shipping Documentation Errors; dated April 7, 2006
AR 539967; Inability to Transfer Waste Sludge to Vendor; dated October 4, 2006  
AR 539967; Inability to Transfer Waste Sludge to Vendor; dated October 4, 2006
Attachment
                                              9                                    Attachment
10AR 569198; Radiation Protection Audit Report; dated September 5, 2007AR 577885; 0WX02TA:Lessons Learned On 10 CFR 61 Analysis; dated January 11, 2007
 
AR 569198; Radiation Protection Audit Report; dated September 5, 2007
AR 577885; 0WX02TA:Lessons Learned On 10 CFR 61 Analysis; dated January 11, 2007
AR 578765; Invalid Data initially Generated; dated January 12, 2007
AR 578765; Invalid Data initially Generated; dated January 12, 2007
AR 585131; Deficiencies in Shipping Documents Found; dated January 30, 2007
AR 585131; Deficiencies in Shipping Documents Found; dated January 30, 2007
Line 1,050: Line 1,666:
AR 643431; Fluid Found on Incoming Radioactive Material Shipment; dated June 22, 2007
AR 643431; Fluid Found on Incoming Radioactive Material Shipment; dated June 22, 2007
AR 661628; Rotor Cribbing Found Deteriorating More Than Last Inspection; dated August 17,
AR 661628; Rotor Cribbing Found Deteriorating More Than Last Inspection; dated August 17,
2007
2007
AR 672300; Approximately 50 Milliliters Leak From Sealand Onto Trailer; dated
AR 672300; Approximately 50 Milliliters Leak From Sealand Onto Trailer; dated
September 17, 2007
September 17, 2007
Line 1,068: Line 1,684:
CPS 6418.04; Analysis of Radwaste Samples for Solid Waste Processing; Revision 9b
CPS 6418.04; Analysis of Radwaste Samples for Solid Waste Processing; Revision 9b
CY-AA-110-200; Sampling; Revision 5
CY-AA-110-200; Sampling; Revision 5
CPS 3222.10; Reactor Sample Station; Revision 102OS1Access Control to Radiologically Significant Areas
CPS 3222.10; Reactor Sample Station; Revision 10
AR289955; NOSA-CPS-05-06; Health Physics Functional Area Nuclear Oversight Audit; datedJuly 27, 2005
2OS1 Access Control to Radiologically Significant Areas
AR289955; NOSA-CPS-05-06; Health Physics Functional Area Nuclear Oversight Audit; dated
July 27, 2005
AR 537844; Purple Painted tool Found Outside the Radiologically Restricted Area; dated
AR 537844; Purple Painted tool Found Outside the Radiologically Restricted Area; dated
August 29, 2006
August 29, 2006
Line 1,084: Line 1,702:
RP-AA-460-1002; High Radiation Area and Locked High Radiation Areas Briefing Form
RP-AA-460-1002; High Radiation Area and Locked High Radiation Areas Briefing Form
RWP 10002868; Spent Fuel Pool Re-Rack Diving; Revision 0
RWP 10002868; Spent Fuel Pool Re-Rack Diving; Revision 0
RWP 10007956; Spent Fuel Pool Re-Rack; Revision 3  
RWP 10007956; Spent Fuel Pool Re-Rack; Revision 3
Attachment
                                              10                                  Attachment
11OA2Identification and Resolution of ProblemsOP-AA-102-103; Operator Work-Around Program; Revision 1CPS 9000.10; Accident Monitoring And Remote Shutdown Instrumentation Log; Revision 31a  
 
OA2 Identification and Resolution of Problems
OP-AA-102-103; Operator Work-Around Program; Revision 1
CPS 9000.10; Accident Monitoring And Remote Shutdown Instrumentation Log; Revision 31a
IR 610835; Eval. Division 1 & 2 H2O2 Monitor INOP Printers: OPS Workaround; March 30,
IR 610835; Eval. Division 1 & 2 H2O2 Monitor INOP Printers: OPS Workaround; March 30,
2007
2007
IR 624538; NOS ID Operations Workaround Leads To Fire Door Impairment; May 2, 2007
IR 624538; NOS ID Operations Workaround Leads To Fire Door Impairment; May 2, 2007
IR 575009; Permanent Access Solution Needed For 1FW004 Valve; January 3, 2007
IR 575009; Permanent Access Solution Needed For 1FW004 Valve; January 3, 2007
IR 617958; Off-Normal Response Enhancement; April 16, 2007
IR 617958; Off-Normal Response Enhancement; April 16, 2007
IR 572918; Eval. Main Turbine BRG #9 Vibe Problem As Operator Challenge; December 25,
IR 572918; Eval. Main Turbine BRG #9 Vibe Problem As Operator Challenge; December 25,
2006
2006
IR 567237; 1KYCP105H Repeat Timer Did Not Advance - OP Challenge; December 9, 2006
IR 567237; 1KYCP105H Repeat Timer Did Not Advance - OP Challenge; December 9, 2006
IR 642744; TDRFP 'B' Turning Gear Failed To Disengage Automatically; June 21, 2007
IR 642744; TDRFP B Turning Gear Failed To Disengage Automatically; June 21, 2007
IR 652502; 1HG02CA Greater Than 3 Hours Run Time In July 2007; July 22, 2007
IR 652502; 1HG02CA Greater Than 3 Hours Run Time In July 2007; July 22, 2007
IR 656515; Missed Opportunity For Operator Work Around/Challenge Review; August 2, 2007
IR 656515; Missed Opportunity For Operator Work Around/Challenge Review; August 2, 2007
WO 843352; Task 01; Contingent Task To Disassemble, Inspect And Repair Valve 1E12F009
WO 843352; Task 01; Contingent Task To Disassemble, Inspect And Repair Valve 1E12F009
Due Seat LeakageOA3Event FollowupLER 05-461/2007-003-00, IGSCC Causes Pressure Boundary Leak and Reactor Shutdown;August 16, 2007
Due Seat Leakage
OA3 Event Followup
LER 05-461/2007-003-00, IGSCC Causes Pressure Boundary Leak and Reactor Shutdown;
August 16, 2007
IR 641375, 4001.01 Reactor Coolant Leakage; June 18, 2007
IR 641375, 4001.01 Reactor Coolant Leakage; June 18, 2007
RCR 641375, Flexible hose failure on Main Steam Line "C" results in manual reactor shutdown
RCR 641375, Flexible hose failure on Main Steam Line C results in manual reactor shutdown
for replacement  
for replacement
Attachment
                                            11                                  Attachment
12LIST OF ACRONYMS USEDADAMSAgency wide Documents Access and Management SystemALARAAs-Low-As-Reasonably-Achievable
 
CPSClinton Power Station
                              LIST OF ACRONYMS USED
CRCondition Report
ADAMS    Agency wide Documents Access and Management System
DAWDry Active Waste
ALARA    As-Low-As-Reasonably-Achievable
DOTDepartment of Transportation
CPS      Clinton Power Station
EPEmergence Preparedness
CR      Condition Report
ERATEmergency Reserve Auxilary Transformer
DAW      Dry Active Waste
FPERFire Protection Evaluation Report
DOT      Department of Transportation
HPCSHigh Pressure Core Spray
EP      Emergence Preparedness
HRAHigh Radiation Area
ERAT    Emergency Reserve Auxilary Transformer
HVACHeating Ventilation and Cooling
FPER    Fire Protection Evaluation Report
IMCInspection Manual Chapter
HPCS    High Pressure Core Spray
IRIssue Report
HRA      High Radiation Area
LCOLimited Condition for Operation
HVAC    Heating Ventilation and Cooling
LPCSLow Pressure Core Spray
IMC      Inspection Manual Chapter
LSALow Specific Activity
IR      Issue Report
MRMaintenance Rule
LCO      Limited Condition for Operation
MSPIMitigating System Performance Indicator
LPCS    Low Pressure Core Spray
NCVNon-Cited Violation
LSA      Low Specific Activity
NEINuclear Energy Institute
MR      Maintenance Rule
NRCNuclear Regulatory Commission
MSPI    Mitigating System Performance Indicator
OPCOperational Support Center
NCV      Non-Cited Violation
OSCOperational Support Center
NEI      Nuclear Energy Institute
PARSPublicly Available Records
NRC      Nuclear Regulatory Commission
PIPerformance Indicator
OPC      Operational Support Center
PMTPost Maintenance Testing
OSC      Operational Support Center
RadwasteRadioactive Waste
PARS    Publicly Available Records
RCSReactor Coolant System
PI      Performance Indicator
RHRResidual Heat Removal
PMT      Post Maintenance Testing
RPRadiation Protection
Radwaste Radioactive Waste
RPTRadiation Protection Technician
RCS      Reactor Coolant System
RWPRadiation Work Permit
RHR      Residual Heat Removal
SDPSignificant Determination Process
RP      Radiation Protection
SVCStatic VAR Compensator
RPT      Radiation Protection Technician
TSTechnical Specification
RWP      Radiation Work Permit
URIUnresolved Item
SDP      Significant Determination Process
USARUpdated Safety Analysis Report
SVC      Static VAR Compensator
WABWork Around Board
TS      Technical Specification
WOWork Order
URI      Unresolved Item
USAR    Updated Safety Analysis Report
WAB      Work Around Board
WO      Work Order
                                          12              Attachment
}}
}}

Revision as of 02:09, 23 November 2019

IR 05000461-07-004; on 07/01/2007 - 09/30/2007; Amergen Energy Company, LLC; Clinton Power Station, Integrated Inspection Report and Event Follow-up
ML073100335
Person / Time
Site: Clinton 
(NPF-062)
Issue date: 11/06/2007
From: Ring M
NRC/RGN-III/DRP/B1
To: Crane C
Exelon Generation Co, Exelon Nuclear
References
IR-07-004
Download: ML073100335 (45)


See also: IR 05000461/2007004

Text

November 6, 2007

Mr. Christopher M. Crane

President and Chief Nuclear Officer

Exelon Nuclear

Exelon Generation Company, LLC

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: CLINTON POWER STATION

NRC INTEGRATED INSPECTION REPORT 05000461/2007004

Dear Mr. Crane:

On September 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an

integrated inspection at your Clinton Power Station. The enclosed report documents the

inspection results, which were discussed on October 4, 2007, with Mr. F.A. Kearney and other

members of your staff.

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

compliance with the Commissions rules and regulations and with the conditions of your license.

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

personnel.

Based on the results of this inspection, three self-revealed findings of very low safety

significance (Green) were identified. All of these issues involved violations of NRC

requirements. However, because of the very low safety significance and because they were

entered into your corrective action program, the NRC is treating these violations as Non-Cited

Violations consistent with Section VI.A.1. of the NRC Enforcement Policy.

If you contest the subject or severity of a Non-Cited Violation, you should provide a response

within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555-0001; with copies to the Regional Administrator, Region III, 2443 Warrenville Road,

Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory

Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Clinton

Power Station.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosure, and your response (if any) will be available electronically for public inspection in the

C. Crane -2-

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRCs document system (ADAMS), accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mark A. Ring, Chief

Branch 1

Division of Reactor Projects

Docket No. 50-461

License No. NPF-62

Enclosure: Inspection Report No. 05000461/2007004

w/Attachment: Supplemental Information

cc w/encl: Site Vice President - Clinton Power Station

Plant Manager - Clinton Power Station

Regulatory Assurance Manager - Clinton Power Station

Chief Operating Officer

Senior Vice President - Nuclear Services

Vice President - Operations Support

Vice President - Licensing and Regulatory Affairs

Manager Licensing - Clinton Power Station

Senior Counsel, Nuclear, Mid-West Regional Operating Group

Document Control Desk - Licensing

Assistant Attorney General

Illinois Emergency Management Agency

State Liaison Officer, State of Illinois

Chairman, Illinois Commerce Commission

C. Crane -2-

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRCs document system (ADAMS), accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mark A. Ring, Chief

Branch 1

Division of Reactor Projects

Docket No. 50-461

License No. NPF-62

Enclosure: Inspection Report No. 05000461/2007004

w/Attachment: Supplemental Information

cc w/encl: Site Vice President - Clinton Power Station

Plant Manager - Clinton Power Station

Regulatory Assurance Manager - Clinton Power Station

Chief Operating Officer

Senior Vice President - Nuclear Services

Vice President - Operations Support

Vice President - Licensing and Regulatory Affairs

Manager Licensing - Clinton Power Station

Senior Counsel, Nuclear, Mid-West Regional Operating Group

Document Control Desk - Licensing

Assistant Attorney General

Illinois Emergency Management Agency

State Liaison Officer, State of Illinois

Chairman, Illinois Commerce Commission

DOCUMENT NAME:C:\FileNet\ML073100335.wpd

G Publicly Available G Non-Publicly Available G Sensitive G Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII RIII RIII RIII

NAME M. Ring for M. Ring

B. Dickson

DATE 11/05/2007 11/06/2007

OFFICIAL RECORD COPY

Letter to C. Crane from M. Ring dated November 6, 2007

SUBJECT: CLINTON POWER STATION

NRC INTEGRATED INSPECTION REPORT 05000461/2007004

DISTRIBUTION:

TEB

RAG1

SPS1

MMT

RidsNrrDirsIrib

MAS

KGO

JKH3

RML2

SAM9

SRI Clinton

CAA1

LSL (electronic IRs only)

C. Pederson, DRP (hard copy - IRs only)

DRSIII

DRPIII

PLB1

TXN

ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-461

License No: NPF-62

Report No: 05000461/2007004

Licensee: AmerGen Energy Company, LLC

Facility: Clinton Power Station

Location: Route 54 West

Clinton, IL 61727

Dates: July 1 through September 30, 2007

Inspectors: B. C. Dickson, Senior Resident Inspector

D. Tharp, Resident Inspector

A. Barker, Senior Project Engineer

J. McGhee, Reactor Engineer

A. Koonce, Reactor Engineer

D. Melendez, Reactor Engineer

M. Mitchell, Health Physicist

Approved by: Mark Ring, Chief

Branch 1

Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000461/2007004, AmerGen Energy Company LLC, on 07/01/07 - 09/30/2007 Clinton

Power Station, Event Follow-up.

This report covers a three month period of baseline resident inspection and announced

baseline inspection on radiation protection. The inspection was conducted by Region III

inspectors and the resident inspectors. Three Green findings, involving Non-Cited Violations,

were identified. The significance of most findings is indicated by their color (Green, White,

Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination

Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a

severity level after NRC management review. The NRCs program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 3, dated July 2000.

A. Inspector-Identified and Self Revealing Findings

Cornerstone: Barrier Integrity

receipt of laboratory results that showed that Division 1 control room ventilation system

charcoal filter penetration values were higher than allowed by Clintons Technical

Specifications. This issue occurred because the licensee failed to establish proper

purchase specifications for charcoal used in the control room ventilation system.

Additionally, this issue led to Division 1 control room ventilation subsystem being

inoperable from May 9 through May 16, 2005, concurrent with the Division 2 control

room ventilation subsystem being inoperable due to planned maintenance from

May 9 through May 14, 2005. Licensee corrective actions included entering the issue

into the corrective action program, revising the charcoal purchase specifications, and

adding limitations to work orders to prevent scheduling work that could impact the

operability of redundant systems.

This issue was more than minor because it affected the objective of the Barrier Integrity

cornerstone of assuring that physical design barriers protect the public from radionuclide

releases caused by accidents or events. Additionally, this issue is associated with the

barrier performance attribute of maintaining Radiological Barrier functionality of the

control room. Failure to ensure adequate purchase specifications resulted in there

being a period where both trains of control room ventilation were inoperable without the

knowledge of the operators. The issue was of very low safety significance because it

only represented a degradation of the radiological barrier function provided for the

control room. (Section 4OA3.1)

  • Green. The inspectors identified a performance deficiency involving a Non-Cited

Violation of Technical Specifications when the licensee failed to meet the required

completion time for an action statement in Technical Specification 3.4.5. Specifically,

Technical Specification 3.4.5 does not allow reactor coolant system pressure boundary

leakage and requires a shutdown to Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if pressure boundary

1 Enclosure

leakage is discovered. Upon entry into the drywell following a shutdown of the reactor

on June 19, 2007, the licensee discovered the existence of reactor coolant system

pressure boundary leakage. Indications of the leakage had been discovered at 0433 on

June 18, 2007, but the plant was not placed in Mode 3 until approximately 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> later

at 1125 on June 19, 2007. Licensee corrective actions included replacing the leaking

flexible hose, scheduling replacement of other flexible hoses, and establishing a

preventive maintenance replacement frequency for the flexible hoses.

This issue was more than minor because operating with a degraded pressure boundary

affected the reactor coolant system equipment and barrier performance attribute of the

Barrier Integrity cornerstone, in that, reactor coolant system pressure boundary leakage

results in a reduction in the reasonable assurance that physical design barriers protect

the public from radionuclide releases caused by accidents or events. The issue was of

very low safety significance because the potential maximum size of the leak was well

within the capability of the available mitigating equipment. The finding is related to the

cross-cutting area of Human Performance (Decision Making) in that operators had

initially entered TS 3.4.5 for pressure boundary leakage, but later chose not to treat the

leakage as pressure boundary leakage, and treat it as unidentified leakage until the

actual location could be determined (H.1(b)). (Section 4OA3.2)

  • Green. A performance deficiency involving a Non-Cited Violation of 10 CFR Part 50 Appendix B, Criteria V, Instructions, Procedures, and Drawings, was self-revealed

following an event on August 17, 2007, where a spent fuel bundle being moved to a

temporary storage location came in contact with and rested upon another fuel bundle

seated in its storage location. The licensee procedure that governs spent fuel pool

movement failed to provide adequate guidance on how high to lift the fuel bundle prior to

traversing across the spent fuel pool. Licensee corrective actions included revising the

fuel handling procedure to provide specific instructions regarding how high to lift a fuel

bundle during spent fuel pool movements.

This issue was more than minor because it affected the barrier integrity objective of

assuring that physical design barriers protect the public from radionuclide releases

caused by accidents or events. The inspectors determined that this issue only degraded

the Fuel Cladding Barrier and its associated cornerstone, therefore, this issue was of

very low safety significance. This finding is related to the cross-cutting area of Human

Performance (Resources) because the licensee did not provide complete and accurate

procedures. Specifically, the procedure relied on the skills of the operator, did not

provided specific values on how high to lift a fuel bundle, and did not require

independent verification (H.2(c)). (Section 4OA3.3)

B. Licensee-Identified Violations

No findings of significance were identified.

2 Enclosure

REPORT DETAILS

Summary of Plant Status

The plant was operated at approximately 96 to 97 percent rated thermal power (maintaining

100 percent electrical output) throughout the inspection period with several derates of

approximately 2-3 percent at the requests of the grid operator. The grid operator made those

requests due to concerns regarding grid stability.

Exceptions to relatively steady state operation occurred on July 1, 2007, when operators

lowered reactor power to approximately 82 percent to make repairs to an electrohydraulic

control system leak on the #4 main turbine control valve and on September 9, 2007, when

operators lowered reactor power of approximately 75 percent to perform control rod pattern

adjustments, quarterly main turbine valve testing and main steam isolation valve testing.

1. REACTOR SAFETY

Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

a. Inspection Scope

The inspectors evaluated site readiness for severe thunderstorms prior to arrival of

weather fronts associated with severe thunderstorms, high winds and rain that resulted

in severe thunderstorm and tornado watches being identified. On each occasion

operations shift manning was verified to be adequate and in accordance with site

procedures. Site walkdowns were performed to evaluate potential vulnerabilities for

missile generation during high winds or tornados and to assess the implementation of

the site procedures. The communications protocol between the control room and the

transmission system operator was also reviewed during the inspections and examples of

the quality of communication were observed due to severe weather conditions during

the inspection.

This review represented two inspection samples of review prior to impending weather

conditions.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments (71111.04Q)

a. Inspection Scope

The inspectors performed partial walkdowns of accessible portions of divisions of

risk-significant mitigating systems equipment during times when the divisions were of

increased importance due to redundant divisions or other related equipment being

3 Enclosure

unavailable. The inspectors utilized the valve and electric breaker checklists listed at

the end of this report to verify that the components were properly positioned and that

support systems were lined up as needed. The inspectors also examined the material

condition of the components and observed operating parameters of equipment to verify

that there were no obvious deficiencies. The inspectors reviewed outstanding work

orders and issue reports (IRs) associated with the divisions to verify that those

documents did not reveal issues that could affect division function. The inspectors used

the information in the appropriate sections of the Updated Safety Analysis Report

(USAR) to determine the functional requirements of the systems. The documents listed

at the end of this report were also used by the inspectors to evaluate this area.

The inspectors performed two samples by verifying the alignment of the reactor core

isolation cooling system and the Division 1 standby gas treatment system while

Division 2 was out of service.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05Q)

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability,

accessibility, and the condition of fire fighting equipment, the control of transient

combustibles and ignition sources, and on the condition and operating status of installed

fire barriers. The inspectors selected fire areas for inspection based on their overall

contribution to internal fire risk, as documented in the individual plant examination of

external events with later additional insights, and their potential to impact equipment

which could cause a plant transient, to verify that fire hoses and extinguishers were in

their designated locations and available for immediate use, that fire detectors and

sprinklers were not obstructed, that transient material loading was within the analyzed

limits, and that fire doors, dampers, and penetration seals appeared to be in satisfactory

condition. The inspectors verified that minor issues identified during the inspection were

entered into the licensees corrective action program.

The inspectors reviewed portions of the licensees fire protection evaluation report and

the USAR to verify consistency in the documented analysis with installed fire protection

equipment at the station.

The inspectors completed seven samples by inspection of the following areas:

  • Fire Area D-5d, Division 1 diesel generator room;

room;

  • Fire Area A-1, 707' auxiliary building, general access area;
  • Fire Area CB-1c, 719' control building, heating ventilation and air conditioning

equipment area;

  • Fire loading and associated fire hazard permits in approved storage area;

4 Enclosure

  • Fire Area D-6a, b, Division 2 diesel generator and day tank room.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

The inspectors observed the flood protection equipment in the B and C residual heat

removal pump rooms. The inspectors verified that flooding mitigation plans and

equipment were consistent with the design requirements and risk analysis assumptions.

The inspectors reviewed USAR Section 3.4.1 for internal flooding protection measures,

reviewed the licensees flooding mitigation procedures, and reviewed issue reports

related to possible flood protection issues. Additionally, plant walkdowns were

performed to verify design barriers were properly maintained. Penetrations between

rooms, watertight doors, electrical conduit seals and covers, and room drains were

inspected to verify material condition met design assumptions. The inspectors

performed a review of the stations maintenance database to verify preventative

maintenance was current and equipment deficiencies were being appropriately reported

and resolved. Additionally, the inspectors reviewed the maintenance rule scoping and

performance criteria and determined that the function was being tracked appropriately.

The corrective action program was also reviewed for the past 12 months for issues

related to internal flood protection. The inspectors completed a one inspection sample

by completing the internal flooding review of the B residual heat removal pump and

heat exchanger room and the C residual heat removal pump room.

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance (71111.07A)

a. Inspection Scope

The inspectors verified readiness and availability of the Division 3 emergency diesel

generator heat exchanger by performing the following activities:

testing results;

  • Observed the condition of heat exchanger end bell and tube sheet during

walkdown;

  • Reviewed the results of tube inspections and outage work packages to

determine whether maintenance was performed in accordance with the

licensees maintenance program for heat exchangers and reviewed issue

reports to verify that deficiencies were identified and incorporated into the

licensees corrective action program;

5 Enclosure

  • Reviewed the evaluation and corrective actions for Action Request 678934,

Div III DG HX (1DG13A) Chemistry Results,

  • Reviewed the evaluation and corrective actions for Action Request 675035,

Excessive Erosion Discovered on the Flange Faces 1VH03A, and

  • Verified the heat exchanger was properly classified under the Maintenance

Rule and identified issues received appropriate program reviews.

This inspection represented the completion of one annual sample.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification (71111.11)

a. Inspection Scope

The inspectors observed an evaluation of an operating crew on September 19, 2007.

The scenario (ESG LOR Exam 87d) consisted of a failure of the A reactor recirculation

flow control valve, a failure to scram using the manual pushbuttons, unisolable flooding

in emergency core cooling system pump room and an emergency depressurization.

The inspectors reviewed licensed-operator requalification training to evaluate operator

performance in mitigating the consequences of a simulated event, particularly in the

areas of Human Performance. The inspectors evaluated operator performance

attributes which included communication clarity and formality, timely performance of

appropriate operator actions, appropriate alarm response, proper procedure use and

adherence, and senior reactor operator oversight and command and control.

Additionally, simulator physical fidelity and training department actions to incorporate

current plant deficiencies and annunciators were evaluated.

The inspectors also assessed the performance of the training staff evaluations involved

in the requalification process. For any weaknesses identified during the session, the

inspectors observed that the licensee evaluators also noted the issues and discussed

them in the critique at the end of the session. Discrepancies were reviewed with the

training staff. The inspectors verified that all issues were captured in the training

program and licensee corrective action program.

These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

6 Enclosure

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors reviewed the effectiveness of the licensees maintenance efforts in

implementing 10 CFR Part 50.65 (the maintenance rule (MR)) requirements, including a

review of scoping, goal-setting, performance monitoring, short and long-term corrective

actions, and current equipment performance problems. These systems were selected

based on their designation as risk-significant under the maintenance rule. The

inspectors also reviewed issue reports and associated documents for appropriate

identification of problems, entry into the corrective action system, and appropriateness

of planned or completed actions. The inspectors completed three samples by reviewing

the following:

  • Division 1 DC Battery and DC distribution;
  • Containment and reactor vessel isolation system and

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors observed the licensees risk assessment processes and considerations

used to plan and schedule maintenance activities on safety-related structures, systems,

and components particularly to ensure that maintenance risk and emergent work

contingencies had been identified and resolved. The inspectors completed five

samples by assessing the effectiveness of risk management activities for the following

work activities or work weeks:

  • Reviewed licensee risk assessment and subsequent area operator staging

associated with standby liquid control system pump and valve quarterly

operability run;

  • Reviewed licensees risk assessment and detailed work plan for reserve auxiliary

transformer static VAR compensator prior to the removal of test equipment;

  • Reviewed licensee risk assessment for planned surveillance on high pressure

core spray system;

  • Reviewed licensee risk assessment associated with six-year preventative

maintenance of the Division 3 diesel generator (including walkdown of risk

sensitive area to ensure proper flagging);

  • Reviewed the licensees risk assessment of 138 kv line work by Ameren IP and

subsequent emergency reserve auxiliary transformer outage.

b. Findings

No findings of significance were identified.

7 Enclosure

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed the following operability determinations and evaluations

affecting mitigating systems to determine whether operability was properly justified and

the component or system remained available such that no unrecognized risk increase

had occurred. The inspectors completed four samples of operability determinations and

evaluations by reviewing the following:

check valves (1E12F084A and 1E12F085A) failure to close;

  • Operability Evaluation 630815-03: Division 1, 2, and 3 shutdown service water

valves (1SX025A, 1SX025B, and 1SX025C) exceed the vendor allowable

deflection;

  • Action Request 667663: Through body leak of shutdown service water valve

(1SX019B);

  • Action Request 660299: Type C Integrated leakage rate testing for test lines

going through containment penetration 1MC-152 not being performed;

(1SX20AB); and

  • Operability Evaluation 671001: Division 3 essential switchgear/shutdown service

water piping wall thickness below minimum screening criteria.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the post maintenance testing activities associated with

maintenance or modification of important mitigating, barrier integrity, and support

systems that were identified as risk significant in the licensees risk analysis. The

inspectors reviewed these activities to verify that the post maintenance testing was

performed adequately, demonstrated that the maintenance was successful, and that

operability was restored. During this inspection activity, the inspectors interviewed

maintenance and engineering department personnel and reviewed the completed post

maintenance testing documentation. The inspectors used the appropriate sections of

the Technical Specifications (TS) and USAR, as well as the documents listed at the end

of this report, to evaluate this area.

Testing subsequent to the following activities was observed and evaluated:

  • Work Order 00318466: Troubleshooting and repair of Division 2, 250 Volt

battery charger (1DC07E);

  • Work Order 01048964-03: Post maintenance testing for optical isolator pair

(manual scram push button) P664-A-A81-A313/A305;

8 Enclosure

  • Work Order 00914954-03: Replacement of 1SX-303A;

pressure switches;

  • Work Order 00909977-02: Replacement of combustible gas control system

pressure switch;

  • Work Order 00969911: Replacement of Division 1 main control room ventilation

supply fan; and

following six year maintenance.

Performance of this review comprised seven samples.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors witnessed selected surveillance testing and/or reviewed test data to

verify that the equipment tested using the surveillance procedures met the TS, the

Technical requirements Manual (TRM), the USAR, and licensee procedural

requirements, and demonstrated that the equipment was capable of performing its

intended safety functions. The activities were selected based on their importance in

verifying mitigating systems capability and barrier integrity. The inspectors used the

documents listed at the end of this report to verify that the testing met the frequency

requirements; that the tests were conducted in accordance with the procedures,

including establishing the proper plant conditions and prerequisites; that the test

acceptance criteria were met; and that the results of the tests were properly reviewed

and recorded. In addition, the inspectors interviewed operations, maintenance, and

engineering department personnel regarding the tests and test results.

Seven samples were completed.

The inspectors evaluated the following surveillance tests:

  • CPS 9000.01, Control room surveillance log and CPS 3315.02 Leak detection;

water leg pump operability;

fill;

  • CPS 9080.02, Diesel generator 1B operability - manual and quick start

operability.

9 Enclosure

These tests included three in-service testing (IST) surveillance samples and one reactor

coolant system leakage detection surveillance sample.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications (7111.23)

The inspectors reviewed and evaluated the following temporary plant modification on

risk significant equipment to verify that the instructions were consistent with applicable

design modification documents and that the modifications did not adversely impact

system operability or availability. The inspectors interviewed operations, engineering

and maintenance personnel, as appropriate, and reviewed the design modification

documents and the 10 CFR 50.59 evaluations against the applicable portions of the

USAR. The documents listed at the end of the report were also used by the inspectors

to evaluate this area. The inspectors reviewed the issues that the licensee entered into

its corrective action program to verify that identified temporary modification problems

were being entered into the program with the appropriate characterization and

significance. The inspectors also reviewed the licensees corrective actions for

temporary modification related issues documented in selected condition reports. The

condition reports are specified in the List of Documents Reviewed.

The inspectors completed one inspection sample by reviewing the following temporary

modification:

  • Defeating Inclined fuel transfer system upender/fuel handling platform Interlock,

Revision 0.

b. Findings

No findings of significance were identified.

2. EMERGENCY PREPAREDNESS

1EP6 Drill Evaluation (71114.06)

a. Inspection Scope

The inspectors observed the emergency response activities associated with the drill

conducted on August 9, 2007. Specifically, the inspectors verified that the emergency

classification and simulated notifications were properly completed, and that the licensee

adequately critiqued the training. Additionally, the inspectors observed licensee

activities during the drill in the simulated control room and the Technical Support Center

(TSC).

The drill included an explosion in the Division 2 emergency diesel generator and a

subsequent anticipated transient without a scram.

10 Enclosure

b. Findings

No findings of significance were identified.

2. RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

.1 Review of Licensee Performance Indicators for the Occupational Exposure Cornerstone

a. Inspection Scope

The inspectors reviewed the licensees Occupational Exposure Control cornerstone

performance indicators (PIs) to determine whether or not the conditions surrounding the

PIs had been evaluated, and identified problems had been entered into the corrective

action program for resolution. These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.2 Plant Walkdowns and Radiation Work Permit Reviews

a. Inspection Scope

The inspectors reviewed licensee controls and surveys in the following two radiologically

significant work areas within radiation areas, high radiation areas and airborne

radioactivity areas in the plant and reviewed work packages which included associated

licensee controls and surveys of these areas to determine if radiological controls

including surveys, postings and barricades were acceptable:

  • Spent fuel pool re-rack project; and
  • Phase separator resin transfer.

These reviews represented one inspection sample.

The inspectors reviewed the radiation work permits (RWP) and work packages used to

access these two areas and other high radiation work areas to identify the work control

instructions and control barriers that had been specified. Electronic dosimeter alarm set

points for both integrated dose and dose rate were evaluated for conformity with survey

indications and plant policy. Workers were interviewed to verify that they were aware of

the actions required when their electronic dosimeters noticeably malfunctioned or

alarmed. These reviews represented one inspection sample.

The inspectors walked down and surveyed (using an NRC survey meter) these two

areas to verify that the prescribed radiation work permit, procedure, and engineering

11 Enclosure

controls were in place, that licensee surveys and postings were complete and accurate,

and that air samplers were properly located. These reviews represented one inspection

sample.

The inspectors reviewed RWPs for airborne radioactivity areas to verify barrier integrity

and engineering controls performance (e.g., HEPA ventilation system operation) and to

determine if there was a potential for individual worker internal exposures of greater

than 50 millirem committed effective dose equivalent. No areas in the plant were

airborne areas with a potential of greater than 5 millirem committed effective dose

equivalent. Work areas having a history of, or the potential for, airborne transuranics

were evaluated to verify that the licensee had considered the potential for transuranic

isotopes and provided appropriate worker protection. The license has not had a history

of transuranic contamination. These reviews represented one inspection sample.

The adequacy of the licensees internal dose assessment process for internal exposures

greater than 50 millirem committed effective dose equivalent was assessed. These

reviews represented one inspection sample.

The inspectors also reviewed the licensees physical and programmatic controls for

highly activated and/or contaminated materials (non-fuel) stored within spent fuel or

other storage pools. These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.3 Problem Identification and Resolution

a. Inspection Scope

The inspectors reviewed the licensees self-assessments, audits, Licensee Event

Reports, and Special Reports related to the access control program to verify that

identified problems were entered into the corrective action program for resolution.

These reviews represented one inspection sample.

The inspectors reviewed seven corrective action reports related to access controls and

high radiation area radiological incidents when available (non-PIs identified by the

licensee in high radiation areas greater than 1R/hr). Staff members were interviewed

and corrective action documents were reviewed to verify that follow-up activities were

being conducted in an effective and timely manner commensurate with their importance

to safety and risk based on the following:

  • Initial problem identification, characterization, and tracking;
  • Disposition of operability/reportability issues;
  • Evaluation of safety significance/risk and priority for resolution;
  • Identification of repetitive problems;
  • Identification of contributing causes;
  • Identification and implementation of effective corrective actions;

12 Enclosure

  • Resolution of Non-Cited Violations (NCVs) tracked in the corrective action

system; and

  • Implementation/consideration of risk significant operational experience feedback.

These reviews represented one inspection sample.

The inspectors evaluated the licensees process for problem identification,

characterization, and prioritization and verified that problems were entered into the

corrective action program and resolved. For repetitive deficiencies and/or significant

individual deficiencies in problem identification and resolution, the inspectors verified

that the licensees self-assessment activities were capable of identifying and addressing

these deficiencies. These reviews represented one inspection sample.

The inspectors reviewed licensee documentation packages for all PI events occurring

since the last inspection to determine if any of these PI events involved dose rates

greater than 25 R/hr at 30 centimeters or greater than 500 R/hr at 1 meter. Barriers

were evaluated for failure and to determine if there were any barriers left to prevent

personnel access. Unintended exposures greater than 100 millirem total effective dose

equivalent (or greater than 5 rem shallow dose equivalent or greater than 1.5 rem lens

dose equivalent), were evaluated to determine if there were any regulatory

overexposures or if there was a substantial potential for an overexposure. There were

no unintended exposures approaching 100 millirem. These reviews represented one

inspection sample.

b. Findings

No findings of significance were identified.

.4 Job-In-Progress Reviews

a. Inspection Scope

The inspectors observed the following two work activities that were being performed in

radiation areas, airborne radioactivity areas, or high radiation areas that presented the

greatest radiological risk to workers:

  • Spent fuel pool re-rack project; and
  • Phase separator resin transfer.

The inspectors reviewed radiological job requirements for these two activities including

RWP requirements and work procedure requirements, and attended

As-Low-As-Reasonably-Achievable (ALARA) job briefings. These reviews represented

one inspection sample.

Job performance was observed with respect to these requirements to verify that

radiological conditions in the work area were adequately communicated to workers

through pre-job briefings and postings. The inspectors also verified the adequacy of

radiological controls including required radiation and contamination surveys; radiation

13 Enclosure

protection job coverage; and contamination controls. These reviews represented one

inspection sample.

Radiological work in high radiation work areas having significant dose rate gradients

was reviewed to evaluate the application of dosimetry to effectively monitor exposure to

personnel and to verify that licensee controls were adequate. These work areas

involved areas where the dose rate gradients were severe (diving activities in the fuel

pool re-rack project) which increased the necessity of providing multiple dosimeters.

These reviews represented one-inspection sample.

b. Findings

No findings of significance were identified.

.5 High Risk Significant, High Dose Rate (HRA), and Very High Radiation Area Controls

a. Inspection Scope

The inspectors held discussions with the acting Radiation Protection Manager

concerning high dose rate/high radiation area and very high radiation area controls and

procedures, including procedural changes that had occurred since the last inspection, in

order to verify that any procedure modifications did not substantially reduce the

effectiveness and level of worker protection. These reviews represented one inspection

sample.

The inspectors discussed with RP supervisors the controls that were in place for special

areas that had the potential to become very high radiation areas during certain plant

operations, to determine if these plant operations required communication beforehand

with the RP group, so as to allow corresponding timely actions to properly post and

control the radiation hazards. These reviews represented one inspection sample.

The inspectors conducted plant walkdowns to verify the posting and locking of

entrances to high dose rate HRAs, and very high radiation. These reviews represented

one inspection sample.

b. Findings

No findings of significance were identified.

.6 Radiation Worker Performance

a. Inspection Scope

During job performance observations, the inspectors evaluated radiation worker

performance with respect to stated radiation protection work requirements and

evaluated whether workers were aware of the significant radiological conditions in their

workplace, the RWP controls and limits in place, and that their performance had

accounted for the level of radiological hazards present. These reviews represented one

inspection sample.

14 Enclosure

The inspectors reviewed radiological problem reports which found that the cause of the

event was due to radiation worker errors to determine if there was an observable pattern

traceable to a similar cause, and to determine if this perspective matched the corrective

action approach taken by the licensee to resolve the reported problems. These

problems, along with planned and taken corrective actions were discussed with the

acting Radiation Protection Manager. These reviews represented one inspection

sample.

b. Findings

No findings of significance were identified.

.7 Radiation Protection Technician Proficiency

a. Inspection Scope

During job performance observations, the inspectors evaluated Radiation Protection

Technician (RPT) performance with respect to radiation protection work requirements

and evaluated whether they were aware of the radiological conditions in their workplace,

the RWP controls and limits in place, and if their performance was consistent with their

training and qualifications with respect to the radiological hazards and work activities.

These reviews represented one inspection sample.

The inspectors reviewed radiological problem reports which found that the cause of the

event was radiation protection technician error to determine if there was an observable

pattern traceable to a similar cause, and to determine if this perspective matched the

corrective action approach taken by the licensee to resolve the reported problems.

These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS2 Radioactive Material Processing and Transportation (71122.02)

.1 Radioactive Waste System

a. Inspection Scope

The inspectors reviewed the liquid and solid radioactive waste system descriptions in

the Updated Final Safety Analysis Report (UFSAR), and the 2006 Annual Radioactive

Effluent Release Report for information on the types and amounts of radioactive waste

(radwaste) generated and disposed. The inspectors reviewed the scope of the

licensees audit/self-assessment activities, with regard to radioactive material processing

and transportation programs to determine if those activities satisfied the requirements of

15 Enclosure

10 CFR 20.1101(c) and the quality assurance audit requirements of Appendix G to

10 CFR Part 20 and of 10 CFR 71.137, as applicable.

These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.2 Radioactive Waste System Walkdowns

a. Inspection Scope

The inspectors walked down portions of the liquid and solid radwaste processing

systems to verify that these systems were consistent with the descriptions in the UFSAR

and in the Process Control Program and to assess the material condition and operability

of those systems. The inspectors reviewed the status of radioactive waste process

equipment that was not operational and/or was abandoned in place. The inspectors

discussed with the licensee the administrative and/or physical controls preventing the

inadvertent use of this equipment to ensure that the equipment would not contribute to

an unmonitored release path or be a source of unnecessary personnel exposure.

The inspectors reviewed changes to the waste processing system to verify the changes

were reviewed and documented in accordance with 10 CFR 50.59 and to assess the

impact of the changes on radiation dose to members of the public. The inspectors

reviewed the licensees processes for transferring waste resin into shipping containers

to determine if appropriate waste stream mixing and sampling was performed so as to

obtain representative waste stream samples for analysis. The inspector also reviewed

the methodologies for waste concentration averaging to determine if representative

samples of the waste product were provided for the purposes of waste classification in

accordance with 10 CFR 61.55.

These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.3 Waste Characterization and Classification

a. Inspection Scope

The inspectors reviewed the licensees methods and procedures for determining the

classification of radioactive waste shipments including the use of scaling factors to

quantify difficult-to-measure radionuclides. The inspectors reviewed the licensees most

recent radiochemical sample analysis results for each of the licensees waste streams,

and the associated calculations used to account for difficult-to-measure radionuclides.

These waste streams consisted of radwaste demineralizer resins, various filter media,

and dry active waste (DAW). The inspectors also reviewed the licensees use of scaling

16 Enclosure

factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting

radionuclides). The reviews were conducted to verify that the licensees program

assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G

of 10 CFR Part 20. The inspectors also reviewed the licensees waste characterization

and classification program to determine if reactor coolant chemistry data was

periodically evaluated to account for changing operational parameters that could

potentially affect waste stream classification and thus validate the continued use of

existing scaling factors between sample analysis updates.

These reviews represented one inspection sample.

b. Findings

No findings of significance were identified.

.4 Shipment Preparation and Records

a. Inspection Scope

The inspectors reviewed the documentation of shipment packaging, surveying, package

labeling and marking, vehicle inspections and placarding, emergency instructions, and

licensee verification of shipment readiness for six selected non-excepted radioactive

material and radwaste shipments, made between March 2006 and January 2007. The

shipment documentation reviewed included:

  • Equipment in a B-25 Box Shipped as Low Specific Activity (LSA);
  • Two Spent Resins Shipped as Type A;
  • Two Phase Separator Resins Shipped as Type A; and
  • Part 61 Resin Samples Shipped as LSA.

For each shipment, the inspectors determined if the requirements of 10 CFR Parts 20

and 61 and those of the Department of Transportation (DOT) in 49 CFR Parts 170-189

were met. Specifically, records were reviewed, and staff involved in shipment activities

were interviewed to determine if packages were labeled and marked properly, if

packages and transport vehicle surveys were performed with appropriate

instrumentation, whether survey results satisfied DOT requirements, and if the quantity

and type of radionuclides in each shipment were determined accurately. The inspectors

also determined whether shipment manifests were completed in accordance with DOT

and NRC requirements, if they included the required emergency response information, if

the recipient was authorized to receive the shipment, and if shipments were tracked as

required by 10 CFR Part 20.

Selected staff involved in shipment activities were interviewed by the inspectors to

determine if they had adequate skills to accomplish shipment related tasks and to

determine if the shippers were knowledgeable of the applicable regulations to satisfy

package preparation requirements for public transport with respect to NRC

Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial.

Also, the inspectors reviewed the transportation specific training for the authorized

shippers to assure that they met the requirements of 49 CFR Part 172, Subpart H.

17 Enclosure

These reviews represented two inspection samples.

b. Findings

(1) Shipment Total Quantity Re-characterized After Shipping

A shipment of phase separator resins was shipped from Clinton Power Station

September 30, 2005, and delivered to a vendor on October 1, 2005. The total curie

quantity in the shipment was in excess of the vendors Agreement State license limits.

The vendor communicated this discrepancy to shipping personnel at Clinton Power

Station on October 3, 2005. The shipper then re-characterized the total quantity of the

shipment by reviewing dose rate survey data and applying a dose to curie

methodology. Contrary to Clinton procedure, the re-characterization was not reviewed

by other Clinton personnel and new paperwork for the shipment, including a new NRC

Form 541 was generated and transferred to the recipient.

This event remains under review by the NRC and is categorized as an Unresolved Item

(URI) (URI 05000461/2007004-01).

.5 Identification and Resolution of Problems for Radwaste Processing and Transportation

a. Inspection Scope

The inspectors reviewed selected condition reports, self-assessment and audit reports,

along with field observation reports that addressed the radioactive waste and radioactive

materials shipping program, since the last inspection to determine if the licensee had

effectively implemented the corrective action program and if problems were identified,

characterized, prioritized, and corrected. The inspectors also determined whether the

licensee's self-assessment program was capable of identifying repetitive deficiencies, or

significant individual deficiencies in problem identification and resolution.

The inspectors also selectively reviewed other corrective action program reports

generated since the previous inspection that dealt with the radioactive material or

radwaste shipping program, interviewed staff, and reviewed documents to determine if

the following activities were being conducted in an effective and timely manner,

commensurate with their importance to safety and risk:

  • Initial problem identification, characterization, and tracking;
  • Disposition of operability/reportability issues;
  • Evaluation of safety significance/risk and priority for resolution;
  • Identification of repetitive problems;
  • Identification of contributing causes;
  • Identification and implementation of effective corrective actions;
  • Resolution of Non-Cited Violations tracked in corrective action system(s); and
  • Implementation/consideration of risk significant operational experience feedback.

These reviews represented one inspection sample.

18 Enclosure

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES (OA)

4OA1 Performance Indicator Verification (71151)

To perform a periodic review of performance indicator (PI) data to determine its

accuracy and completeness.

Cornerstones: Mitigation Systems

1. Mitigating Systems Performance Indicators (MSPI)

a. Inspection Scope

The inspectors sampled the licensees submittals for performance indicators for the

period of July 2006 through June 2007. The inspectors used performance indicator

definitions and guidance contained in revision 5 of Nuclear Energy Institute (NEI)

document 99-02, Regulatory Assessment Performance Indicator Guideline, to verify

the accuracy of the performance indicator data. The inspectors performed three

samples by reviewing the following:

b. Issues and Findings

No findings of significance were identified.

2. Safety System Functional Failures Performance Indicator

a. Inspection Scope

The inspectors reviewed, at a minimum, the most recent 24 months of Licensee Event

Reports, licensee data reported to the NRC, plant logs, issue reports, and NRC

inspection reports to verify the following performance indicators reported by the

licensee for the 2nd Quarter of 2007 for Safety System Functional Failures.

The inspectors verified that the licensee accurately reported performance as defined by

the applicable revision of Nuclear Energy Institute Document 99-02, Regulatory

Assessment Performance Indicator Guideline.

This performance indicator review constituted one inspection sample.

19 Enclosure

b. Findings

No findings of significance were identified.

Cornerstones: Public Radiation Safety and Barrier Integrity

a. Inspection Scope

The inspectors reviewed the licensees determination of PIs for the Public Radiation

Safety Performance Indicator (Radiological Environmental Technical

Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences) and

Barrier Integrity Performance Indicator (Reactor Coolant System Specific Activity) to

determine if the licensee accurately determined these performance indicators and had

identified all occurrences. Specifically, the inspectors reviewed the licensees

corrective action program documents for the 4th quarter of CY 2006 and the 1st, 2nd, and

3rd quarters of CY 2007 and Public Radiation Safety and Barrier Integrity Performance

Indicator data to ensure that there were no PI occurrences that were not identified by

the licensee. In addition to record reviews, the inspectors observed a chemistry

technician obtain and analyze a reactor coolant system sample. The inspectors

interviewed members of the licensees staff who were responsible for performance

indicator data acquisition, verification and reporting, to determine if their review and

assessment of the data was adequate.

These reviews represented two inspection samples.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152)

a. Inspection Scope

As discussed in previous sections of this report, the inspectors routinely reviewed

issues during baseline inspection activities and plant status reviews to verify that they

were being entered into the licensees corrective action system at an appropriate

threshold, that adequate attention was being given to timely corrective actions, and that

adverse trends were identified and addressed. In addition, the inspectors reviewed the

following issue:

b. Findings

There were no findings of significance identified. The inspectors reviewed procedure

OP-AA-102-103, Operator Work-Around Program, and the issues being tracked for

program resolution. As of July 23, 2007, there were two operator workarounds that

were being tracked for resolution. The inspectors review determined that the issues

were appropriately characterized as operator workarounds.

20 Enclosure

The inspectors also reviewed selected operations department concerns and out of

tolerance items that were identified in operations narrative logs to identify potential

operator workarounds that were not in the program. The inspectors concluded that

there were no additional workarounds identified from the sources reviewed.

On August 2, 2007, the inspector attended a WorkAround Board (WAB) meeting. One

of the items under review that was identified during forced outage C1F049 and

documented by IR 642141, was the operation of 1E12-F009, residual heat removal

shutdown cooling inboard isolation valve, from the main control room. The valve would

not open or close electrically (i.e., mechanically bound). An operator workaround

program review was not requested by IR 642141. The resident inspectors questioned

the licensee on the appropriateness of not conducting an operator workaround program

review. This resulted in the August 2 review of this condition. In addition, the licensee

generated IR 656515 on the missed opportunity to conduct an operator workaround

program review of 1E12-F009 valve operation. On August 2, 2007, the WAB approved

1E12-F009 valve operation as an operator workaround. The WAB member dialogue

on the issues that were reviewed on August 2, 2007, was at the appropriate level of

detail, and considered operator compensatory actions required to comply with plant

procedures, design requirements and technical specifications.

4OA3 Event Follow-up (71153)

.1 (Closed) LER 05000461/2005-001-00. Inadequate Procurement Specification for

Charcoal Results in Inoperable Control Room Ventilation Subsystem.

Introduction: A performance deficiency involving a Non-Cited Violation of

10 CFR Part 50, Appendix B, Criterion IV, Procurement Document Control, was self

revealed following receipt of results that showed that Division 1 control room ventilation

(VC) system charcoal filter penetration values were higher than allowed by Clintons

Technical Specifications. This issue occurred because the licensee failed to establish

proper purchase specifications for charcoal used in the VC system. Additionally, this

issue led to Division 1 VC subsystems being inoperable from May 9 through

May 16, 2005, concurrent with Division 2 VC subsystems being inoperable due to

planned maintenance from May 9 through May 14, 2005.

Description: On May 4, 2005, the licensee took charcoal absorber samples from the

Division 1 VC recirculation charcoal bed filter in order to perform charcoal penetration

testing as required by VC system Technical Specification surveillance requirement 3.7.3.3. On May 9, 2005, planned maintenance was performed on the Division 2

emergency diesel generator resulting in it becoming inoperable. The licensee also

declared the Division 2 VC subsystem inoperable because of the diesel inoperability.

The Division 2 emergency diesel generator and the Division 2 VC system were

declared operable on May 14, 2005, following completion of planned maintenance on

the emergency diesel generator. On May 16, 2005, the licensee received the

Division 1 charcoal sample analysis results which showed that after applying a

correction factor, the charcoal penetration value was 8.168. This charcoal penetration

was higher than the charcoal penetration operability value of 6.0 contained in Clintons

Technical Specifications.

21 Enclosure

Because of the unsatisfactory results, the licensee concluded that the seven day

required action completion time to restore an inoperable VC subsystem was not met,

nor was the required action to be in Mode 3 and Mode 4 per Clintons Technical

Specifications. Additionally, the Division 2 VC subsystem was inoperable from

May 9 to May 14, 2005, due to the Division 2 emergency diesel generator maintenance

outage. The licensee concluded that the station was in Technical Specification (TS) 3.7.3 required action D.1, requiring entry into TS limiting condition for operation

(LCO) 3.0.3. The licensee did not enter the TS 3.7.3 required action and LCO 3.0.3,

since the sample results were not known during the emergency diesel generator

outage.

A licensee investigation concluded that the cause of this event was that charcoal

purchasing requirements were inadequate for the unique application at Clinton. The

licensee purchased the charcoal installed in the Division 1 VC system to

ANSI/ASME N509-1980, Nuclear Power Plant Air Cleaning Units and Components.

According to the licensee, this industry standard had no limit on as-manufactured

moisture levels. The licensee concluded that the Clinton VC systems unique design

attributes, which included higher than normal airflow velocity, thin charcoal beds, and

no airflow heaters coupled with high as-manufactured moisture levels significantly

reduced the charcoal residence time and increased the penetration levels. The

licensee investigation also concluded that 10 percent of the charcoal contained in the

failed filter was caked after 17 months of operations. The licensee stated that this

caking was again proof of high as-manufactured moisture content.

The failed charcoal bed filter contained coal from lot 55, batch 68. The licensees extent

of condition review determined that this event was limited to the VC A recirculation

charcoal bed filter. The bases of this conclusion were that penetration tests results

were satisfactory for the other beds in the VC system and no lot 55, batch 68, charcoal

was in storage. The licensee investigation also determined that the charcoal in lot 55,

batch 68, had as-manufactured high moisture content of at least 12 percent by weight.

All charcoal currently in storage was confirmed to have a moisture content of less than

eight percent.

The inspectors were concerned that the licensee maintenance scheduling process

would allow for the redundant VC subsystem to be made inoperable without knowing

the results of the Technical Specification required sample analysis. The inspectors

concluded poor scheduling of work contributed to both VC subsystems becoming

inoperable per the licensees Technical Specifications. The licensee did not address

this issue in the root cause report. In response to the inspectors questions in this area,

the licensee provided issue report 340314, Enhancement to Manage Risk of Charcoal

Samples. This issue report addressed the inspectors concern, in that, it incorporated

corrective actions that implemented an administrative trigger using model work orders

to ensure that no work would be scheduled for the next work week that would cause an

inoperability of the opposite train or its support systems. This administrative trigger

was placed into model work orders for all VC system and standby gas treatment

system predefined activities.

Analysis: The inspectors determined that the licensees failure to provide adequate

purchase specifications to satisfy the requirements for the Clinton unique VC system

22 Enclosure

was a performance deficiency warranting a significance evaluation. The inspectors

concluded that the finding was more than minor in accordance with IMC 0612, Power

Reactor Inspection Reports, Appendix B, because the finding affected the objective of

the Barrier Integrity cornerstone of assuring that physical design barriers protect the

public from radionuclide releases caused by accidents or events. Additionally, this

issue is associated with the barrier performance attribute of maintaining Radiological

Barrier functionality of the control room. Failure to ensure adequate purchase

specifications resulted in there being a period where both trains of control room

ventilation were inoperable without the knowledge of the operators.

The inspectors completed a Phase 1 significance determination using IMC 0609,

Significance Determination Process, Appendix A, Attachment 1, dated

March 23, 2007. Using IMC 0609 Appendix A, SDP Phase 1 screening worksheet, the

inspectors determined that this issue degraded the Containment Barrier. The

inspectors answered Yes, to whether the finding only represents a degradation of the

radiological barrier function provided for the control room, or auxiliary building, or spent

fuel pool, or SBGT system (BWR). As a result, the Phase 1 Worksheets screened as

Green.

The finding is also related to the cross-cutting area of Human Performance as defined

in IMC 0305, Operating Reactor Assessment Program, specifically, the finding is

related to the resources and work control component because the licensee did not

provide an adequate purchase specification reflective of the requirements for the VC

system. However, this issue was determined not to have a cross-cutting aspect

because it was over two years old and not reflective of current performance in this area

based on the inspectors review of the licensees effectiveness review of corrective

actions established to prevent this issue from occurring again.

Enforcement: 10 CFR Part 50, Appendix B, Criteria IV, Procurement Document

Control states that measures shall be established to assure that applicable regulatory

requirements, design bases, and other requirements which are necessary to assure

adequate quality are suitably included or referenced in the documents for procurement

of material, equipment, and services, whether purchased by the applicant or by its

contractors or subcontractors.

Contrary to the above, Clinton Power Station failed to specify in a procurement

document the moisture content for charcoal filters to be used in the VC system. This

issue resulted in charcoal being used in the division 1 VC system that was outside the

penetration limits established by Technical Specification 3.7.3, from May 4 to

May 16, 2007. This issue also resulted in both control room ventilation systems being

inoperable. The licensee entered this issue into the corrective action program (CAP)

as issue reports 335698 and 340314. Corrective action for this issue included revising

the charcoal purchase specifications to limit as-manufactured content of eight percent

by weight. Additionally, the licensee added limitations to model work orders to prevent

or limit the scheduling of work that could impact the operability of redundant systems

that contained charcoal. Because the licensee entered the issue into the CAP and the

finding is of very low safety significance, this violation is being treated as an NCV,

23 Enclosure

consistent with Section VI.A of the NRC Enforcement policy.

(NCV 05000451/2007-004-01)

.2 (Closed) LER 05000461/2007-003-00, IGSCC Causes RCS Pressure Boundary Leak

and Reactor Shutdown

a. Inspection Scope

The inspectors observed the station response to a steam leak in the drywell on

June 18, 2007. The inspectors arrived in the control room approximately two hours

after the initial alarms and indications of a leak were received and discussed the

actions that had been taken with control room operators. The inspectors then

proceeded to the outage control center, which had been manned for troubleshooting

and to support the control room in decision making, to discuss proposed actions with

licensee management. The inspectors reviewed the licensees troubleshooting

documents, equipment prompt investigation, root cause report, and LER 2007-003.

b. Findings

Introduction: A Non-Cited Violation of Technical Specifications (TS) having very low

safety significance (Green), was self-revealed when the licensee failed to meet the

required completion time for an action statement in TS 3.4.5. Specifically, TS 3.4.5

does not allow reactor coolant system pressure boundary leakage and requires a

shutdown to Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if pressure boundary leakage is discovered. Upon

entry into the drywell following a shutdown of the reactor on June 19, 2007, the

licensee discovered the existence of reactor coolant system (RCS) pressure boundary

leakage. Indications of the leakage had been discovered at 0433 on June 18, 2007,

but the plant was not placed in Mode 3 until approximately 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> later at 1125 on

June 19, 2007.

Description: At 0433 on June 18, 2007, plant operators responded to main control

room alarms and other indications, and determined the presence of a steam leak in the

drywell. The initial alarms included: Transient Test Alarm, Fission Product Particulate

High Radiation, and Fission Product Iodine High. Other indications included transient

test system trouble, channel 119, main steam line C elbow tap differential pressure, an

increased trend in drywell pressure rise, and the fission product monitor particulate and

iodine channels had taken a step change. The operators took appropriate actions in

accordance with station procedures for reactor coolant leakage and abnormal release

of airborne radioactivity. The operators noted that a spike in main steam line C elbow

tap differential pressure was an indication of a steam leak somewhere in the area of

the elbow tap. The C main steam line elbow taps were located within the area

considered reactor coolant system pressure boundary. The operators entered TS 3.4.5

actions C.1, be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and C.2, be in Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The licensee manned the outage control center at 0641. After further deliberations, the

licensee noted that there were other components (mechanical joints for flexi-hose) that

are associated with the C main steam line flow instrumentation that are not considered

pressure boundaries and, therefore, the increase in drywall leakage was not

24 Enclosure

necessarily pressure boundary leakage. Based on this, the licensee then decided to

consider the steam leak as unidentified leakage. With the change in classification to

unidentified leakage the leak rates did not meet any of the requirements for remaining

in TS 3.4.5. The licensee exited action statements C.1 and C.2. However, although

small, the leakage continued to increase. Due to the steady increase in unidentified

leakage, operators commenced a normal plant shutdown at 2011 on June 18, 2007, to

enter the drywell and identify the actual location of the steam leak. At 0635 on

June 19, 2007, maintenance personnel entered the drywell and found pressure

boundary leakage on a one-inch diameter ASME Section III Class II stainless steel

braided flexible hose assembly on the C main steam line flow elbow tap. Operators

once again entered the actions of TS 3.4.5 due to reactor coolant pressure boundary

leakage. The plant entered Mode 3 at 1125 on June 19, 2007, (approximately 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />

after indication of pressure boundary leakage), and Mode 4 at 2300 on June 19, 2007.

The licensee replaced the leaking flexible hose and initiated a root cause investigation.

The root cause determined that the leak was caused by intergranular stress corrosion

cracking of the flexible hose.

Analysis: The inspectors determined that failure to meet the required completion times

for TS actions was a performance deficiency warranting a significance evaluation. The

inspectors determined that the finding was more than minor by using Inspection Manual

Chapter 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening,

because operating with a degraded pressure boundary affected the reactor coolant

system (RCS) equipment and barrier performance attribute of the Barrier Integrity

cornerstone, in that, RCS pressure boundary leakage results in a reduction in the

reasonable assurance that physical design barriers protect the public from radionuclide

releases caused by accidents or events. The finding also affected the cross-cutting

component of Decision Making in the area of Human Performance in that operators

had initially entered TS 3.4.5 for pressure boundary leakage, but subsequently, the

organization decided not to treat the leak as pressure boundary leakage, but rather as

unidentified leakage until the actual location could be determined.

The inspectors completed a significance determination using IMC 0609, Significance

Determination Process. The Phase 1 worksheet directed the inspectors to consider

the reactor coolant system leakage under the Initiating Events Cornerstone column.

The inspectors answered Yes to question one under the Initiating Events cornerstone

column stating that assuming worst case degradation, the finding would result in

exceeding the TS limit for identified RCS leakage. The Phase 1 worksheet directed the

inspector to Phase II. For the Phase II screening, the inspectors used the table for a

small break loss of coolant accident, and conservatively set the initiating event

frequency to 1 (X=0), because the event was actually occurring in the form of the

steam leak. Since all of the mitigating equipment was available, the finding was

determined to be of very low safety significance (Green). The licensee established the

following corrective actions to address this issue: 1) replaced the leaking flexible hose,

2) scheduled replacement of all other flexible hoses used on the main steam lines

during the next refueling outage and 3) established a 16-year preventive maintenance

replacement frequency for the flexible hoses used on the main steam line.

Enforcement: Technical Specification 3.4.5 a. limits RCS operational leakage to

No pressure boundary leakage, and states that if pressure boundary leakage is

25 Enclosure

present, the plant is required to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Contrary to the above, on June 18, 2007, pressure boundary leakage was present and

the operators did not place the plant in Mode 3 for nearly 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> and Mode 4 for

approximately 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. Because this violation was of very low safety significance and

it was entered into the licensees corrective action program as IR 641375, this violation

was treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy.

The LER is closed. (NCV 05000461/2007004-02)

.3 Spent Fuel Bundle Incident During Rerack Project

Introduction: A performance deficiency involving a Non-Cited Violation of 10 CFR

Part 50 Appendix B, Criteria V, Instructions, Procedures, and Drawings, was

self-revealed following an event on August 17, 2007, where a spent fuel bundle being

moved to a temporary storage location came in contact with and rested upon another

fuel bundle seated in its storage location. The licensee procedure that governs spent

fuel pool movement failed to provide adequate guidance on how high to lift the fuel

bundle prior to traversing across the spent fuel pool.

Description: During spent fuel moves on August 17, 2007, in support of the spent fuel

pool re-rack project, a spent fuel bundle being moved by a spent fuel bridge operator

came in contact with the bail handle of a spent fuel bundle seated in its storage

location. Upon recognition of this situation the spent fuel bridge operator immediately

stopped. Immediately following the stoppage of the spent fuel bridge the licensee

observed that the fuel bundle was leaning slightly and the grapple-engaged light was

no longer lit. The grapple-engage light being no longer lit was an indication that the

grapple switch was no longer engaged and that an interlock was in place that

prevented the fuel bundle from being lifted vertically. Prior to resuming fuel movement,

the licensee verified that the grapple was indeed engaged by use of an underwater

camera. After this verification, the interlock associated with the grapple-engage light

was bypassed. The spent fuel bundle was then raised and placed back in its original

location.

A situation where a fuel bundle comes in contact with and rests upon another fuel

bundle is a concern because it challenges the integrity of the fuel cladding. The fuel

cladding is considered one of three physical barriers designed to separate the fuel from

the public and the environment.

Upon review of procedure CPS 3703.02,Fuel Handling Platform Operations, the

inspectors concluded that the procedure failed to provide adequate guidance on how

high the bundle should be lifted prior to moving the bundle to a new location. This

procedure was the administrative procedure which governs the operation of the bridge

and is used by the bridge operators to perform spent fuel pool movement. For example

step 8.2.2.15 requires lifting the bundle or blade until the grapple normal up light is lit

if moving the fuel bundle into the inclined fuel transfer system upender. The normal

up indication occurs at a reference vertical position (Z coordinate) of 0 inches. As

the fuel bundle is lowered from the normal up position, the Z coordinate increases.

Appendix A of the CPS 3703.02, showed several minimum fuel grapple Z coordinates

26 Enclosure

for various movements. The appendix showed that the fuel bundle must be at or above

Z position of 66 inches to enter the spent fuel pool racks.

The inspectors noted that a caution prior to step 8.2.2.15 states, it is not required to

raise the main hoist to normal up prior to platform or trolley movement, however

adequate clearance shall exist. The inspectors concluded that this step does not

contain adequate guidance on how high to lift the fuel bundle prior to moving it to

another location in the spent fuel pool. The inspectors concluded that the lack of

specific guidance caused this event to occur. Additionally, the procedure did not

require any form of verification or peer checks prior to fuel movement.

Analysis: The inspectors determined that the licensees failure to provided adequate

details in the procedure was a performance deficiency warranting a significance

evaluation. The inspectors concluded that the finding was more than minor in

accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, because

the finding affects the barrier integrity objective of assuring that physical design barriers

protect the public from radionuclide releases caused by accidents or events. The

finding is associated with the procedure quality attribute of the Barrier Integrity

cornerstone because it challenged the functionality of the fuel cladding.

The inspectors completed a Phase 1 significance determination using IMC 0609,

Significance Determination Process, Appendix A, Attachment 1, dated

March 23,2007. Using IMC 0609 Appendix A, SDP Phase 1 screening worksheet, the

inspectors determined that this issue degraded only the Fuel Cladding Barrier and its

associated cornerstone. Therefore, in accordance with the screening worksheet, this

issue screens directly as Green. This finding is related to a cross-cutting component

in the area of Human Performance associated with Resources (H.2(c)) because the

licensee did not provide complete and accurate procedures. Specifically, the

procedure relied on the skill of the operator and did not require independent

verification.

Enforcement: 10 CFR Part 50, Appendix B, Criteria V, Instructions, Procedures, and

Drawings states that activities affecting quality shall be prescribed by documented

instructions, procedures, or drawings, of a type appropriate to the circumstances and

shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, Clinton Power Station (CPS) procedure 3703.02 failed to

provide adequate instructions for handling spent fuel bundles. This resulted in a spent

fuel bundle that was being moved to a temporary storage location coming in contact

with another fuel bundle seated in its storage location on August 17, 2007. This issue

was entered into the licensees corrective action program as issue report 661918.

Corrective action included revising the fuel handling procedure. Because this violation

was of very low safety significance and was entered into the licensees CA program,

this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC

Enforcement Policy. (NCV 05000451/2007-004-03)

27 Enclosure

4OA4 Cross-Cutting Aspects of Findings

.1 A finding described in section 4OA3.2 of this report had, as its primary cause, a Human

Performance deficiency, in that, licensee decision making in determining the source of

a steam leak in the drywell resulted in exceeding the TS allowed time for placing the

plant in Modes 3 and 4 when RCS pressure boundary leakage was present.

.2 A finding described in section 4OA3.3 of this report had, as its primary cause, a Human

Performance deficiency, in that, the licensee failed to provide adequate procedural

guidance in regard to moving spent fuel in the spent fuel pool.

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. B Hanson and other members of

licensee management at the conclusion of the inspection on October 4, 2007. The

inspectors asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

.2 Interim Exit Meetings

Interim exit meetings were conducted for:

instrumentation and protective equipment with Mr. F. Kearney, Plant Manager on

August 10, 2007.

  • Radioactive Material Processing and Transportation program with Mr. B. Hanson

on September 21, 2007.

ATTACHMENT: SUPPLEMENTAL INFORMATION

28 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Hanson, Site Vice President

R. Kearney, Plant Manager

R. Schenck, Work Management Director

G. Vickers, Radiation Protection Director

J. Gackstetter, Regulatory Assurance Manager

R. Frantz, Regulatory Assurance Representative

M. Hiter, Access Control Supervisor

M. Friedmann, Acting Regulatory Assurance Director

C. VanDerburgh, Nuclear Oversight Manager

J. Domitrovich, Maintenance Director

D. Schavey, Operations Director

J. Rappeport, Acting Chemistry Manager

J. Lindsay, Training Manager

C. Williamson, Security Manager

R. Peak, Site Engineering Director

T. Chalmers, Shift Operations Superintendent

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened

05000461/2007004-01 URI Shipment Total Quantity Re-characterized After

Shipping (Section 2PS2.3)

05000451/2007-004-01 NCV Inadequate Procurement Specification for

Charcoal Results in Inoperable Control Room

Ventilation Subsystem

05000451/2007-004-02 NCV Failure to Comply with Technical Specification 3.4.5 for RCS Pressure Boundary Leak

05000451/2007-004-03 NCV Inadequate Procedure Results in Spent Fuel

Bundle Incident

Closed

05000461/2007-003-00 LER IGSCC Causes RCS Pressure Boundary Leak

and Reactor Shutdown

05000461/2005-001-00 LER Inadequate Procurement Specification for

Charcoal Results in Inoperable Control Room

Ventilation Subsystem

1 Attachment

05000451/2007-004-01 NCV Inadequate Procurement Specification for

Charcoal Results in Inoperable Control Room

Ventilation Subsystem

05000451/2007-004-02 NCV Failure to Comply with Technical Specification 3.4.5 for RCS Pressure Boundary Leak

05000451/2007-004-03 NCV Inadequate Procedure Results in Spent Fuel

Bundle Incident

Discussed

None

2 Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety but rather that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

1R01 Adverse Weather

OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines; Revision 2

OP-AA-102-102, General Area Checks and Operator Field Rounds; Revision 5

WC-AA-107, Seasonal Readiness; Revision 3

CPS 1019.05, Transient Equipment/Materials; Revision 11

CPS 4302.01, Tornado/High Winds; Revision 18e

1R04 Equipment Alignments

CPS 3319.01V001, Standby Gas Treatment Valve Lineup; Revision 8

CPS 3319.01E001, Standby Gas Treatment Electrical Lineup; Revision 10c

1R05 Fire Protection

CPS 1893.04M310, 719 Control: HVAC Equipment Area Pre-fire Plan; Revision 5a

Section 3.2.1.2, Fire Area A-2: Zone A-2a, Fire Protection Evaluation Report,

CPS 1893.01, Fire Protection Impairment Reporting, Revision 16a

CPS Updated Final Safety Analysis Report, Fire Hazard Analysis

CPS 1892.01, Fire Protection Impairment Reporting, 08/02/07, Revision 16b.

Section 6.2.6.3, Updated Safety Analysis Report

ANSI 56.8, 1987, Containment System Leakage Testing Requirements

Reg. Guide 1.163, Performanced - Based Containment Leak - Test Program

10 CFR 50 App. J., Primary Reactor Containment Leakage Testing for Water - Cooled Power

Reactors

CPS - ITS

CPS Risk Evaluation #1631, Risk Analysis for Missed Surveillance, failure to complete LLRT

on Containment Monitoring Test Lines

IR 660299, Type C Testing for LLRT Test Lines

1R06 Flood Protection

CPS 4304.01, Flooding, Revision 4e

IR 670686, Setpoints For Maximum Normal Operating Water Level Switches

IR 670693, Flood Water Level & Secondary Containment Temperature Instrumentation

IR 670429, Max Safe Flood Alarm Out of Cal in RH [residual heat removal] A Room

IR 670415, Max Safe Flood Alarms Out of Cal in RI Pump Room

1R07 Heat Sink Performance

WO 1005225, Open, Inspect, Boroscope, Eddy Current 100%, and Clean 1DG13A

ER-AA-340-1002, Service water heat exchanger and component inspection guide; Revision 3

IR 678934, Division three diesel generator heat exchanger chemistry results; October 2, 2007

IR 675035, Diesel generator jacket water cooler zinc modification execution impact;

September 24, 2007

3 Attachment

IR 675091, Excessive erosion discovered on the flange faces of 1VH03A; September 25, 2007

WO 01005225, Open, Inspect, Boroscope, Eddy Current 100%, and Clean

AR 00678934, Division II Diesel Generator HX (1DG13A) Chemistry Results

AR 00675035, Diesel Generator Jacket Water Cooler Zinc Mod Execution Impact

ER-AA-340-1002, Service Water Heat Exchanger and Component Inspection Guide,

Revision 3

1R12 Maintenance Effectiveness

IR 518197, NOS ID MSPI Basis Document Requires Revision

IR 519897, Potential Air Leak on 1VQ002 or 1VQ005

IR 520828, CPS 4001.02C001 Setpoint Update Needed

IR 524365, Automatic Reactor Scram on Reactor High Water Level

IR 524768, RCIC Isolation Troubleshooting Results

IR 552156, Condition Monitoring Failure - LD Inst 1E31N085A - RCIC Isolation

IR 550868, 1SX01PA: Low Margin for Division I SX Design Flows

IR 548493, 1C91P633: STS Failure, 5004-3H, RCIC Division 1 Card C-A14-A125

IR 530970, Invalid Assumption in Calculation

IR 556556, Unexpected Annunciators during STS Summary Card B-A11-A111

IR 557804, Evaluate Transmitter 1E31N085B Time Delay Settings

IR 557809, Received Annunciator 5004-3H, STS Failure

IR 648094, 1E51-F054 RCIC Drain Pot Bypass Valve has Small Packing Leak

IR 639727, RCIC Pump Outboard Bearing Bubbler Crosshairs not @ 90 Degrees

IR 631320, NRC Question: Impact of EC 365827 Changes on Close Time Test

IR 589210, RCIC Speed > 4600 RPM during Surveillance Testing

IR 589461, Found RCIC Turbine & Governor Oil Below the Standby Band

IR 627033, 1E51-N590: New RGSC Card Cat ID 1148300-01 Failed Testing

IR 587482, 1E51F046 Potential MOV Over Thrust Risk

IR 584757, 1E51N590: RCIC RGSC Module Replacement & Procedure Enhance

IR 562400, 1 Foot Steam Plum Leak at Base of 1E51N010

IR 555469, 1E51N010: 5063-2C Turbine Stm Line Wtr Drain Trap Level High

IR 555312, Crack Found in Housing for Level Switch during WO 924362

IR 535878, Minor Steam Leak under Insulation of RCIC Turbine 1E51-C002

IR 531654, RCIC Quick Start Surv CPS 9054.01C004

IR 531065, RCIC Turbine Stayed at Incorrect Speed during 9054.01C004

IR 529655, NOS IDD RCIC Restoration with out of Cal Pressure Transmi

IR 528901, IMD Lessons Learned form 1E31N085A Replacement

IR 524345, RCIC Division 1 Isolated Following Scram

IR 517311, Revise ARPs 5062-3D & 5063-2E and 3310.01

IR 517453, New Fittings for RCIC Vortex Mod does not Match Design

IR 517558, Mini-PM for RCIC Turbine 1E51-C002 - C1R11

IR 517768, Feasibility Study for RPV Head Piping

IR 517775, Security Required for RCIC Tank Control Sooner than Planned

IR 517874, TS 3.3.3.2, Remote Shutdown Instrumentation, Enhancement

IR 518522, E51-N655F Failed Initial +/- .25% Input/Output Comparison

IR 518849, Heater Support Stands not secured to Tank

IR 518932, Free Release of Transmitters

IR 519207, Transposition Error for RPM Values - RCIC Turbine Speed

IR 519208, 1TR-CM018 Points above Alarm Setpoint with no Alarm Leds Lit

IR 519566, Items Discovered on Carts not Properly RAM Tagged/Controlled

4 Attachment

IR 519776, Red Hose Found by RCIC Tank

IR 520032, NOS ID - Unavailability Baseline Data Errors in MSPI Basis Doc

IR 520069, Work Week Preps Did Not Identify Issues

IR 520293, NRC Question on MSPI Implementation

IR 520803, Contamination Found on Floor in RCIC Tank Valve Room

IR 520906, TS LCO 3.3.5.1/3.3.5.2 Logical Connections Need Indenting

IR 522049, NSRB Issue - Unsecured Cables at Contaminated Area Boundary

IR 522119, NOS ID - Deficiencies Found During NSRB Tour

IR 523330, NRC Identified MSPI Basis Document Error for HP

IR 524547, Possible Training Process Problem

IR 524893, Poor Decision Making in PORC Meeting

IR 525078, Actions Required RCIC High Steam Flow Time Delay EC 362261

IR 526991, Correction Needed for IR 518932 Response

IR 528013, New Card Received Damaged from Stores

IR 528655, NOS ID Line Not Properly Controlled

IR 528787, RP Work Practices Need Improvement

IR 529288, Enhancements to RCIC Restoration Procedure

IR 529423, NOS ID Technical Rigor Weakness for RCIC OpEval 524768-02

IR 529475, Revise Tornado Missile Hazard Analysis

IR 529411, Change to 9054.01C004, RCIC Quick Start Surveillance

IR 529718, Process Improvements in Status Control

IR 531090, Enhancements: Clarify Tech Spec Bases for LCO 3.5.3 RCIC

IR 531215, RCIC Procedure Lacks Steam Line Draining Steps

IR 531392, Ramp Generator Card Received with Jumper not used at CPS

IR 531410, FLS Provided Inaccurate Estimate for First Time Performance

IR 531412, RCIC Ramp Generator Card in Repair Program

IR 537945, Support for Estimating Flows for Mitigating Strategies

IR 539389, Trng: Simulator: Simulator Responses to Evaluated Scenario

IR 541955, RCIC Isolations Incorrectly Referenced in CPS 9532.16

IR 543371, Potential Trend in Equipment Failure Cause Identification

IR 543520, Evaluate Common Causes of RCIC System Issues

IR 543638, NOS-ID Appropriate Cause Evaluation not Assigned

IR 543661, Enhancement IR to Revise 9080.23

IR 546682, Trng: Drawing Reference is Incorrect

IR 553475, 1LL59BP18E: Electrolyte Level below Plates on Two Cells

IR 554669, B.5.B Phase 2 and 3 Closure Actions

IR 555735, Expectation not Met as Required by CPS Policy #54

IR 556474, Ownership of 3209.01 Raw Water Treatment

IR 557274, E-2 Ready to Work Exceptions not in Goal for WW645

IR 557833, RCIC Vent Pipe Leaks at Sampling Point with Sample Equipment

IR 558269, Fix RCIC Sampling

IR 559377, NOS ID Separation Criteria not Maintained During EC Install

IR 560786, NOS IDd Gaps in Technical Rigor Used in OP Determinations

IR 561779, 9030.01C034 & C035 Missing an Expected Alarm

IR 562215, Security Tour Improvement Opportunities

IR 562813, Procedural Conflict for RCIC Instrument Valve Position

IR 563344, 1E51F378 has Minor Packing Leak

IR 563348, Minor Oil Leaks on Oil Sightglass & Govenor Assembly

IR 563632, Replace LD Transmitters to Prevent RCIC Isolation

5 Attachment

IR 563745, Generate WO for LD Transmitter in Relation to CR-563632

IR 565444, NRC Non-Cited Violation 2006-11-02, RCIC Suction Vortexing

IR 567532, RCIC Valve 1E51-337 with Lockwire

IR 569112, ORM NTSP Value Incorrect for RCIC Storage Tank Level Low

IR 570095, NOS ID Project Plan for PI&R Inspection not Developed

IR 570783, Cause Analysis for HPCS Vortex Issue

IR 574514, Inappropriate Assignment of Corrective Actions

IR 579912, C1R11 Surv Opt HIT - 9438.05 Enhancements

IR 582944, Non-Oily Sheen on Top of Suppression Pool

IR 583348, Clean Up of Cask Wash Down Pit

IR 585490, Black Marker Found Floating in Suppression Pool

IR 588801, Procedure Enhancement to 9030.01C34

IR 588802, Procedure Enhancement to 9030.01C035 RI MS Sup Press

IR 588886, Enhance to 9054.02

IR 589228, 1RI01T: Notice of Violation (White Finding) Related to HPCS

IR 590313, Division 1 ADS Backup Air Bottles Losing 25-50 # per Day

IR 596320, Perform ISI/NDE and Provide Support Work Pre C1R11

IR 597183, Trng - Revision Needed to Operations Strategies Document

IR 599370, Install Walkway across Berm at the RCIC Tank

IR 599388, Install Sidewalk to RCIC Tank

IR 599404, Install Gate on Existing Walkway

IR 599942, Procedure Review/Enhancement for Remote Shutdown Actions

IR 599989, RCIC TTV Gimpel Valve Discontinuation Future Material

IR 600927, RCR Identifies Weakness in OP-AA-108-115/OP-AA-106-1006

IR 600993, INPO CDE Website, MSPI PRA Data

IR 603347, NOS ID Post August 2006 Organization Weakness not Addressed

IR 603659, NOS ID Inadequate Appl of Standards during Work Activities

IR 604716, 1E51-N636A as Found DAC Values OOT

IR 608092, Trng - Changes to Transient Mitigation Needed

IR 608292, 2007 NRC PI&R Observation on Use of OPEX

IR 610762, Work Orders Removed from Week 0719 Parts

IR 610943, PMRQ for RV 1E12-F036 Specifies Incorrect Testing and Freque

IR 613782, 9027.01C007 Section 8.7.7 Challenges SX Loads

IR 613800, Work Orders Removed from Week 0719

IR 615740, NOS ID Stated Apparent Cause was not addressed in EOC

IR 617461, RCIC Isolation Bypass Switch Operations in not Crisp

IR 618123, E-4 Clearance Indicator not at Goal of 100%

IR 602553, RCIC Transmitters not Available for SOW

IR 602760, Perform Inspection of Component Supports and Support

IR 602867, Procedure Enhancement for Filling RCIC Storage Tank

IR 618251, Fuse Missing form Interlock for Doors 329 and 330

IR 618423, Trng - Enhancement to 3310.01 RCIC

IR 619749, Tornado Missile Found in the RCIC Berm

IR 621632, NOS ID Trend Codes for CAP Products not Consistency Entered

IR 622636, Enhancement to ECCS Availability Due to WL Pump Availability

IR 622674, Missed Opportunity: Late Cancellation of a Work Order

IR 623199, RAT SVC Tripped Resulting in Unplnd Entry into 72 hr SD LCO

IR 623608, RCIC System Outage Questions

IR 623611, CDBI FASA Â Configured Design Specification not Updated

6 Attachment

IR 624129, Use of Admin Controls during RCIC Surveillance

IR 624937, WO 19406 Removed from Week 0719 due to Parts

IR 625517, MSPI Related Work Windows are not Consistently Scheduled

IR 626291, A TDRFP Oil Leak at 1PSFW105

IR 626496, RHR Unprojected Unavailability SSPI/MSPI Impact

IR 626577, Clearance Program Tag Font Remains Ambiguous/Unclear

IR 626578, Safety - Cannot Access Scaffold #5465 Safely

IR 627067, 1C88N2403: TT Point 30 Failed Calibration

IR 627527, 1E51N003: Computer Point E51DA001 Out of Spec Low (OOT)

IR 627710, Enhancement to ARP 5063-2D

IR 628094, 1C88K607: Received Spurious Trip of TTHMI Server Channel 119

IR 628259, CDBI FASA Enhancement to Loss of AC Off Normal 4200.01

IR 629191, CDBI FASA - Check Valve 1E22-F016 Not in ATLAS

IR 630647, 1RIX-AR013 Alert Alarm due to Spike

IR 632033, PMS Requires Valve Cycling in D/W and STM Tunnel

IR 632043, LL on LLRT Type C Test

IR 632321, Enhancement to CPS 3315.02, Leak Detection (LD)

IR 632785, CDBI FASA: Leakage to RCIC Tank not Updated in Alt. ST Docs

IR 634385, Placement of Red/Green Dots in the MCR

IR 634633, INPO Walk Downs List of Discrepancies

IR 635283, 1VX14S Air Gap Between Housing and Cooling Coils 1VX14AA/AB

IR 636156, NRC Performance Indicator for SSFFS in Action Region

IR 636753, Chemistry Sample Results for 1VY04A RCIC Room Cooler

IR 636859, 9030.01C007 Enhancement

IR 637549, Trng - Procedure Enhancement 3310.01 RCIC

IR 638917, 1C71S001C: Unexpected Alarms Division 3 NSPS Inverter

IR 641088, No Engineered Test Points for Jumper/Test Leads in 9532.13

IR 644916, Set Test Condition for RI Min Flow Valve Therm. Overl. Test

IR 647267, 1C91P633: Received 5004-3H STS Failure

IR 648508, 3220.01 Requires Revision to Support C1R11

IR 649191, Procedure Step Needs Revision Regarding Bypass Switch

IR 652248, CAPR not Implemented as Worded

IR 654201, NOS ID: Trending of PAR Data for Common Causes

IR 616603, 1E51N052: Unexpected MCR Alarm During 9054.06

IR 654764, NRC Questions RCIC Turbine Inboard Bearing Oil Level

IR 627562, 1E51F064: Abnormal Voltage Indicated During Surveillance

IR 627546, 9861.02D015 Test Set A had Leakage in Excess of 20,000 SCCM

ER-AA-310, Implementation of the Maintenance Rule, Revision 6

ER-AA-310-1001, Maintenance Rule - Scoping, Revision 3

ER-AA-310-1002, Maintenance Rule - SSC Risk Significance Determination, Revision 2

ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 3

ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 5

ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a) (1) and (a) (2), Revision 5

ER-AA-310-1006, Maintenance Rule - Expert Panel Roles and Responsibilities, Revision 3

ER-AA-310-1007, Maintenance Rule - Periodic (a) (3) Assessment, Revision 4

Performance Criteria Report for RI System

Failure Report for RI System

Scoping/Risk Significance Detailed Report for RI System

7 Attachment

Assessment of Maintenance Effectiveness; 10CFR50.65 (a) (3) Assessment; Clinton Power

Station; 3/1/2004 to 3/1/2006.

CPS Technical Specifications: TS 3.8.4, 3.8.5, and 3.8.6 and associated bases

USAR Section 8.3.2

Vendor Manual K2989-0001, Power Conversion Products Battery Chargers

IR 546815, Division 2 DC Bus Voltage Fluctuations

IR 651865, Potential Adverse Trend on Division 4 DC Bus Voltage

CPS System DC Equipment Failure Report for July 2005 to July 2007

1R15 Operability Evaluations

IR 671001, Essential switchgear cooling C shutdown service water line thickness below

minimum screening criteria; September 13, 2007

EC 367363, Minimum wall calculation for reducer small ends for 3"X1.5" swg at valve

1SX025C on line 1SX23AC-3", Revision 0

IR 667633, Through body leak 1SX019B; September 4, 2007

IR 667865, Issues identified during disassembly of 1SX019B valve; September 5, 2007

IR 667974, LL valve has through body leak after decision to defer repair; September 5, 2007

IR 668216, ASME code case N-513-1, Augmented volumetric exam of 1SX20AA;

September 5, 2007

IR 668217, ASME code case N-513-1, augmented volumetric exam of 1SX23BA;

September 5, 2007

IR 668220, ASME code case N-513-1, augmented volumetric exam of 1SX23AB;

September 5, 2007

IR 668221, ASME code case N-513-1, augmented volumetric exam of 1SX23AC;

September 5, 2007

IR 668223, ASME code case N-513-1, augmented volumetric exam of 1SX04AC;

September 5, 2007

IR 668304, Division 3 control room ventilation chiller shutdown service water supply/return

vacuum breakers leaking; September 6, 2007

IR 670094, Division 3 shutdown service water ultrasonic testing results below screening

criteria; September 11, 2007

IR 670193, Essential switchgear cooling A shutdown service water piping ultrasonic testing

results below screening criteria; September 11, 2007

IR 670479, Isolated points on shutdown service water A piping less than minimum evaluation

criteria; September 12, 2007

EC 367242, Temporary acceptance of pitting of the VC-B head pressure controller valve body,

1SX019B; Revision 0

IR 666899, 1SX019B: Cavitation damage found in valve body; August 31, 2007

IR 658234, NRC Questions on OPEVAL 655836-02; August 07, 2007

1R19 Post Maintenance Testing

IR 671554, 0VC03CA fan replacement post job review - WW 0736; September 14, 2007

EC 366835, Modification to replace supply fan 0VC03CA; Revision 0

WO 969991, 0VC03CA -VC A Supply Fan Noise; September 9, 2007

IR 675847, Cut O-ings; September 26, 2007

IR 675914, Division 3 emergency diesel generator turbocharger drain tubing missing;

September 26, 2007

IR 676864, Out of specification parameters on Division 3 diesel generator during surveillance

run; September 28, 2007

8 Attachment

IR 676905, K1 Lockout relay failed to trip emergency diesel generator; September 28, 2007

WO 795653, Replace Normally deenergized relay 1E22S001B-8; September 28, 2007

WO 1005265, Division 3 diesel generator six year maintenance: September 28, 2007

CPS 9080.03, Diesel generator 1C operability - Manual quick start operability; Revision 28e

CPS 3316.01,

CPS Operations Narrative Logs for August 14, 2007

WO 909977, Replace Rosemount Transmitter

WO 318466, EM Troubleshoot/Repair 1DC07E

1R22 Surveillance Testing

CPS 9054.01D002, RCIC (1E51 - C001) High Pressure Operability Checks Checklist,

Revision 23a

CPS 9054.01C002, RCIC (1E51 - C001) High Pressure Operability Check, Revision 2b

CPS 9054.01, RCIC System Operability Check, Revision 42e

IR 657976, Unexpected Alarm 5063 -1D RCIC Pump Suction Press

IR 658065, 1E51-F059 Limit switch Didnt Operate Properly During 9054.01

IR 627527, 1E51N003: Computer Point E51DA001 Out of Spec Low (OOT)

IR 658055, RCIC Turbine Steam Disch Press Gauge Reads Zero #

CPS 9052.01, LPCS/RHR A Pumps & LPCS/RHR A Water Leg Pump Operability, 09/13/06;

Revision 43d,

IR 655830, 1E21F349A Unquantifiable Seat Leakage

IR 655831, 1E21F350A Unquantifiable Seat Leakage

IR 655833, 1E21R501, Gauge Overanged During 9052.01

IR 655836, 1E12F084A, WLP Check To RHR A, failed to close

IR 655838, 1E12F085A, WLP to RHR a, failed to close

IR 658200, Senior Resident Has Question on RCIC Alarm; August 07, 2007

Clinton Power Station Updated Final Safety Analysis Report

CPS Technical Specification Surveillance Requirement 3.8.1.3 and associated bases

CPS 9080.02, Diesel generator 1B Operability - Manual and Quick Start Operability;

Revision 47d

IR 660893, NRC Questioned KVAR Loading on 9080.02 Division 2 Diesel; August 15, 2007

CPS 9069.01, Shutdown Service Water Operability Test; Revision 45

CPS Technical Specification 3.7.1/3.7.2 and associated bases

CPS 9861.09D007, Leakage Test on Valve 1CC075B and 1CC076B, Revision 1a

2PS2 Radioactive Material Processing and Transportation

USAR Chapter 11 Solid and Liquid Radwaste Management System, Revision 11

2006 Annual Radioactive Effluent Release Report; dated April 27, 2007

AR 435702435702 Chemistry, Radwaste, Effluent and Environmental Monitoring Audit Report Audit

NOSA-CPS-06-04; dated April 19, 2006

AR 302506302506 Contamination Found in a Twenty Foot Sea Van; dated February 17, 2005

AR 309873309873 Incorrect Dose Rate Listed in Waste Shipment Notification; dated March 8, 2005

AR 345179345179 Legacy Filter Waste Stores Without an Inventory; dated June17, 2005

AR 354609354609 Laundry Trailer Found with Small Hole in Flooring; dated July 19, 2005

AR 430473430473 FlatBed Trailer Separated from Semi-Tractor While Moving; dated

December 5, 2005

AR 451440451440 Incomplete Departure Survey Documentation; dated February 8, 2006

AR 476188476188 Radioactive Shipping Documentation Errors; dated April 7, 2006

AR 539967539967 Inability to Transfer Waste Sludge to Vendor; dated October 4, 2006

9 Attachment

AR 569198569198 Radiation Protection Audit Report; dated September 5, 2007

AR 577885577885 0WX02TA:Lessons Learned On 10 CFR 61 Analysis; dated January 11, 2007

AR 578765578765 Invalid Data initially Generated; dated January 12, 2007

AR 585131585131 Deficiencies in Shipping Documents Found; dated January 30, 2007

AR 617139617139 Radwaste Vendor Processing Creates Elevated Dose Rates in Walkway; dated

April 14, 2007

AR 626907626907 Water on Floor of Sealand Number 59; dated May 8, 2007

AR 643431643431 Fluid Found on Incoming Radioactive Material Shipment; dated June 22, 2007

AR 661628661628 Rotor Cribbing Found Deteriorating More Than Last Inspection; dated August 17,

2007

AR 672300672300 Approximately 50 Milliliters Leak From Sealand Onto Trailer; dated

September 17, 2007

ASSA 563448; Transportation and Radwaste Self-assessment; dated July 20, 2007

ASSA 581780-04; detailed Review of 2004 Through 2006 Shipping Records; dated

January 31, 2007

RP-AA-100; Process Control Program For Radioactive Wastes; Revision 4

RP-AA-600; Radioactive Material/Waste Shipments; Revision 10

RP-AA-602; Packaging of Radioactive Material Shipments; Revision 12

RP-AA-603; Inspection and Loading of Radioactive Material Shipments; Revision 3

RP-CL-605-1001; CPS 10 CFR Part 61 Program; Revision 1

CPS 3909.01; Operating Spent Resin System; Revision 21

CPS 3909.02; Operating Phase Separators; Revision 20e

CPS 3909.03; Operating Waste Sludge System; Revision 20d

CPS 3909.04; Operating Concentrate Waste System; Revision 15b

CPS 3909.05; Operating Fuel Pool Filter Demineralizer Sludge System; Revision 12b

CPS 6418.04; Analysis of Radwaste Samples for Solid Waste Processing; Revision 9b

CY-AA-110-200; Sampling; Revision 5

CPS 3222.10; Reactor Sample Station; Revision 10

2OS1 Access Control to Radiologically Significant Areas

AR289955289955 NOSA-CPS-05-06; Health Physics Functional Area Nuclear Oversight Audit; dated

July 27, 2005

AR 537844537844 Purple Painted tool Found Outside the Radiologically Restricted Area; dated

August 29, 2006

AR 575308575308 Building wall Damaged in Rotor Storage Building; dated January 4, 2007

AR 582546582546 1DR1-142 Door Hanging-up; dated January 24, 2007

AR 601273601273 High Radiation Area Near Miss Event; dated March 8, 2007

AR 633042633042 Emergent High Radiation Area Access; dated May 23, 2007

AR 630925630925 Radiography Inspection Terminated Due To Boundary Dose Rates; dated

May 16, 2007

RP-AA-210; Dosimetry Issue; Usage and Control; Revision 10

RP-AA-460; Controls for High and Very High Radiation Areas; Revision 12

RP-AA-460-101; Radiological Key Control and Area Access Requirements; Revision 3a

RP-AA-460-1001; Additional High Radiation Exposure Control; Revision 2

RP-AA-460-1002; High Radiation Area and Locked High Radiation Areas Briefing Form

RWP 10002868; Spent Fuel Pool Re-Rack Diving; Revision 0

RWP 10007956; Spent Fuel Pool Re-Rack; Revision 3

10 Attachment

OA2 Identification and Resolution of Problems

OP-AA-102-103; Operator Work-Around Program; Revision 1

CPS 9000.10; Accident Monitoring And Remote Shutdown Instrumentation Log; Revision 31a

IR 610835; Eval. Division 1 & 2 H2O2 Monitor INOP Printers: OPS Workaround; March 30,

2007

IR 624538; NOS ID Operations Workaround Leads To Fire Door Impairment; May 2, 2007

IR 575009; Permanent Access Solution Needed For 1FW004 Valve; January 3, 2007

IR 617958; Off-Normal Response Enhancement; April 16, 2007

IR 572918; Eval. Main Turbine BRG #9 Vibe Problem As Operator Challenge; December 25,

2006

IR 567237; 1KYCP105H Repeat Timer Did Not Advance - OP Challenge; December 9, 2006

IR 642744; TDRFP B Turning Gear Failed To Disengage Automatically; June 21, 2007

IR 652502; 1HG02CA Greater Than 3 Hours Run Time In July 2007; July 22, 2007

IR 656515; Missed Opportunity For Operator Work Around/Challenge Review; August 2, 2007

WO 843352; Task 01; Contingent Task To Disassemble, Inspect And Repair Valve 1E12F009

Due Seat Leakage

OA3 Event Followup

LER 05-461/2007-003-00, IGSCC Causes Pressure Boundary Leak and Reactor Shutdown;

August 16, 2007

IR 641375, 4001.01 Reactor Coolant Leakage; June 18, 2007

RCR 641375, Flexible hose failure on Main Steam Line C results in manual reactor shutdown

for replacement

11 Attachment

LIST OF ACRONYMS USED

ADAMS Agency wide Documents Access and Management System

ALARA As-Low-As-Reasonably-Achievable

CPS Clinton Power Station

CR Condition Report

DAW Dry Active Waste

DOT Department of Transportation

EP Emergence Preparedness

ERAT Emergency Reserve Auxilary Transformer

FPER Fire Protection Evaluation Report

HPCS High Pressure Core Spray

HRA High Radiation Area

HVAC Heating Ventilation and Cooling

IMC Inspection Manual Chapter

IR Issue Report

LCO Limited Condition for Operation

LPCS Low Pressure Core Spray

LSA Low Specific Activity

MR Maintenance Rule

MSPI Mitigating System Performance Indicator

NCV Non-Cited Violation

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

OPC Operational Support Center

OSC Operational Support Center

PARS Publicly Available Records

PI Performance Indicator

PMT Post Maintenance Testing

Radwaste Radioactive Waste

RCS Reactor Coolant System

RHR Residual Heat Removal

RP Radiation Protection

RPT Radiation Protection Technician

RWP Radiation Work Permit

SDP Significant Determination Process

SVC Static VAR Compensator

TS Technical Specification

URI Unresolved Item

USAR Updated Safety Analysis Report

WAB Work Around Board

WO Work Order 12 Attachment