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Safety Insp Rept 50-461/85-65 on 851216-860127.No Violation or Deviation Noted.Major Areas Inspected:Const, Preoperational Testing,Operational Preparedness Activities, Employee Concerns & Review of Allegations
	ML20138C495
Person / Time
Site:	Clinton
Issue date:	03/24/1986
From:	Gwynn T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20138C482	List: IR 05000461/1985065; ML20138C477;
References
	50-461-85-65, NUDOCS 8604020511
	Download: ML20138C495 (41)
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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No.'50-461/85065(DRP)

Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Conducted: December 16, 1985, through January 27, 1986 Inspectors: T. P. Gwynn P. L. Hiland D. E. Keating ,

F. J. Jablonski

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ddkland9 * Y Approved By: T. ( nn, Chief / 2 8b Projects Section IB Dat'e /

Inspection Summary Inspection on December 16, 1985, through January 27, 1986 (Report No. 50-461/85065(DRP))

Areas Inspected; Routine safety inspection by resident and regional based inspectors of construction, preoperational testing, and operational preparedness activities including applicant action on previous inspection findings; review of IE Bulletins and Circulais; review of 10 CFR 21 reports; review of a l 10 CFR 50.55(e) report; employee concerns; review of alle0ations; functional or program areas (including site surveillance tours, administrative procedures review, operational staffing, installation of safety related components and structural integrity test /drywell leakage test witnessing and review);

headquarters / regional requests (including drywell vacuum relief valves and i

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s limitorque valve actuators with unqualified wire) and readiness for fuel loading meeting report. The inspection involved 264 inspector-hours onsite by three resident inspectors and one regional based inspector including 22 inspector-hours onsite during off shift Results: Of the areas inspected, 'io violations or deviations were identifie The corrective actions being taken by IP plant staff to address'a previously identified unresolved item were e.pparently not adequate. The unresolved item involved the adequacy of procedure reviews to assure that a workable system of plant procedures was available to control applicable plant staff activities in conformance with requirement The applicant was requested to provide a written response to that unresolved item (see Paragraph 8.b. of this report).

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DETAILS

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. Personnel Contacted Illinois Power Company (IP)

D. Antonelli, Director - Plant Operations

K. Baker, Licensing and Safety (L&S)

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G. Bell, Director, Construction.and Procurement Quality Assurance (QA)

L. Boquist, Control and Instrument Engineer i B. Calhoun, Quality Projects Coordinator, IP QA R. Campbell, Director - Quality Systems and Audits, QA

+* Connell, Manager - QA J. Cook, Assistant Manager - Clinton Power Station (CPS)

E. Corrigan, Director - Quality Engineering and Verification, QA

H. Daniels, Project Manager

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L. Davis, Supervisor, Document Control, Nuclear Support (NS)

i + Edgar, IP Counsel F. Espinoza, Nuclear Services Engineer, Control and Instrumentation (C&I)

S. Fisher, Manager, NS

J. Greene, Manager - Startup (SU)

D. Hall, Vice President, Nuclear D. Holesinger, Director - Startup Test, SU

D. Holtzscher, Director - Safety Analysis, L&S J. Hunsicker,. Supervising Engineer, C&I J. Jones, Supervisor - Mechanical Maintenance E. Kant, Assistant Manager, Nuclear Station Engineering (NSE)

*J. Loomis,' Construction Manager

J. Miller, Director - Startup Programs, SU K. More, Startup Group Lead Engineer

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R. Morgenstern, Director - Plant Technical H. Nodine, Supervisor, C&I

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M. Norris, Supervisor - Testing and Scheduling

J. Palchak, Supervisor - Plant Support Services

J. Perry, Manager - Nuclear Prograe Coordination

+R. Phares, Technical Staff S. Rasor, Supervisor - Construction QA '

S. Richey, Director - Maintenance

+T. Riley, IP, Licensing Project Engineer R. Schaller, Director - Nuclear Training

D. Shelton, Manager - NSE

+F. Spangenberg, Manager .- L&S L. Stifter, Control and Instrumentation Engineer

+ Telthorst, IP, Licensing Engineer D. Tucker, Lead Commitment Control Engineer M. Vandermyde, Nuclear Project Engineer D. Vincent, Startup Lead Program Engineer R. Wenborne, Control and Instrumentation Engineer

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+*J. Wilson, Manager - CPS F. Worrell, Supervisor - Plant Operations

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Baldwin Associates (BA)

J. Brennan, Electrical Field Supervisor M. Daniell, Manager, Technical Services J. Doolin, Supervisor of Training, Quality & Technical Services B. Fraser, NDE Engineer, Level II R. Greer, Manager - Quality and Technical Services E. Rosol, Project Manager

D. Schlatka, Project Manager D. Selva, QA Engineer J. Thompson, Manager - Quality Engineering P. Trenkle, Electrical QC Inspector D. Zimmerman, Electrical QC inspector Soyland/Wipco J. Greenwood, Manager - Power Supply Nuclear Regulatory Commission (NRC)-

+ Black, NRR, Planning and Program Analysis Staff

+ Boehnert, NRC, Advisory Committee Reactor Safeguards Staff

+ Butler, NRC, Division of Boiling Water Reactor Licensing (DBL)

+K. Campe, NRC, DBL, Power Systems Branch

+P.. Gwynn, NRC-RIII, Chief, Projects Section 18

+ Hiland, NRC-RIII, Resident Inspector

+ Hodges, NRC, DBL, Reactor Systems Branch

+ Housfin, NRC, DBL

+ Jablonski, NRC-RIII, Projects Inspector

+ Keating, NRC-RIII, Senior Resident Inspector

+ Lainas, NRC, DBL

+ Scheibelhut, NRC-Argonne National Laboratory

+B. Siegel, NRC, Licensing Project Manager

+M. Srinivasan, NRC, DBL

+D. Vassallo, NRR, DBL, Facilities and Operations Support

+R. Warnick, NRC-RIII, Chief, Reactor Projects Branch 1

Denotes those attending the monthly exit meetin + Denotes those attending a meeting in Bethesda, MD. on January 13, 1986, to discuss readiness for fuel loa See Paragraph 10 of this report for detail The inspectors also contacted others of the construction project and operations staff . Applicant Action On Previous Inspection Findings (92701/92702) (0 pen) Open Item (461/85005-19): Verify that valves in the fire protection water supply system, which are not electrically supervised, are keylocked open and have strict key control procedures and monthly verification of valve positio (Safety Evaluation Report (SER) SER, Paragraph 9.5.1)

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The inspector reviewed CPS No. 9071.19, " Monthly Fire Protection Valve Lineup", Revision 0, ~ dated August 29, 1985. The procedure required for monthly surveillance of fire protection (FP) water supply valve position to demonstrate operability of the FP system.in accordance with the Clinton Power Station (CPS) technical specification The inspector reviewed the results of the monthly surveillance of FP system valves for the month of December 1985. The inspector noted that CPS No. 9071.19 was implemented, and discrepancies'in system lineup were annotated on the valve lineup sheet The. inspector verified by review of drawings and physical observation of system valves that the valves necessary to supply FP water from one-of the diesel driven fire pumps to a fire main located in the auxiliary building were included in the CPS No. 9071.19 valve lineup sheet and were properly positioned. One discrepancy was identified; valve 0FP288 was not ~ included in the valve checklist. The inspector-noted that the valve in question had been installed under a design change in June 1985; that the valve was not identified; had a broken operator window; and i.ad not been painted. The applicant stated that the valve was still under the jurisdiction of IP Startup; that the valve would be included on the checklist as part of the normal system turnover process; and that finishing work was required for the valve prior to turnover which was being tracked by IP. This information was sufficient to satisfy the inspector's concer The inspector requested information related to the controls provided for FP valve lock key The applicant was not able to provide the re_ quested information; there were no plans in place to control the keys for FP valve lock This matter was referred to the cognizant license reviewer in the NRC Office of Nuclear Reactor Regulation. This item remains open pending resolution of the question concerning key contro b. (0 pen) Open Item (461/85005-30): Verify that a corporate management directive has been prepared emphasizing the management responsibility of the shift supervisor and the establishment of a training program-for shift supervisors to meet the guidelines of NUREG-0578 (Three Mile Island (TMI) Item I.C.3).

The inspector reviewed IP Nuclear Policy Statement No. 7, " Supervisory Responsibilities", Revision 0, dated March 13, 1985. That policy statement, which was distributed to all licensed operators and licens candidates, met the quidelines of NUREG-0694, "TMI-Related Requirements for New Operating Licenses".

The inspector reviewed the information provided by the applicant concerning training for shift supervisors to meet the guidelines'of NUREG-0578. The applicant was not able to provide information which demonstrated that the current shift supervisors had been trained to a

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program that met the applicable requirements. This matter was discussed with responsible IP management who stated that action would be taken to resolve this discrepancy. This item remains open pending review of the required training program and verification of performance of the required trainin c. (0 pen) Open Item (461/85005-44): Verify that loose parts monitoring systems (LPMS) are operational prior to fuel loa Review of the CPS SER, NUREG-0653, Paragraph 4.4.1 showed that this open item was stated as follows: "...the applicant will have a loose-parts monitoring system (LPMS) operational at the time of initial reactor startup testing." The CPS draft technical specifications, Paragraph 3.7.7.10 requires that the LPMS be operable in operational conditions 1 & 2. Thus the open item, as originally defined in Inspection Report No. 50-461/85005, was incorrect in that the LPMS is not required to be operational prior to fuel load. The LPMS is required to be operational prior to initial criticalit The inspector reviewed the applicant's information provided to close this item. The information indicated that a surveillance procedure was available to demonstrate the operability of the LPMS for two of three applicable technical specification surveillance requirement The information provided did not address the third surveillance requirement. More importantly, the information provided did not address the operai.ional status of the LPMS to support initial reactor operation. This item remains open pending receipt of additional information from the applican d. (0 pen) Unresolved Item (461/85012-02): Inspection of plant staff administrative control procedures, documented in Inspection Report No. 50-461/85012, identified several deficiencies requiring corrective action. Those deficiencies are summarized as follows:

(1) Several requirements of ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," were not reflected in the plant administrative procedures reviewe (2) Procedure steps tc provide for conformance to the CPS technical specifications were not reflected in the procedures reviewed and were not identified and tracked as missing information ("LATER").

(3) Several requirements of upper tier documents were identified as recommendations ("should") rather than as requirements ("shall").

(4) There were apparent conflicts between procedure requirement (5) Some plant administrative control procedures were misclassified as nonsafety-related in the operating manual status report. This misclassification resulted in the procedure and changes thereto not having required review \-

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Of particular concern was the lack of independent review of plant procedures to which the other deficiencies were attribute In order to corroc't the above deficiencies, the applicant verbally committed to the following:

(1) Perform a review of all procedures with a class code of N (nonsafety-related) or F (nonsafety-related, Facilities Review Group (FRG) review required) to assure that all identified procedures had been properly classified and had received all required reviews; and (2) Perform an independent technical review of specified plant procedures in order to demonstrate compliance with the facility technical speci fications. That review was to be completed and documented prior to fuel loa Monitoring of the above actions by the inspector, documented in Inspection Reports No. 50-461/85045 and 85053, indicated that the applicant was progressing according to a schedule that would support the facility fuel-load dat See Paragraph 8.b. of this inspection repor This matter remains unresolve s e. (Closed) Open Item (461/83010-01): Design verification of electrical raceway syste This matter was previously discussed in Inspection Reports No. 50-461/83010, 83012, and 83014. In report 50-461/83014 it was stated that IP would audit or otherwise review Sargent & Lundy's (S&L)

design process to verify the overall performance of the electrical raceway system; that is, performance would not be comoromised by interaction or cumulative effects creatediby the several deficiencies reported by IP to Region II l l

The inspector reviewed the enclosure to S&L letter to IP, SLS-I-5478, dated December 12, 1985. The enclosure was titled " Interaction Effects of 10 CFR 50.55(e) Issues for Electrical Component Installation," and included discussions about 10 CFR 50.55(e) Reports 80-08, 80-09, 81-05, 82-01, 82-09, 83-05, 83-11, 84-02, and 84-18. Among other things, the S&L report included the engineering basis for disposition and/or corrective actions, an explanation of any impact on design' margin, and possible cumulative effect/ interaction. The review was complete and detailed. The report indicated that all hardware related problems were corrected to minimize or completely remove any impact on the overall design of the electrical raceway system. The inspector agreed with S&L's conclusion that the subject 10 CFR 50.55(e) reports did not exhibit cumulative effects and there were no apparent interactions which would impact on the designed function of the electrical raceway system. Other matters related to problems with materials and components of the electrical raceway system were documented in Inspection Reports No. 50-461/81029, 84028, and 85054. The inspector has no further questions about this ite This matter is close _- __

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. (Closed) Open Item (50-461/84004-01): Cracks in concrete slabs and wall A previous inspection identified visible cracks in the Power Block concrete slab walls and floor One~ vertical crack was identified in the Radwaste Building east wall at 737 level, location G-20 Numerous cracks were identified in the 800 level main turbine floor-emanating from the generator hold down bolts. This matter was referred to the applicant's Quality Assurance (QA) group for study and disposition. 0A was also requested to perform a similar surveillance of the Power Block and to address the subject of acceptability /

rejectability of crack Although the acceptability or rejectability of concrete cracks was not specifically addressed in the Final Safety Analysis Report (FSAR),

there was information in the form of technical papers that provide recommended practices. These were as follows:

(1) ACI-SP-20, "Causes, Mechanisms, and Control of Cracking in Concrete" (2) ACI-224R-80, " Control of. Cracking in Concrete Structures" (3) ACI-SP-30, " Cracking, Deflection and Ultimate Load of Concrete Slab Systems" These three papers specify design factors and parameters to be used for the design of beams and slabs for crack contro The inspector requested that IP provide design calculations for one-way and two-way slabs for review of these factors. A review of the calculations showed that whatever cracking may occur will be within normal code limits as specified for nuclear power plant This item is close (Closed) Open Item (461/85005-06): Verify installation of automatic Reactor Core Isolation Cooling (RCIC) turbine restart on low reactor water level (SER, Paragraphs 5.4.1 and 6.3.2.3).

The inspector reviewed sheets 9 and 12 of Schematic Diagram E02-1RI99 to verify that the RCIC turbine will automatically restart on low reactor _ vessel water level. The inspector also discussed with IP Startup personnel the methods used by them to verify by test that the circuitry changes ware made as documented in Generic Test Procedure (GTP)-40 for drawing E02-1RI99 as part of Preoperational Test Procedure.(PTP) PTP-RI-01. The inspector was satisfied that the required circuitry changes had been made and tested. This item is close (Closed) Open Item (461/85005-07): Verify installation of a time delay relay in the logic of the RCIC system (TMI II.K.3.15, SER Paragraphs 5.4.1 and 7.3.3.3).

The inspector reviewed sheets 11 and 13 of Schematic Diagram E02-1RI99 to verify that a three second time delay relay had been installed in the RCIC steam supply line break detection circuitry to ,

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prevent spurious RCIC system isolation. The inspector also discussed with IP Startup personnel the methods used by them to verify by test-that the circuitry changes were made as documented in GTP-40 for drawing E02-1RI99 as part of PTP-RI-01. The inspector was satisfied that the required circuitry changes had been made and tested. This item is close i. (Closed) Open Item (461/85005-08): Verify that the high drywell pressure interlock on the High Pressure Core Spray (HPCS) injection valve is removed (SER, Paragraph 6.3.2.3).

The inspector reviewed' revisions C and D of schematic diagram E02-1HP99 to verify removal of the drywell high pressure interlock for closure of the HPCS injection valve on reactor vessel high water leve The inspector also discussed with IP Startup personnel the methods used by them to verify by test that the circuitry changes were made as documented on sheets 4 and 5 of GTP-40 for drawing E02-1HP99 as part of PTP-HP-01. The inspector was satisfied that the. required circuitry changes had been made and tested. This item is close j. (Closed) Open Item (461/85005-31): SER, Paragraph 13.1. Review the operating organization when it can be observed functioning in more areas (6 to 9 months prior to fuel load).

At the time the CPS SER (NUREG-0853) was issued in February 1982, CPS staffing was not sufficiently complete to allow the NRC staff to conclude that the applicant met minimum requirements of the Standard Review Plan (SRP). Since the SER was issued, a number of reports delineating the NRC staff review and verification of specific areas in the operating organization have been issued. Inspection Report No. 50-461/85063, Paragraph 7.c., and Paragraph 8.c. of this report, provide the details of NRC staff inspections performed to verify the j applicant's Operational Staffing commitments. These inspections and the reports referenced therein provide the basis for concluding that the applicant's operating organization meets the minimum requirements of the SRP and is in accordance with the FSAR. This item is close k. (Llosed) Open Item (461/85005-40): Verify that modifications have been made to certain balance of plant valves, prior to fuel load, to prevent them from reverting to their normal operating position upon reset of a loss of coolant accicent (LOCA) isolation signal (Supplementary Safety Evaluation Report (SSER) 2, Paragraph 7.3.3.7).

The inspector reviewed constructicn travelers and verified by field observation that the modifications required by (SSER) 2, Paragraph 7.3.3.7 have been completed. The details of this review are discussed in Paragraph 3.d. belo _ _ _ _ _ _ _ _

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Modifications have been made to prevent certain balance of plant valves from reverting to their normal operating position upon reset of a LOCA isolation signal. This item is close . (0 pen) Open item (461/85005-43): Verify that commitments listed in SSER2, Paragraph 9.3.5 are incorporated into the Clinton Core Damage procedure prior to fuel load (TMI Item II.B.3).

The applicant provided information for closure of this ite SSER2, Paragraph 9.3.5.1, subsection (1), required that the applicant maintain a post-accident sampling system (PASS) testing and operator training program that included the following elements:

(1) Is performed on a semiannual basi (2) Consists of obtaining and analyzing reactor coolant, suppression pool, and residual heat removal (RHR) system samples chemically and radiochemically by persons responsible for post-accident procedure (3) Corrects any discrepancies found in the training exercises in a revised procedur The information provided by the applicant was not responsive to the above requirements. The inspector advised the applicant that, in order to provide an adequate basis for closure of this item, the applicant must provide an implementing procedure or instruction, approved by the FRG, which references Technical Specification Requirement 6.8.4.c and which is responsive to the above listed SER requirements. The applicant acknowledged this information.

' SSER2, Paragraph 9.3.5.1, subsection (2), requires that the applicant maintain Clinton specific core damage procedures that include the following:

l (1) Provide means to differentiate between cladding failure and core melt and the degree of each type of core damag (2) Factor in a third core damage category between cladding failure and core melt, namely, fuel overheatin The applicant provided Emergency Plan Implementing Procedure (EPIP)

EC-13, " Reactor Core Damage Estimation", Revisfon 1, dated November 27, l 1985, as basis for closure of this portion of the open item. The inspector reviewed procedure EC-13 and found it to be responsive to the SER requirements. The following procedural discrepancies were oiscussed with the applicant:

(1) The table in Paragraph 1.2 was missing < and > symbols (that is,

<10% vice 10% and > 50% vice 50%).

(2) The procedure did not state when or if Paragraph 4.2 was to be used.

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(3) Paragraph 4.1.7 did not provide guidance for estimating core damage when the normalized I-131 concentration was less than the upper limi (4) Paragraph 4.5 and the record sheet on attachment 12 were not changed when the graph on attachment 13 was change This caused

some confusion when trying to follow the procedur (5) The procedure never required the person implementing the 4 procedure to translate data obtained in terms of % clad failure 1 and % fuel melt to a core damage class and degree for management use.

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a subsequent revision of the procedure.

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This item remains open pending provision of an implementing procedure or instruction, approved by the FRG, which references Technical Specification Requirement 6.8.4.c and which is responsive to the SER requirement (Closed) Violation (461/85042-01): BA Procedures (BAPs) 3.3.1, 3.3.6, and 3.3.14 (Installation instructions for conduit, electrical raceway,

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30d conduit supports, respectively), were not consistent with the requirements of upper tier documents for control.of material traceabilit The requirements of BAP 1.5, " Material Traceability,"

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for QC inspectors to record the presence of a QC accept stamp on cut

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materials may not have been properly implemented as a resul The inspector reviewed corrective actions taken by the applicant as described in BA Corrective Action Request (CAR) 249 dated June 7, 198 BA Quality Engineering evaluation of the hardware condition revealed no hardware impact since all materials available for use were procured as safety-related and had been determined to meet the weldability requirements of AWS D 1.1 (Structural Welding Code). BA made changes to the affected procedures, trained applicable. crafts, and performed an evaluation of nonconformance report dispositions to verify their adequacy. All committed actions were verified complete by BA Quality Engineering on September-27, 198 Records of these actions were on file in the IP Central File In addition, the inspector independently verified that the affected procedures had been revised to address the CAR. This matter is closed.

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No violations or deviations were identifie . Review of IE Bulletins and Circulars (92703) (0 pen) IE Circular 79-12 (461/79012-CC): Potential Diesel Generator Turbocharger Proble l

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IE Circular 79-12 identified a potential problem involving lack of adequate lubrication for General Motors - Electromotive Division,(EMD)

diesel engine turbochargers when restarting a hot engine within 15 minutes to 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months of the last engine run (lube oil temperature > 140 degrees F). .

IP received this Circular on July 2, 1979. EvaluationbyIPindidated that the circular was applicable to the Stewart & Stevenson supplied EMD diesel engines used at CPS to provide an onsite source of emergency electrical power (diesel generators).

This circular was previously reviewed by Region III in Inspection Reports No. 50-461/80004 and 8200 Applicant actions relative to this circular had not been completed at the time of the last inspectio *

The concerns identified in IE Circular 79-12 were stated as follows:

EMD-is currently developing a modification to improve the lube oil syste It is planned that this modification will be available for installation in approximately six month In the interim, the following actions are recommended for those having EMD diesel engines:

(1) Repeated fast hot starts within a minimum 15 minute to 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months time frame after shutdown should be avoided. Allow the engine to cool at least 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months after it has been operated in the " loaded" mode, or otherwise a restart should be performed within 15 minutes of shutdow (2) After changing oil filter elements or draining the accessory oil system for any reason, and upon refilling of the system make sure that the circulating oil pump is in operation for at least 30 minutes and that the strainer box is full before starting the engine. The engine should then be brought to an idling conditicn to assure complete filling of accessories before any subsequent fast start is mad (3) Any small leak at the top of the oil cooler should be correcte A leak at this location allows air to be drawn into the cooler during shutdown, which will cause the drain'back to be more rapi (4) Avoid testing of the redundant diesel engines concurrently. .

Where it is necessary to run the redundant diesels concurrently, maintain one diesel in the running mode for a minimum of three hours following the shutdown of the othe IP actions taken in response to this circular were identified as follows:

(1) CPS Procedure 3506.01, " Diesel Generator and Support Systems,"

Sections 4.14 and 8.1.3.1 have been revised to caution against hot restart . _ . . - .

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(2) CPS Procedures 10P3506.01S, ISP908.01S through .55, and ISP9080.085 have been revised to ensure the diesel generators have been operated or prelubed within the last~ 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months prior to startin (3) No leaks exist at the top of the oil coolers on CPS diesel (4) CPS Procedure 3506.01, " Diesel Generator and Support Systems,"

Section 4.15 has been revised to caution against testing the

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diesel generators concurrently and to maintain one diesel in the running mode for a minimum of three hours following shutdown of the others. The only exception is a ten year operational independence test which is performed in accordance with CPS Procedure 9080.08, " Diesel Generator Operational Independence Verifications."

The inspector noted that the applicant plans to install a modification to the EMD diesel generator lube oil prelube system to address these concern Review of CPS No. 3506.01, revision 1 dated October 25, 1985, verified the actions stated in applicant actions 1. and 4. above had been carried ou The inspector reviewed procedures to verify applicant action 2. as follows:

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CPS No. 3506.01, " Diesel Generator and Support Systems,"

Revision 1, dated October 25, 198 CPS No. ISP9080.015. " Diesel Generator Operability Manual,"

Revision 0, dated July 10, 1980 (TCF 85-295).

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CPS No. 9080.02, " Diesel Generator 1C Operability Manual,"

Revision 20, dated January 10, 198 CPS No. 1SP9080.035, " Diesel Generator Operability - ECCS,"

Revision 0, dated May 29, 1981 (TCF 85-275).

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CPS No. 1SP9080.045, " Diesel Generator Auto Load / Reject Verification Test," Revision 0, dated December 31, 1980 (TCF 85-276).

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CPS No. 1SP9080.055, " Diesel Generator 24 Hour Operability Checks Division I," Revision 0, dated June 9, 1981 (TCF 85-277).

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CPS No. 1SP9080.08S, " Diesel Generator Operational Independence Verification," Revision 0, dated April 14, 1981 (TCF 85-278).

The inspector found that, for the procedures reviewed, temporary change forms (TCFs) had been issued to implement the stated actio However, CPS No. 9080.02 had been recently revised and the stated

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action included in the TCF had not been incorporated. The inspector requested that the applicant clarify this matter and assure that the other TCFs were incorporated in subsequent procedure revision Applicant actions in item 3 above were not specifically addressed in the records provided to the inspector for revie The inspector requested that the applicant provide objective evidence that the Division I, II, and III diesel engines had been inspected for oil leaks in the top of the engine oil cooler Tho applicant's actions did not specifically address concern #2 of the circular; however, records were provided which indicated that applicable maintenance procedures were scheduled to be revised to address the. concern of the circular. Review of CPS No. 8207.02,

" Emergency Diesel Maintenance," .evision 1, dated November 26, 1985, and CPS No. 8207.01, "8000 Hour Diesel Engine Inspection (Division I, II, and III)," Revision 0, dated June 22, 1984, showed that CPS No. 8207.02 had been revised to address the circular but CPS 8207.01 had no This circular remains open pending clarification of the status of CPS 9080.02; pending assurance that the other TCFs will be incorporated, if required; pending receipt of objective evidence supporting applicant action 3. above; and pending revision of CPS No. 8207.01 to address the circula b. (Closed) IE Circular 79-05 (461/79005-CC): Moisture Leakage In Stranded Wire Conductor IP requested S&L to review IE Circular 79-05 in April and May of 198 The inspector reviewed S&L's response to IP in letter SLBI-17563 dated May 21, 1985. S&L reviewed design documents applicable to terminations at penetrations, splices, junction boxes, terminal blocks, motors, solenoid valves, limit switches, instruments and other equipment penetrated by conduits. IP reviewed BA installation procedures in reference to the S&L letter and concluded that problems with moisture leakage in stranded wire conductors would be preclude The actions recommended in IE Circular 79-05 have been complete IE Circular 79-05 is close c. (Closed) IE Bulletin 79-23 (461/79023-BB): Potential Failure of Emergency Diesel Generator Field Exciter Transforme IE Bulletin 79-23 identified certain deficiencies in the wiring of emergency diesel generator field exciter transformers that could result in failure of tne diesel generator after continuous operation at rated load for a period of approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months . The bulletin required the applicant to determine if the specific deficiency was applicable to CPS, and to provide a schedule for testing of emergency diesel generators or completed test results meeting the bulletin requirements. Testing was required to demonstrate full load carrying

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capability for an interval of not less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , of which 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months was to be at a load equivalent to the continuous rating of the diesel generator and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at a load equivalent to the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months rating of the diesel generator. .The test was also to verify that voltage and frequency requirements were maintained and that the cooling system functioned within design limit This bulletin was previously reviewed in Inspection Reports No. 50-461/80011,'81001, and 8401 Those reports verified that the applicant had received the bulletin, had reviewed it for applicability, and had provided a response within the time frame required by the bulleti The applicant had preoperational test procedures which met the testing requirements of the bulletin. The inspector reviewed the following preoperational test sections:

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PTP-DG/00-01, " Division I Diesel Generator and Fuel Oil,"

Revision 0, dated August 20, 1985; Paragraphs 7.2.1 through 7.2.2 PTP-DG/D0-02, " Division II Diesel Generator and Fuel Oil,"

Revision 0, dated September 20, 1985; Paragraphs 7.2.1 through 7.2.2 PTP-DG/D0-03, " Division III Diesel Generator and Fuel Oil,"

Revision 0, dated July 2, 1985; paragraphs 7.2.1 through 7.2.2 This review showed that the preoperational test procedures for all CPS emergency diesel generators complied with the requirements of the bulleti Test results were .,ot available for the Division I and II diesel generators at the time of this revie The inspector requested copies of selected portions of the Division III diesel generator test results and verified that the test was conducted as committed. Test results had been reviewed by the applicant and were acceptabl Results of the Division I & II diesel generator preoperational tests are scheduled for review by Region III under thel routine inspection progra This bulletin is close d. (Closed) IE Bulletin 80-06 (461/80006-BB): Engineered Safety Feature (ESF) Reset Controls. IE Bulletin 80-06 identified circumstances where automatic reset of an ESF actuation signal that is, without operator action, would cause certain equipment to return to its normal operating condition and compromise protective actions taken in affected system At the time IE Bulletin 80-06 was issued, the applicant was a construction permit holder and as such a written response was not I required. However, the NRC staff (see Paragraph 2.k. above) asked the applicant to review the electrical schematic / control circuit diagrams for all safety-related equipment to determine whether or not, upon

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s reset of an ESF actuation signal, this equipment would remain in its emergency mod Inspection Report No. 50-461/84-19, Paragraph 2.e.,

documented the results of the applicant's review and commitments to modify the control circuitr The inspector verified that the modifications committed to by the applicant were completed for both the nuclear steam supply system (NSSS) and balance of plant (80P) system valves as follows:

RCIC The applicant committed to revise the control circuitry fc.' the RCIC inboard isolation valve E51-F063, and outboard isolation valve E51-FC64. The inspector reviewed construction travelers (WA-E21A-XX-025 and WA-E21A-XX-018) and confirmed, by direct observation, that the hand switches (IE51A-51 and IE51A-S2) -in the control room had been modified. Operator action was required to reopen.these valves after the reset of a RCIC system isolation signa Nuclear Steam Supply Shutoff System / Nuclear Boiler System The applicant committed to modify the circuitry for RHR sample line valves E12-F050A, B, and E12-F075A, B and reactor water sample valves 833-F019 and B33-F020. The inspector reviewed Field Deviation Disposition Request (FDDR) LHI-1227 and LHI-1612 which were the controlling construction documents to remove and reinstall control room panels H13-P661, H13-P662, H13-P663, and H13-P66 These control room panels were sent to the General Electric Company, San Jose, California facility for required modifications which included the control circuitry abov The inspector reviewed the control circuitry design drawing E02-INB99 sheets 201 and 227 which identified the seal-in circuit required for the circuit modificatio The inspector verified by direct observation, that the required seal-in circuit card was installed in control room panel P-662, circuit card location C-A16-A113. Operator action after reset was required for these valves to reope BOP Systems

- The applicant committed to modify a total of 28 valves in the Component Cooling (CC) and Process Sampling (PS) systems to provide a seal-in on a LOCA signal. In addition, four valves in'the Containment Combustible Gas Control (HG) system were committed to' be modified to seal-in with the HG system in either normal or tes The required modifications were verified by the inspector to have been completed by review of the following closed construction travelers:

(1) CC Valves: Traveler H13-F4574 incorporated Field Engineering Change Notice (FECN) 4574 which provided seal-in logic for valves 1CC071, ICC072, ICC073, and ICC07 . .

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(2) PS Valves: Traveler H13-4765 incorporated Engineering Change Notice (ECN) 4765 which provided seal-in logic for valves IPS003, IPS004, IPS005, IPS009, IPS010, IPS016, IPS017, IPS022, IPSG31, IPS032, IPS034, IPS035, IPS037, IPS038, IPSO 43A, IPS0438, IPSO 44A, IPSO 448, IPSO 47, IPSO 48, IPS055, IPS056, IPS069, and IPS07 (3) HG Valves: Traveler H13-5298 incorporated ECN 5298 which revised the wiring scheme to prevent 'IHG001, IHG004, IHG008 from reopening after a LOCA signal has been cleared if valve switches are in test positio The design changes committed to by the applicant and confirmed in the SER have been performed. IE Bulletin 80006-BB is close (Closed) IE Bulletin 84-03 (461/84003-88): Refueling Cavity Water Sea This bulletin notified all power reactor licensees and construction permit holders of an incident in which the refueling cavity water seal failed and rapidly drained the refueling cavity at an operating reactor plant. This bulletin requested certain actions be taken to assure that fuel uncovery during refueling remains an unlikely even Inspection of this bulletin response (see Inspection Report No. 50-461/85012, paragraph 3.a) identified that certain information was missing from the applicant's original response to the bulleti The applicant provided additional information in response to the bulletin on June 5, 1985. Review of this bulletin response, with the additional information, showed that the applicant had received and evaluated the information included in the bulletin and had responded to all applicable portions of the bulletin. Based on their evaluation, the applicant concluded that the gross failure of the CPS refueling bellows (a stainless steel design equivalent to the rubber boot seals described in the bulletin) was a highly unlikely event and that

' adequate plant procedures were provided to detect and mitigate the potential consequences of a refueling bellows failure. The inspector observed that the procedures in place would provide for detection and mitigation of any failure which could result in draining of the containment upper pools. This information provided an adequate basis

.for closure of this bulleti . Review of 10 CFR 21 Reports (92716) (Closed) 10 CFR 21 Report (461/82001-PP): Ventilation fan housings supplied by Buffalo Forge Co. did not provide protection for adjacent safety-related equipment from internally generated missile ~

This matter was previously reviewed in Inspection Report No. 50-461/85046, Paragraph 2., open item 461/85005-3 During that inspection the inspector found that the applicant's corrective actions were satisfactory to resnive the open' item and the 10 CFR 21 repor This matter is close . , -. - - -

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. (Closed) 10 CFR 21 Report (461/82012-PP): Cell cracks ir. Model KC-11 batterie Although this item was included in the Region III Tracking System, it had never been reported to the NRC by the vendor or applican This item has been determined to be not reportable. This matter is close (Closed) 10 CFR 21 Report (461/82012-PP): STS Cable pin Although this item was included in the Region III Tracking System, it had never been reported to the NRC bv the vendor or applican This item has k en determined to be not reportable. This matter is close . Review of 10 CFR 50.55(e) Report (92700)

(Closed) 50.55(e) Item (461/84002-EE): Material traceability. This matter was initially reported to the NRC as a potentially reportable construction deficiency on January 11, 1984. On July 9, 1985, IP reported that, based on their completed review of the subject, a. reportable deficiency did not exis No significant conditions adverse to the safety of operations were identifie Problems related to material traceability have been documented in Inspection Reports No. 50-461/81003, 83010, 83014, 83019, and 8501 Item 461/84002-EE was reported based on a combination of problems documented in various audit, deviation, nonconformance, and corrective action report The problems reported include areas where the requirements for material traceability were unclear or in question. Areas affected were identified as follows:

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Structural shapes and plates for electrical supports

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ASME subsection NF-2 and 3 components supports

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Strut and strut fittings for electrical and instrument supports

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Hilti anchor bolts

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Unmarked bolts

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Field fabricated cable finger assemblies

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Washers and shim stock i Corrective actions taken by the applicant included one or more of the <

following items: )

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Initiation of a corrective action report

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Develop and implement a sampling program

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Revise procedures

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Provide training

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Future procurement as safety related

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Test material

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Revise specifications

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Purge site of non-traceable items i

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Q Inspection Report No. 50-461/85015 documented.that current measures to identify and control materials used in construction at CPS were adequate, sample plans met the intent of Military Standard (MIL-STD)-414 requirements, ano analysis of chemical test results showed that no weldability problems i existe Based on that report and a review of IP interoffice memorandum Y-32325 and

'the data referenced therein, the inspector agreed with IP's conclusion that no significant conditions adverse to safety were identified; therefore, a reportable deficiency did not exist. This matter is close . Employee Concerns (99014)

The inspectors reviewed concerns expressed by site personnel from time to time throughout the inspection period. Those concerns related to regulated activities were documented by the inspectors and submitted to Region II Two concerns were transmitted to the regional office during this report perio . Review Of Allegations (99014)

i (Closed) Allegations (RIII-85-A-0196-02 thru -07/#174-02 thru -07): :

An individual alleged a number of conditions existed in a Field ;

Document Control (FDC) station that were not in accordance with site procedures. One additional concern (Concern #1, RIII-85-A-0196-01)

was reviewed and the results documented in Inspection Report No. 50/461-85063, Paragraph 6.d. The remaining specific concerns expressed were as follows: i Concern # 2

" Approved for Construction" stick drawings were being checked out of field document control center FDC3 by construction crafts for longer than the previously accepted three work days. This could allow

" approved for construction" drawings to be out in the field when a r'equired change notice goes into effec NRC Review The in;r 'm. reviewed the appropriate BA project procedures used at the CPS for document control. The governing procedure, BAP 2.0, Revision 14, " Document Control," delineated responsibilities for the receipt, distribution and traceability of controlled documents and revisions. Field Document Control station "FDC3" was. located in the l Diesel Generator Building. Electricians were the primary users of j FDC The inspector interviewed the FDC3 supervisor, seven Stone and Webster (S&W) electricians, four BA electricians, and three BA electrical-crew foremen to determine the actual practice for checking out stick drawings from FDC3. While not a precedural requirement, the inspector l determined through these interviews that the users were instructed to j return stick drawings in their possession at the close of business on )

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Wednesday and_ Friday of each wee Stick drawings checked out on Saturday or Sunday were to be returned at the close of business on the day of checkou Control of revisions to drawings was proceduralized in BAP 2.0, Paragraph 5.4.1.c, which required recipients of document transmittals to " return to the Document Control Center within ten working days, a signed copy of the transmittal in accordance with the transmittal instructions". Paragraph 5.4.3 required a " Followup No. 1" request to be forwarded to recipients of document transmittals who fail to process the applicable documents. Paragraph 5.4.3 further stated

" Follow-Up No. 1 transmittals not returned to the Document Control Center within five working days will be forwarded to the Manager of Document Control for resolution within ten calendar days". As noted above, the approved project procedure for document control allowed a total of 15 " wor.kdays" for document changes to be processed by the recipients. At the end of this 15 " workday" allowance, the Document Control Manager was responsible for resolution within ten calendar day The inspector interviewed the acting BA Document Control Manager in order to ascertain the status of outstanding document transmittal The site Document Control Center (DCC) maintained a suspense file of

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document transmittals which the inspector reviewed with the Document Control Manager. The inspector concluded that the site DCC was complying with the requirements of BAP 2.0, Revision 14, Document Control, Paragraphs 5.4.1.c and 5.4.3 as evidenced by review of the suspense file for outstanding document transmittal In November 1985, a Clinton SAFETEAM investigator identified a concern (12416-B) that addressed a backlog of change document transmittals at FDC One of the root causes for this backlog, as stated in the SAFETEAM report, was that " drawings are not always returned after the three day check out to allow updating". Corrective action was taken in response to this SAFETEAM concern and the backlog of document change transmittals was reduced to an acceptable level by increased man hours devoted to FDC The inspector reviewed the backlog of document transmittals at FDC3 on two occasions during this report period. The inspector noted a reasonable backlog of 10 to 15 transmittals, none of which was past the initial 10 workday process time allowed by BAP 2.0, Paragraph 5.4. Results

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The allegation that " Approved for Construction" stick drawings were being checked out of FDC3 for longer than the accepted three days was substantiated. However, as delineated in BAP 2.0, recipients of change documents had 15 workdays before the Manager of Document Control was required to resolve (within 10 calendar days) failures to process applicable document _ _ _ _ .__ _ ._ - . _ - _ - - -

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It was noted that Clinton SAFETEAM Concern #12416-B stated that failure to return drawings after the three day checkout was a contributing factor to a large number of document transmittals being backlogged in November 1985. That backlog has since been correcte Limiting the checkout time to " Approved for Construction" stick drawings to three days was-not a procedural requirement. The procedurally imposed requirement for a recipient of change documents to incorporate changes with 15 workdays was being accoaplished. The inspector verified by review of the site.DCC suspense file that-document change transmittals were being' handled in accordance with site approved procedure The problem had been identified to the licensee and correcte The inspector's review indicated that the corrective action was acceptabl This matter is close No violations or deviations were identifie Concern #3 Electricians don't realize that drawings reproduced on green paper are for reference only; they use them in the field for construction purpose NRC Review The inspector reviewed BAP 2.0 Paragraph 5.2.g, Exception 2, which stated that " Drawings reproduced on green paper shall not be used for i

construction / inspection purposes."

The inspector interviewed six S&W electricians, four BA electricians, and four electrical crew foremen to ascertain their level of under-standing on the use of " green drawings". -These interviews were conducted at the worksite in order for the inspector to witness actual .

use of construction drawings. All the personnel interviewed had an accurate understanding of the procedural requirements. In each case, the interviewee stated that only drawings stamped " Approved for Construction"-were to be used in the actual construction of electrical item The interviewees acknowledged, and the inspector confirmed through direct observation, that " green drawings" were used by electricians when performing nonsafety related construction activities and there

was no evidence to suggest that they were being issued and u.ed for safety-related construction activitie The inspector observed electricians using " green drawings" to install nonsafety-related lighting circuit . ..--. - - .- . .-- _. _ ..

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Results This allegation was partially substantiate Electricians were using

" green drawings" in the field; however, the usage was limited _to nonsafety-related activitie The inspector concluded through interviews with electricians and observation of actual work practices that electricians working at the CPS were aware that " green drawings" were to be used for reference only. See Concerns #6 and #7 for further discussion on " green drawings." This item is close No violations or deviations were identifie Concern #4 BA DCC was not maintaining Field Document Control Center.FDC3. This would be evident if an audit of FDC3 were performe NRC Review The inspector conducted an unannounced inspection at FDC3 during this report period. The purpose of the inspection was to ascertain if the

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BA site DCC was maintaining F3C3.at an acceptable leve The inspector randomly selected a representative sample of 26 drawings being maintained at FDC3. The drawings selected were stamped

" Approved for Construction". The drawings selected were representa-tive of detailed design drawings used in construction of structures, systems, and components in the Containment Building, Fuel Building, Auxiliary Building, Diesel Building, and Control Buildin For the drawings selected, the inspector noted the actual revision at FDC3 and current design change postings annotated on the FDC3 drawin The inspector requested site DCC to identify the current revision and required design change postings for each of the drawings selecte With the inspector present, site DCC identified, through their computer terminal, the current revision and dasign change postings for each'of the drawings selected by the inspector. No discrepancies were identifie The inspector noted that an extensive review of work done by Field Document Control technicians had been performed by IPQA in response to document control problems identified in Inspection Report

. No. 50-461/85063. That review was documented by IPQA in Surveillance Report #CQ-01701 dated December 12, 1985. That surveillance report provided additional information relevant to the quality of work

performed by BA Field Document Ccntrol stations in that only a small number of posting discrepancies were identified based on a very large

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i sample population. This inspection confirmed the results of the IPQA surveillanc _ _ _ - - . _ . _ _- ._ ._. _ ...-._ _ _ - ___ _ _ - _ .

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Results The allegation was not substantiate This item is close No violations or deviations were identifie Concern #5 An activity which was believed to be a SAFETEAM audit of FDC3, undertaken in response to a concern, was inadequate as the investigator only selected one drawing at the FDC3 reproduction satellite sta' ion to revie NRC Review The inspector contacted the SAFETEAM director and requested an interview with the SAFETEAM investigator (s) that had performed any activities at the FDC3 reproduction satellite station. The FDC3 reproduction satellite station was located in the Diesel Generator Building, one elevation below the FDC3 statio The purpose of the FDC3 satellite station was to provide "information only" copies of design change documents (ECNs, FCRs, NCRs, etc.) and "information only" copies of drawings from aperture card file 'One SAFETEAM. investigator was interviewed by the inspector to determine if a SAFETEAM audit of FDC3 reproduction satellite station had taken place. The SAFETEAM investigator stated that during the investigation of concern #12416, a brief review of activities conducted at the FDC3 reproduction satellite station was performe The SAFETEAM investigator stated that an " Audit" was never planned or-performed by SAFETEAM at the FDC3 reproduction satellite station. The SAFETEAM investigation was focused on a concern regarding the capabilities of a Field Document Control superviso The inspector reviewed the SAFETEAM investigation file on concerns

12416-A and #12416-B and concluded that an " Audit" of FDC3 reproduction satellite station was not planned or performed. The SAFETEAM investigator did identify a backlog at the reproduction office in the filing of aperture cards transmitted to that satellite station. The backlog was corrected by assigning two people to the reproduction offic The inspector conducted three unannounced inspections of the FDC3 reproduction satellite station during this report perio For each inspection, the' inspector observed the activities of the Field Document Control technician on duty and conducted interviews to determine the purpose of that satellite statio The inspector noted during each inspection that the Field Document Control technician was aware of the "information only" (not to be used for inspection /

construction) status of documents distributed from the FDC3 reproduction satellite station and that procedures were being adequately followe ,

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Results This allegation was not substantiated. The SAFETEAM did not conduct an audit of the FDC3 reproduction satellite station nor was there any apparent reason to do.so. The FDC3 reproduction satellite station distributes "information only" documents. This item is close No violations or deviations were identifie Concer'n #6 Aperture cards being used at the Field Document Control station FDC3 were not stamped correctly (that is safety-related, for construction only, or for reference only).

NRC Review The inspector reviewed BA procedure BAP 2.0, Revision 14, " Document Control," and conducted an unannounced inspection of Field Document Control station FDC The inspector reviewed the existing files at the FDC3 reproduction satellite station and noted that some aperture cards were stamped

" safety-related" and some did not have any stampings. The inspector's review of BAP 2.0, did not identify any procedural requirement for stamping aperture cards under the control of BA Document Control. The inspector noted that the. aperture cards at the FDC3 reproduction satellite station were being used to produce "information only" prints for site personne The status of the print was defined by either stamping "For Reference Only" on the copy or by use of " green paper" as previously discussed above in Concern #3. If a drawing was safety-related, this annotation appeared in the title block in the printed copy of the aperture car BAP 2.0, Paragraph 5.2.g.3 stated that " Aperture cards shall be issued "For Reference Only"." The inspector noted that aperture cards under the control of PA Document Control, if issued in accordance with site procedures, should be identified "For Reference Only". Based on conversations with cognizant personnel the inspector determined that no requests had ever been made for issuance of aperture card The inspector noted that FDC3 reproduction satellite station did not

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issue aperture cards. The aperture cards on file at this station were used to reproduce "Information Only" drawing Results This allegation was substantiated; however, the fact that the aperture cards themselves were not stamped was of no significance. It was the responsibility of the Field Document Control technicians to identify, in accordance with approved procedures, the status of-drawings reproduced from aperture cards when issued at the Field Document Control station. This item is close , ,. - _ . _ _ _ _ . _ _ _ _ _ . . . _ ._ _ . _ _

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No violations or deviations were identifie Concern #7 Craft were using from drawings reproduced from the above (Concern #6)

3per.ture cards to perform work in the fiel NRC Review The inspector determined that the drawings produced from aperture 3 cards were the same " green paper" drawings discussed above in Concern # Results As identified in Concern #3 above, this allegation was partially substantiated that is, reference only " green drawings" were being used to perform work in the field; however, it was determined that the use of " Reference Only" drawings during installation of nonsafety-related hardware, such as lighting, does not have any safety significance. This item is close No violations or deviations were identifie (Closed) Allegation (RIII-85-A-0184, #172): Intimidation of QC

^ inspectors at Clinton by use of Daily Inspection Report Lo Concern

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Afraid that the Daily Inspection Report Log could be used against inspectors when compiling a lay-off list;

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Production placed ahead of quality;

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Misuse of Daily Inspection Report Log,-for example, in legal matters such as Department of Labor hearing NRC Review It has been previously established and verified in Inspection Report No. 50-461/85046 that the primary purpose of the Daily Inspection Report Log (Log) is to track daily QC inspection activities and provide management with trends of individual and group performance to determine overall department capabilitie Note: In inspection Report No. 50-461/85046 the Daily Inspection Report Log is referred to as the Quality Control Daily Repor The Log is described in BA memorandum JRM-85-144, dated October 26, 1985. Management of personnel is usually based on results of performanc If any person, including a QC inspector, chronically or habitually performs below the established norm then management must take corrective action, including termination or layoff if necessar The Log can also be used as a reference if an inspector's work is suspect of an impropriet .

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There were no specific references made by the allegers about how quality was sacrificed in favor of productio As.previously stated, similar allegations were reviewed in Inspection Report 50-461/85046; the allegations pertaining to the Daily Inspection Report. Log were not substantiated. The allegations do not state there was any evidence that the individuals were unwilling to raise safety issues or identify-nonconforming conditions, or that the individuals were discharged or otherwise discriminated against with respect to compensation, terms, conditions, or privileges of emp1cyraent as stated in Section 210 of the Energy Reorganization Act. It appeared from the review that the primary concern was certain individuals were afraid the Daily inspection P.; port Log could be used to establish layoff list There was no evidence to suggest that the Log was used to place productio ahead of qualit It should be noted that all documents used in the construction of the Clinton Power Station have the potential of being used in a judicial hearing; therefore, the use of the Log in a Department of Labor

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proceeding does not appear to be inappropriat Resul ts It is concluded that the primary concern with the Daily Inspection Report Log information is that it could be used by their management for the stated purposes as well as establishing layoff lists; however, no regulatory requirements prohibit such management actions unless it

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would intimidate an individual to not raise safety issues or identify nonconforming condition Discrimination, ac defined by the Energy Reorganization Act, did not occur and there was no evidence that production was being substituted for quality. No further NRC action will be taken. This matter is close No violations or deviations were identifie (Closed) Allegation (RIII-85-A-0183, #168): Improper certification of BA QC Electrical Inspector Concern #1 The person making the allegations named three BA QC electrical Level II inspectors who were certified without having prior inspection experience. The person stated that tnere were five to six other inspectors who did not have prior inspection experience; however, the

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person would not name the NRC Review Requirements for QC inspectors are delineated in Section 5 of the BA QC Training and Qualifications Manual. The manual includes the same inspector qualifications, that is, minimum personnel capabilities, education, and experience levels, as ANSI N45.2.6-1978, " Qualifications of Inspection Examination and Testing Personnel for Nuclear Power Plants". Capabilities for QC inspectors are verified by written examination and satisfactory completion of specified practical factor .

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Education and previous work experience are verified by BA by telephone contact with previous employers and schools. As stated in the manual, education and experience requirements can be met in one of four ways. Three of the sour ways include the phrase "related experience in equivalent inspection, examination, or testing activities". The selection of this wording allows the user of ANSI N45.2.6 to identify and assess the relevance and equivalence of previous experience compared to the user's needs. . This is necessary since no two persons have identical backgrounds or directly related experienc One of the identified QC inspectors' qualifications were previously reviewed as documented in Inspection Report 50-461/8403 The individual was listed as Inspector "E" in Paragraph 4. of that repor The NRC inspection resulted in Open Item No. 461/84032-02 That open item was satisfactorily closed in Inspection Report No. 50-461/85041 where it was documented that the individual was qualified as a Level II QC electrical inspecto The inspector reviewed the certification records for the other two identified QC inspectors. The records showed that both of the QC inspectors had extensive backgrounds in electrical construction, including electrical QC inspection experience. Although one of the QC inspectors appeared "more qualified" than the other, both of them met the requirements as previously state The inspector randomly selected six other QC inspector certification records for review. The records showed a wide range of "related experience". As a result, some of the QC inspectors had " limited certification", and others were only certified in one or two of the six possible classification In all cases, the QC inspectors appeared to be properly certified for the type of inspections indicated in the recor Results The allegation could not be substantiate In all cases reviewed by the inspector, the QC inspectors were properly certified based on the level of education and prior r~ elated experienc No violations or deviations were identifie Concern #2 The person making the allegations stated he had heard that one of the identified BA QC inspectors was given a copy of the written test with answers prior to taking the written portion of the QC electrical Level II examination. The person said that this was common knowledge among the QC inspection staf .

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NRC Review The inspector interviewed IP and BA supervisory personnel and electrical QC inspectors, including the individual identified as being given the written test with answers, and reviewed the available documentation of the inciden The inspector interviewed individuals A and B on January 21,.198 Individual A stated that he did not have any knowledge of the incident described in the above allegation. The inspector was told by individual B that sometime during mid-1984, on the night shift, while looking for a pencil in individual C's desk, an unidentified person found what appeared to be handwritten questions and answers to the Level II QC electrical examination. Individual B believed this matter was made known to someone in BA managemen The inspector interviewed individual C on January 22, 1986. The inspector was told by individual C that when first reporting to the CPS, one of his assignments was preparing questions for QC inspector examinations. After preparing 17 questions for an upcoming Level II QC Electrical Equipment Inspector examination, individual C stated that he felt uneasy about the assignment because he was not certified as a Level II inspector and there was potential for him to be so certifie Individual C stated that during the middle of May 1984, he notified his supervisor who agreed with individual C about his concern. The inspector determined that the task of preparing QC electrical inspector test questions was assigned to individual D who was a qualified Level II QC electrical inspector in all six possible classifications including electrical equipmen Individual C stated that he gave the 17 questions to individual D to use as individual D saw fit. Individual C stated that he was transferred to a new work location during this same time frame. Individual C stated that his personal effects were removed from his desk by laborers and relocated to the new work location. On June 22, 1984, individual C stated that he and others were administered the examination for Level II QC Electrical Equipment Inspector; individual C received a passing grad On or about June 24, 1984, an unknown individual found the 17 questions in individual C's desk drawe Individual C stated that this matter was looked into by his supervisor, and to remove any doubt about the examination results, all persons who were tested on June 22, 1984, were retested; again, individual C received a passing grad According to a memorandum which was attached to BA Interoffice Memorandum BAQC-CV-25, hand written by individual D, on or about May 18, 1984, individual D prepared questions for an upcoming Level II QC Electrical Equipment Inspector examination while working in an area where he was not rcrmally assigned. After proof reading the questions he placed them into a drawer of the desk he was temporarily using, which coincideatly belonged to individual C. According to individual D's memoreadum, the contents of the desk were subsequently removed and transferird to a different field offic .

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The inspector also discussed this matter with the BA Supervisor of Training for Quality and Technical Services. The BA supervisor told the inspector that this matter was reviewed by BA management as described in BA Interoffice Memorandum BAQC-CV-25, dated June 25, 1984. A review of the memorandum by the inspector confirmed that individual C's desk drawer did contain 17 questions, 12 of which were included in the examination administered on June 22, 1984; however, the memorandum also confirmed that BA management was convinced cheating did not occur and individual C did not know the questions were in his desk drawer. BA management's conclusions were based on verbal information provided by individual C and substantiated by individual D in his hand written memorandum. The memorandum also showed that BA recognized a weakness in control of examination According to memorandum BAQC-CV-25, all personnel who were tested on June 22, 1984, would be retested to a completely revised examinatio Personnel records reviewed by the inspector indicated that individual C successfully passed the new examination in July 198 The inspector discussed this matter with the IP Director of Quality Systems and Audits who stated to the inspector that IP did not perform a formal investigation into this matter; however, they did monitor BA's actions end reviewed BA's conclusions. The inspector reviewed a Memorandum to File, dated January 23, 1986, wherein IP documented its conclusion that "there was no impact on the quality program at CPS as a result of the test questions being found in the desk at the field QC office".

Based on numerous NRC inspection in the area of BA QC inspector certifications the above incident appears to be isolate Past NRC inspections have shown that BA's methods and procedures meet pertinent requirement Results Based on the above review of documents and interviews, the allegation was not substantiated. However, a QC inspector identified as the individual given a copy of the written test prior to taking the written portion of the QC electrical Level II examination, had prepared 17 questions for future Level II QC Electrical Equipment examination and 12 of those questions subsequently appeared on the tes The identified individual and all other persons who were tested on June 22, 1984, were reteste This matter is close Note: BA recognized a weakness in control of QC test preparation and corrective actions were taken to improve test securit No violations or deviations weta identifie Concern #3 The person making the allegation stated he had heard that a copy of the written test for QC electrical Level II inspector was removed from a QC inspector's desk 11/2 years ago and given to an unidentified NRC inspector who apparently did nothing about it.-

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NRC Review This concern appears to be based on hearsay information in that the person making the allegation did not have any first hand knowledge of-the incident. There is no record of this incident in the Region III file, and discussion in Region III did not disclose any information about this matte Results This matter will be referred to the appropriate NRC Office for revie ~

No violations or deviations were identifie (Closed) Allegation (RIII-85-A-0190, #175): Illinois Power

supervisors within the Nuclear Station Engineering Department (NSED)

Control and Instrumentation (C&I) data sheet review group emphasized quantity over quality; they deviated from and diluted the established guidelines; and reviewers were denied access to computer NRC Review As stated by the individual when originally reporting this allegation to the NRC, examples of diluting and deviating from established " guidelines" included not typing-notes from telephone calls to vendors, and not including library documents w' i data sheet packages. The inspector determined that ther no regulatory or IP procedural requirement to perfor .er tas The individual had contacted the SAFETEAM and pr :ed the NRC with the SAFETEAM report numbe The inspector reviet the SAFETEAM report and determined that it correctly stated 1 -urpose of the IP NSED C&I data sheet review group; that is, to 'acifically add more detailed information to instrument data sheets for calibration of nonsafety-related, non-augmented D; and non-fire protection instruments. As such, NRC does not have jurisdiction over these matters. However, interviews were conducted with five members of the IP NSED C&I' data sheet review group including the supervising engineer, the lead reviewer, and three reviewers. Based on those interviews the following information was obtained:

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The purpose of the IP NSED C&I data sheet review group was to provide complete calibration information to the field in order to support startu Information such as device manufacturer, model number, range, set point, and accuracy was obtained in several different ways including field inspection of the device, review of catalogues and instruction books, and telephone contact with the manufacturer. The IP NSED C&I data sheet review group was exclusively responsible for nonsafety related devices. General Electric Company and S&L were responsible for providing calibration data for safety-related device _ _ - . _ . . _ _ _ -_ _ _ _ __ _ _

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The review started September 4, 1985, and was completed December 31, 1985. The task included the review of about 10,000 devices and was accomplished by nine contract employees. Three of the contract employees were still under contract to I From the onset, reviewers understood that overtime would be required to complete the task on tim ~

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The lead reviewer was characterized by the three reviewers and the supervising engineer as technically competent with more than 15 years experience as an engineer. The lead reviewer was characterized by two reviewers as not having very good interpersonal relationships although the pressure of.the task at hand could have been a contributing facto Even though the IP NSED C&I data sheet review group task was of relatively short duration, there were personnel actions including the termination of two reviewers. According to two reviewers, the lead reviewer, and the supervising engineer one of the terminated reviewers had poor work habits and the other was characterized as being less productive than the other reviewers because of his pre-occupation with over attention to detai According to-two reviewers and the supervising engineer the latter individual's personality was in conflict with the lead reviewe None of the persons interviewed felt that either of the terminated individuals was unfairly terminate Reviewers were allowed access to computers, for example, mistakes or changes were documented on Field Engineering Change Notices (FECN) which were cross checked with other FECNs by use of a-compute Every. person interviewed expressed the basic principle that production of an inaccurate data sheet strictly for production sake would have been counter productive and that a complete and accurate instrument data sheet was key to completing startup activities.

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Results The allegation could not be substantiated in that there was no direct evidence to suggest that supervision was emphasizing quantity over quality or that they deviated or diluted the established guidelines. Interviews with reviewers and other reviews indicated that the review task had a known time limit and it's associateo'

pressure; that the group was small and everyone had to carry their load; that certain extras such as typing notes and copying reference material was not justified; and that since the information assembled was being directly applied to field startup activities, it would be counter productive not to provide accurate information. This matter is close No violations or deviations were identifie , -- - - - -. .. - _ _ -. --- _ _ .

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8. Functional or Program Areas Inspected Site Surveillance Tours (71302)

At periodic intervals during the report period, surveillance tours of selected areas of the site were performed. Those surveillances were intended to assess: . cleanliness of the site; storage and maintenance conditions of equipment and material being used in site construction; i potential for fire or other hazards which might have a deleterious effect on personnel or equipment; storage conditions of new fuel; and to witness construction, maintenance, and preoperational testing activities.in progres The inspector witnessed portions of safety-related welding activities performed by the plant staf Plant staff welders were working to an approved Maintenance Work Request (MWR) to perform Plant Modification

LP- The inspector noted that the work being performed was in accordance with the Weld History Report (WHR) available at the workplace; weld rod used was per the WHR requirements; unused weld rod was properly stored in an energized rod caddy; and QC holdpoints were properly annotate The inspector witnessed initial performance of the Division-2 diesel generator preoperacional test procedure (PTP-DG/00-02, Revision 0).

The inspector verified that the prerequisite steps identified in Paragraphs 7.3.1, 7.3.2, and 7.3.3 of the' procedure were signed off before commencement of the tes The inspector toured the Division-2 diesel generator room with the applicant's Start-Up (SU) test engineer just prior to diesel start and noted that the test engineer was aware of the pre-test conditions and was knowledgeable of the test procedur The inspector witnessed plant staff electricians conducting motor operated valve analysis and test system (M0 VATS) testing on motor operated valve ISX074A. The testing was conducted in accordance with approved MWR-824271. The current revision to the M0 VATS test procedure (CPS No.-8451.02, Revision 1) was at the workplace and being followed. Wire or component removal log (CPS No. 8801.01F001) was at the workplace and properly complete The-inspector identified and brought to the applicant's attention one safety-related cable (cable IRH68K) that was cut or broken in tw The applicant documented the identified deficiency on NCR

39913 to provide for corrective action. The subject cable was one of three cables that exited their respective conduits and was routed three to four feet off the floor directly across a normal construction walkway in the containment. The inspector noted that routine construction traffic through this walkway could easily cause the noted damag .No violations or deviations were identifie , - .-

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. Administrative Procedures Review (42400)'(35744)

This inspection continued a review (see Inspection Reports No. 50-461/85005, Paragraph 9, 85012, . Paragraph 5, and 85063,

Paragraph 8.b.) of procedures to be used during the plant operations phase. The purpose of the review was to confirm that the scope of the plant procedures system is adequate to control safety related i plant operations within applicable regulatory requirements, and to verify.the adequacy of management controls in implementing and maintaining c workable procedure system. See paragraph 2.d. of this report for relevant background informatio (1) Procedures Reviewed (a) CPS No. 1003.01, " Design Control and Modification,"

Revision (b) CPS No. 1003.01, " Design Control and Modification,"

Revision 5, dated January 14, 198 (2) Discussion CPS No. 1003.01, Revision 4., was selected for review because it was subject to unresolved item (461/85012-02) and because it was obviously deficient on its surface. The Corporate NJclear Procedures, which were the basis for the applicant's design control and modification program, had undergone substantive changes in October 1985. CPS 1003.01, revision 4, had not been revised at that time. Discrepancies noted in the procedure, other than the lack of required review, included the following:

i (a) The procedure did not incorporate all ANSI N18.7-1976 requirement (b) The procedure did not provide for compliance to applicable technical specification requirement (c) The procedure did not reflect the current organizational structure and responsibilities defined in the corporate nuclear procedures and interfacing plant staff procedure (d) Interfaces between organizational units were not clearly establishe (e) Requirements of the Code of Federal Regulations were either not. reflected in the procedure or were identified as recommendations of the procedure. The missing information was not identified with "LATER".

The inspector met with cognizant applicant personnel on January 8, 1986, to discuss the above review result The applicant's representatives stated that revision 5 to CPS No. 1003.01 was pending review and approval by the FRG at the time of the meeting. A copy of

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the draft procedure. revision was presented to the' inspector who briefly reviewed it with the applicant's representative The revised procedure was obviously a substantial improvement over the previous revision. As a result of this preliminary review, one question related to compliance to 10 CFR 50.59 was left unresolved. The applicant's representatives agreed to respond to the unresolved item prior to January 27, 198 The inspector subsequently performed a detailed' review of several sections.of revision 5 to CPS 1003.01 which had been approved for use on January 14, 1986. That review indicated continuing problems in establishing compliance to ANSI N18.7-1976, Paragraph 5.2.15, CPS Technical Specifications 6.5.1.6.d., 6.5.1.7.a. and b., and 10 CFR 50.59. Of particular concern was the use of the word "should" where a requirement ("shall") was needed; the processing of "=:Wited" plant and minor modification requests which bypassed several technical specification requirements and at least one ANSI-requirement; and the use of a modification package classification of " safety-related" or

"nonsafety" as the sole criteria for determining if a safety evaluation was required in accordance with 10 CFR 50.59 (the inspector noted that a "nonsafety" modification could affect nuclear safety and that the CPS technical specifications require that the FRG review all proposed changes or modifications to unit systems and equipment that affect nuclear safety).

The above review results were discussed with the applicant's representative and cognizant management personnel on January 24, 198 At that meeting, the applicant's representative indicated a clear understanding of the nature and substance of the above review result The inspector stated that, at the time of issuance of the operating license (when the plant technical specifications and 10 CFR 50.59 become binding requirements), the applicant could be in violation of the referenced requirements if the identified deficiencies have not been corrected. The inspector clearly identified that only a portion of the procedure had been reviewed. In addition, the inspector stated that the types of discrepancies identified during this review were similar in scope to earlier findings which were the basis for unresolved item (461/85012-02). Resolution of the above discrepancies will be reviewed prior to issuance of the operating license under the-previously identified unresolved ite Revision 5 to CPS 1003.01 had been subject to an independent technical review which was the applicant's committed corrective action under unresolved item (461/85012-02). The procedural deficiencies identified above had not been identified and corrected by that independent review process. This failure indicated the need for management attention to assure the adequacy of corrective actions to address unresolved item 461/85012-02 (that is procedural reviews being currently performed by plant staff). This matter was discussed with the Manager, CPS on January 9, 1986, and again on January 27, 1386. A written response to the unresolved item was requeste One unresolved item was confirme .

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c. Operational Staffing (36301)

This inspection continued a review isee Inspect'on Report No. 50-461/85063, Paragraph 7.c.) to verify _that the applicant's current operational staffing plar. fas in accordance with the FSAR and proposed Technical Specificatic.is; that staff positions were filled; and that staff qualifications were adequate for their designated assignments.

. This inspection included licensed and unlicensed plant operators,

technicians, electricians, and Shift Technical Advisor (STA) staf (1) Documentation Reviewed (a) IPC Nuclear Organization Staffing Plan, Revision 7, dated August 30, 198 (b) CPS Organization Chart (IP Memo SBF-0366-85), dated November 1, 198 (c) CPS No. 1302.04, " Shift Technical Advisor Training,"

Revision 0, dated December 27, 1985.

. (d) CPS No. 1402, "Non-licensed Training," Revision 3, dated November 30, 198 (e) CPS No. 0AP1502.03N, " Personnel Qualifications for Maintenance Activities," Revision 2, dated July 16, 198 (f) FSAR, Chapter 13, " Conduct of Operations," Amendment 35,

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dated October 198 (2) Discussion /Results (a) The inspector interviewed the applicant's Control and Instrumentation (C&I) Maintenance Supervisor and the applicant's Electrical Maintenance Supervisor to ascertain current C&I/ Electrical maintenance capabilities. The inspector noted that all positions in.the C&I and electrical departments were filled. .The qualification matrices (Appendix A to CPS No. 0AP1502.03N) available in the C&I and electrical offices provided documented evidence of the training programs provided to maintenance personnel ir. both of these groups. Review of the matrices and discussion with the C&I supervisor and the electrical supervisor indicated that a continuing program of both general and specialized training was-provided. This information was adequate to demonstrate that sufficient numbers of qualified C&I-maintenance personnel and electrical maintenance personnel were.available to support routine maintenance tasks during operation of CP e

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(b) The inspector interviewed the applicant's Supervisor - Plant Operations to ascertain current licensed and non-licensed operator staffing. The " normal" shift crew for the CPS was delineated in the FSAR, Paragraph 13.1.2.3. The applicant committed to provide a minimum of five operating shift c.ew . Review and discussion of the current qualification status of Auxiliary Operator and 'Jnit Attendant positions (non-licensed) with the Supervisor-Plant Operations indicated that a sufficient number of non-licensed personnel were available to fill the five operating shift crew reouirements. The inspector noted that due to ongoing construction activities some of the practical factors prescribed in qualification checklists (CPS No. 1402.02C002, C003, C004) for the non-licensed

. operators had been waived. The inspector also noted that non-licensed training was a prerequisite to being license The Supervisor - Plant Operations indicatd that an on going training program (CPS No. 1402.02F005) was in place to upgrade non-licensed training as systems become available to plant staf The inspector will verify the implementatin of required trairing prior to fuel loa This is an open item (50-461/85065-01).

- The inspector noted that a sufficient number of licensed personnel were currently filling all the i positions required to support five operating shift However, at the time of thi_s inspection, the final examination results were not available. This resulted in some personnel, currently assigned shift duties, being in a SRO/R0 license " candidate" status at the conclusion of this i.nspection period. The inspector will verify.that each operating shift.is manned by a sufficient number of licensed personnel prior to fuel load. This is an open item (50-461/85065-02).

(c) The inspector interviewed the applicant's Director - P %nt Technical to ascertain the current status of the STf, training and qualification progra At the time of the inspection, seven individuals were in the final stages of qualifying STA in accordance with the applicant's procedure (CPS No. 1302.04, STA Training).

The inspector noted that a sufficient number of personnel were participating in the STA training program to support the five " normal" operating shift crews. However, at the conclusion of the inspection pe'riod, verification of STA qualification was not completed. The inspector will verify that operating shifts are manned by qualified STAS prior to fuel load. This is an open item (50-461/85065-03).

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No violations or deviations were identifie Installation of Safety Related Components (MSRV) (50073C)

This is a continuation of an inspection documented in Inspection Report No. 50-461/85063. The inspector observed the installation of four Main Steam Relief Valves (MSRV) and repair work on two valve The inspector observed installation of the following four valves:

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Serial No. 160779, MPL IP21-F047A

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Serial No. 160783, MPL 1821-F051B

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Serial No. 160780, MPL~1821-F047B l

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Serial No. 160536, MPL 1821-F0418 The. inspector observed machining operations on the following two valves:

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Serial No. 160538, MPL 1821-F041C

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Serial -No. 160535, MPL 1821-F041A The repair method.(machining) used on these valves was different than (

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that indicated in the referenced inspection report. General Electri had reevaluated the initial nonconformance report (NCR) disposition and determined that certain flanges on ten of the affected valves should be machined rather than stoned. ~The machining observed on the two valves referenced above was done on the inlet flanges. NCRs 38071 and 38446, written by IP, and NCRs 39782 and 39811, written by BA~ to identify the adverse conditions, were reviewed by the' inspector. The i inspector also reviewed BA travelers B21-088 and 093, which provided l instructions for the installation work to be performe The observations and reviews performed showed that control of these l activities was maintained through QC sign-offs at required hold point No violations or deviations were identifie e. Structural Integrity Test and Drywell Leakage Test (63050B)

This inspection was performed to ascertain that the CPS containment structural integrity test and drywell leakage test ~(PTP-SIT-01) was performed consistent with regulatory rcquirements, applicable national '

standards, and applicant commitments contained in the CPS FSA This inspection consisted of a detailed review of the applicable test procedure; independent verification of selected test prerequisites; participation in a pre-test walkdow'n inspection of the CPS drywell; verification of instrumentation installation, checkout, and calibration; direct observation of test setup, test crew performance, and independent verification of data acquisition; interviews of cognizent test personnel to ascertain their level of knowledge and familiarity with test requirements and expected test results; and review-of preliminary test results to verify their validit : . .. ,

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(1) Documentation Reviewed (a) PTP-SIT-01, "Drywell Structural Integrity Test," Revision 1, dated December 12, 198 (b) Drawing SK-ILRT, " Location of Dewcells and RTDs," Revision A (c) Drawing SK-FPR-6586, "As Built Locations of LVDTs for SIT and Attachment Details,"

Revision A, sheets 1 and 2 (d) Drawing W249-77418-C-SIT-1, " Embedded Strain Gauge Locations," Revision 3 (e) Drawing E27-1301, " Embedded Strain Gauge Instrumentation Conduit Layout," Revision G j (2). Procedure Review The inspector performed a-detailed review of PTP-SIT-01. The procedure was reviewed with respect to the applicable requirements of the CPS FSAR, ANSI /ANS 56.8-1981, " Containment System Leakage Testing Requirements," and applicable regulatory requirement The inspector determined that the procedure was consistent with all applicable requirements reviewe (3) Test Witnessing

, The inspector observed the conduct of a pre-test walkdown by f

cognizant test personnel, accompanied the test director during the walkdown, and discussed walkdown results with the test director. Several minor deficiencies identified during the walkdown were corrected-prior to start of the tes The inspector selected a sample of test prerequisites and verified that they were met. Prerequisites verified included the placement of certain instrumentation; observation of instrumentation checkout and calibration procedures; location of selected concrete crack mapping grids, strain gauges, dewcells, RTDs, and LVDTs; and the establishment and maintenance of access

! control to the CPS drywell. The inspector noted that the j

E instruments checked were located in accordance with applicable drawings; that the instruments had been checked and calibrated using appropriately qualifi.ed personnel; that concrete crack i mapping preparations were appropriate and in compliance with l

. applicable drawing requirements; and that strict access controls I had been established and were maintained throughout the tes Instrument locations that deviated from applicable requirements due to physical interferences had been properly documented and identified on "as built" instrumentation location drawing The grids for concrete crack mapping were handled in the same manne O

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Interviews with cognizant test personnel and observation of test crew performance indicated that the personnel were knowledgeable of the test procedure, test program requirements, and applicable code requirements. Test crew actions were timely, coordinated, and reflected a thorough understanding of the evolutions in progress. Unanticipated problems that occurred during the test performance were handled quickly and properly by the test cre Data was recorded accurately by cognizant personnel on the data sheets provide Concrete mapping crews plotted and recorded concrete cracks in excess of 0.04 inches in width that were greater than 6 inches in length. Independent data recorded by the inspector was consistent with data recorded by the test cre (4) Test Results Review Review of preliminary test results indicated that the CPS containment had performed as expected; that the drywell leakage rate was well within the acceptance criteria established by the architect engineer; and that no significant concrete cracking had occurred during performance of the tes (5) Results Based on these reviews and observations, no violations or deviations were identifie . Headquarters / Regional Requests (92701) Drywell Vacuum Relief Valves The NRC Cffice of Inspection & Enforcement (IE) requested that the inspector notify the applicant of a construction deficiency reported by Perry Nuclear Power Plant (PNPP) under the requirements of 10 CFR 50.55(e) and determine if the deficiency was also applicable to CP The deficiency was related to the actuation logic for the drywell vacuum relief valves (PNPP) Construction Deficiency Report 50-440 RDC 141 (85).

The inspector forwarded the request to cognizant applicant representatives who reviewed the matter with respect to'the CPS drywell vacuum relief valve design. The applicant reported that the CPS design did not use actuation logic and that the PNPP deficiency did not apply to CPS. The inspector reviewed S&L drawing M5-1063,

" Combustible Gas Control System," Revision G, and verified that the drywell vacuum breakers were self-actuating; there was no actuation logic involved in the CPS design. This information was provided verbally to I o

. Limitorque Valve Actuators With Unqualified Wire Region III requested that the inspector notify the applicant of a generic deficiency reported by Commonwealth Edison Co. under the requirements of 10 CFR 21 and determine if the deficiency was applicable to CPS. The deficiency related to the use of unqualified wire in environmentally qualified limitorque valve actuators (LER 304/85018).

The inspector forwarded the request to cognizant applicant representatives who began a review of the matter with respect to the CPS environmental qualification program. This matter was still under review at the conclusion of this inspectio The applicant stated that their review was scheduled for completion by January 31, 1986. This matter will be reviewed further by the inspector when the applicant's review is complete This is an open item (461/85065-04).

1 CPS Readiness For Fuel Load Meeting (30702)

A meeting was held in the NRC Offices in Bethesda, Maryland on January 13, 1986, between NRC Region III, NRR representatives, and IP management to discuss the readiness of CPS for fuel load. Attendees at the meeting are denoted by a (+) in Paragraph 1 of this' repor The applicant provided a briefing for the attendees which addressed the following topics:

(1) CPS " Readiness To Load Fuel" Letter

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(2) SER And I&E Issues Status (3) FSAR Certification (4) Site Wide Statusing System (5) Construction And Testing Status (6) Specific Arras Of Regulatory Interest (7) Power Ascension Program Acceleration (PAPA) Program Questions and answers were discussed during the meetin Region III observed that IP anticipated having a large number of deferrals which was not consistent with Region III polic This matter will be discussed further during a future meetin . Open Items (92701)

Open items are matter that have discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC, applicant, or both. Open items disclosed during this inspection are discussed in Paragraphs 8.c. and e

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T . Exit Meetings (30703) '

The inspectors met with applicant representatives (denoted in Paragraph 1)

throughout the inspection and at the conclusion of-the. inspection on January.27, 1986. The inspectors summarized the scope and findings of the inspection activities. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The applicant did not identify any such documents / processes as proprietar .The applicant acknowledged the inspection finding '

The resident inspectors attended exit meetings held between Region III and/or headquarters based inspectors and the applicant as follows:

Inspector (s)

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Date Hare 1/9/86 Love- 1/16/86 Ulie 1/24/86

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v t e Inspection Report - Clinton - 1985065
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1985 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 17(0) 25(0) 28(0) 29(0) 30(0) 31(0) 32(0) 33(0) 34(0) 35(0) 36(0) 37(0) 38(0) 39(0) 40(0) 41(0) 42(0) 43(0) 44(0) 45(0) 46(0) 47(0) 48(0) 49(0) 50(0) 51(0) 52(0) 53(0) 54(0) 55(0) 56(0) 57(0) 58(0) 59(0) 60(0) 61(0) 62(0) 63(0) 64(0) 65(0) Security Operator Exams Emergency Planning Other

IR 05000461/1985065

Text

REGION III

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