IR 05000461/2009007

IR 05000461-09-007; on 03/30/2009 - 04/17/2009; Clinton Power Station; Identification and Resolution of Problems

ML091410068
Person / Time
Site:	Clinton
Issue date:	05/20/2009
From:	Ring M NRC/RGN-III/DRP/B1
To:	Pardee C Exelon Generation Co
References
FOIA/PA-2010-0209 IR-09-007
Download: ML091410068 (29)

Text

May 20, 2009

SUBJECT:

CLINTON POWER STATION NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000461/2009007

Dear Mr. Pardee:

On April 17, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Clinton Power Station. The enclosed inspection report documents the inspection results, which were discussed on April 17, 2009, with Mr. Kearney and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission=s rules and regulations and with the conditions of your license.

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

Bases on the results of this inspection, no findings of significance were identified. On the basis of the samples selected for review, the team concluded that, in general, problems were properly identified, evaluated, and corrected.

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

Sincerely,

/RA/

Mark A. Ring, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62 Enclosure: Inspection Report 05000461/2009-007 w/Attachment: Supplemental Information cc w/encl: Site Vice President - Clinton Power Station Plant Manager - Clinton Power Station Manager Regulatory Assurance - Clinton Power Station Senior Vice President - Midwest Operations Senior Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director - Licensing and Regulatory Affairs Manager Licensing - Clinton, Dresden and Quad Cities Associate General Counsel Document Control Desk - Licensing Assistant Attorney General J. Klinger, State Liaison Officer, Illinois Emergency Management Agency Chairman, Illinois Commerce Commission

SUMMARY OF FINDINGS

IR 05000461/2009007; 03/30/2009 - 04/17/2009; Clinton Power Station; Identification and

Resolution of Problems.

This inspection was conducted with region-based inspectors, the NRC Resident Inspector at the Clinton Power Station and the onsite Illinois Emergency Management Agency (IEMA) inspector.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Identification and Resolution of Problems The inspectors concluded that the implementation of the corrective action program (CAP) at Clinton was generally good. The licensee had a low threshold for identifying station problems and entering them into the CAP. In addition, the station was effective at incorporating operating experience (OE) reports into the CAP. The inspectors determined that issues were generally effectively screened and prioritized in a timely manner using established criteria based on plant risk and uncertainty. Causal evaluations sampled were generally of sufficient depth, considered extent of condition, generic issues, and previous occurrences. CAP assignments were generally completed in a timely and accurate manner. The team noted that station effectiveness reviews, audits, and self-assessment were generally thorough and effective at identifying unrecognized weaknesses. The inspectors concluded that station employees appeared to be willing to express safety concerns through established processes and a healthy safety conscious work environment (SCWE) existed at the station.

NRC-Identified

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

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

.1 Assessment of the Corrective Action Program (CAP) Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures and processes that describe Exelons CAP at Clinton Power Station to ensure, in part, that the station had an adequate program for meeting 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requirements.

Exelon entered identified problems for evaluation and resolution into the CAP by initiating action requests (ARs) via a computer based system. The ARs were subsequently screened by the station for operability and reportability, categorized by significance, and assigned for further evaluation and/or corrective action. The issue priority was determined largely in part by the issues specific risk significance and uncertainty. Action Requests were also tracked to identify adverse trends and repetitive issues. Plant staff and management were interviewed to determine their understanding of and involvement with the CAP. The inspectors observed and evaluated the effectiveness of CAP meetings such as the Station Oversight Committee (SOC) and Management Review Committee (MRC).

The inspectors reviewed selected ARs across the seven cornerstones of safety in the NRCs Reactor Oversight Process (ROP) to determine if site personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution. The inspectors selected items from functional areas that included emergency preparedness (EP), engineering, maintenance, operations, physical security, radiation safety, and oversight programs to ensure that Exelon appropriately addressed problems identified in these functional areas. The inspectors selected a risk-informed sample of ARs that had been issued since the last NRC biennial Problem Identification and Resolution (PI&R) inspection conducted in March 2007. The inspectors considered risk insights from the stations risk analyses to focus the sample selection and plant tours on risk-significant systems and components. Inspection samples focused on, but were not limited to, these systems. In addition, the inspectors conducted system walk downs and interviewed station personnel to ensure apparent and known issues were being entered into the CAP.

The inspectors selected a sample of causal evaluations for review based on issues identified within the CAP. This sample included the full range of Exelon causal evaluations (i.e., root cause evaluations (RCE), apparent cause evaluations (ACE),equipment apparent cause evaluations (EACE), and quick human performance investigations (QHPI).) In addition to these causal evaluations, the inspectors also reviewed a selected sample of common cause evaluations (CCEs) to evaluate the stations ability to identify and eliminate the most prevalent cause of a continuing problem.

The inspectors reviewed CAP assignments associated with selected ARs to determine whether the corrective actions addressed the identified causes of the problems. The inspectors reviewed selected ARs to verify that adverse trends and repetitive problems were being effectively addressed in a broader sense. The inspectors assessed the stations timeliness in implementing corrective actions and effectiveness in precluding the reoccurrence for significant conditions adverse to quality (SCAQ). The inspectors also reviewed ARs associated with selected violations (VIOs), non-cited violations (NCVs), and findings (FINs) to determine whether the station properly evaluated and resolved the issues.

Items from processes other then the CAP were selected by the inspectors to verify that the issues were appropriately considered for entry into the CAP. Specifically, the inspectors reviewed a sample of engineering change requests (ECRs), operator workarounds, operability evaluations, work orders, work requests, and system health reports. The inspectors also reviewed completed work packages to determine if issues identified during the performance of corrective, elective, and preventative maintenance were appropriately entered into the CAP. In addition, the inspectors reviewed operator and security logs to determine whether problems described in the logs were entered into the CAP. The inspectors further reviewed the backlog of elective and corrective actions in maintenance, engineering, and operations to determine, individually and collectively, if there was an increased risk due to delays implementing the corrective actions. As part of the backlog review, the inspectors reviewed the stations process for removing work items that had been characterized as elective.

The inspectors also conducted an expanded five year review of selected ARs associated with the service water and high pressure core spray (HPCS) systems. These systems were selected, in part, due to their relatively high individual risk achievement worth and potential aging related vulnerabilities (i.e., erosion of piping, degradation of safety-related raw water systems, aging of electronic components, etc.). In addition to this AR review, the inspectors conducted system walk downs and interviewed key station personnel to determine if problems were being entered into the CAP and were being properly addressed.

The inspectors conducted a targeted review to evaluate the completion and effectiveness of the stations corrective actions taken to address weaknesses identified during the 2007 NRC 95001 supplemental inspection involving a White violation related to a HPCS vortexing issue (CLINTON POWER STATION NRC SUPPLEMENTAL INSPECTION REPORT NO. 05000461/2007009, ML072710132). The inspection was conducted to provide assurance that the root causes and contributing causes of the events resulting in the White finding were understood, to independently assess the extent of condition, and to provide assurance that the corrective actions for risk significant performance issues were sufficient to address the root causes and contributing causes, and to prevent recurrence.

The ARs and other documents reviewed, as well as key personnel contacted, are listed in the Attachment to this report.

b. Assessment

(1) Identification of Issues The inspectors concluded that, in general, the station continued to identify issues at a low threshold by entering them into the CAP. The inspectors determined that the station was appropriately screening both NRC and industry OE at an appropriate level and entering identified issues into the CAP when applicable to the station. The inspectors determined that although a number of security related ARs had been written by security officers, a number of security officers did not have training or did not have adequate training to utilize the stations computer based CAP process. The inspectors determined that although no related regulatory requirement existed, the station could strengthen this area of the CAP by ensuring all station personnel had an adequate working knowledge of entering issues into the CAP. The inspectors determined that this observation was not a significant concern since the security officers interviewed stated that they would be willing to voice issues to their management and/or ask another employee to write the AR for them.

The inspectors determined that the MRC CAP meeting was generally thorough and maintained a high standard for approving action. The inspectors noted that it was not uncommon for the MRC to change an AR priority, add or modify AR assignments, require that the SOC provide additional information to operability and reportability comments, and ask for issue clarification from the SOC. The inspectors determined that these examples represented MRC strengths and areas that could be improved upon by the SOC.

The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances were previous corrective actions were ineffective or were inappropriately closed. The inspectors noted one exception, in that, nine ARs had been written over the past two years related to issues identified with protected equipment postings. Of these ARs, two ARs were level 5 improvements, four ARs were posting errors, and three ARs were posting inconsistencies. The inspectors determined that these issues had not been reviewed collectively to determine if an adverse trend existed.

The licensee entered this observation into the CAP for further evaluation (AR 00908324).

The inspectors determined that the station was generally effective at identifying the cause(s) of abnormal station parameters, however, did note one exception. As of the end of this inspection (April 17, 2009), the station had not identified the cause(s) of an unexplained minor temperature rise in the auxiliary building steam tunnel. This temperature rise was initially discovered on January 8, 2009. The inspectors determined that the station had placed a high priority and applied significance resources on identifying the cause(s). The inspectors determined that although the cause(s) had not been determined, the station had implemented and maintained an interim compensatory measure to periodically monitor the steam tunnel temperature. This compensatory action was implemented to identify a worsening trend to provide ample time for the station to take action prior to the condition significantly worsening.

The inspectors determined that the weaknesses identified in NRC supplemental inspection report IR 05000461/2007009 had been properly addressed through the stations CAP.

(2) Prioritization and Evaluation of Issues The inspectors concluded that the station was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem.

However, the inspectors noted two issues that had been inappropriately assigned a low 5/D enhancement significance level. In accordance with station procedures, these issues should have been assigned a higher significance level since the individual issues required the station to address regulatory requirements or challenges in meeting regulatory requirements. The stations 5/D enhancement significance level is reserved for station improvements and therefore generally has a lower priority for corrective actions and a lower threshold for deleting the issue(s) from the CAP. The team determined that these issues were minor, in part, because they had been corrected in a reasonable time frame despite their assigned significance and priority level. In addition, these performance deficiencies were not reflective of current performance since they occurred in the 2005 timeframe. The licensee entered this issue into the CAP, (AR 00920113).

• AR 00267337 identified that a controlled drawing was inaccurate since it had mislabeled a safety-related current transformer associated with the HPCS system. 10 CFR 50 Appendix B, Criterion III, Design Control, requires, in part, that this type of quality document accurately reflect the design.

• AR 00351291 identified that the scale of an installed pressure gauge was inadequate to ensure that an in-service test (IST) differential pressure range could accurately be read by an operator to ensure that the safety-related service water pumps had adequate performance.

The team determined that the station was generally effective at evaluating equipment functionality requirements after a degraded or non-conforming issue was identified with one exception. The team determined that the station had not evaluated how a previously identified degraded B reactor recirculation pump seal would perform during transient events (i.e., loss of seal cooling, reactor scram, station black out, etc.) The inspectors concluded that the station had been effective at evaluating and monitoring the seals condition under steady state conditions and had appropriately set a seal pressure limit in which an orderly down power or shutdown would commence. The inspectors determined that this evaluation, alone, was not adequate since the station could not readily ensure the inspectors that an unexpected seal failure and resultant loss of coolant accident (LOCA) would occur from the spectrum of license based transient events. Ultimately, the inspectors determined that the failure to perform this type of functionality evaluation was a minor issue since the station was able to provide the inspectors confidence that the redundant seal would operate adequately until an orderly shutdown and cool down would be completed in the case the degraded seal unexpectedly failed during a transient event.

The team determined that causal analyses generally considered extent of condition, generic issues, and previous occurrences with one exception. Specifically, a CCE related to six separate on-site badging issues and fifty eight issues corporate wide did not identify any common causes. Based on the teams review, the inspectors determined that this common cause lacked rigor in evaluating higher level common causes such as personnel responsibility, training, and awareness.

(3) Effectiveness of Corrective Action The team concluded that corrective actions for identified deficiencies were typically timely and adequately implemented. The team concluded that sampled corrective actions assignments for selected NRC documented violations were timely but not effective in one instance. Specifically, over the course of the past two years, the NRC had identified three NCVs associated with transient combustible free-zones and related issues. These issues were categorized as conditions adverse to quality (CAQ) within the stations CAP. Corrective actions such as, painting these areas consistently throughout the plant to avoid potential confusion and system walk downs to ensure legacy issues had been identified, did not prevent additional related NRC-identified NCVs.

The team concluded that, in general, administrative controls had been effective at ensuring that corrective actions were completed as scheduled and reviews were performed to ensure that actions were implemented as intended.

For SCAQs, the inspectors determined that the stations corrective actions designed to prevent a reoccurrence (i.e., CAPRs) were generally comprehensive, thorough, and successful.

The team concluded that corrective actions to address all weaknesses identified in the September 2007 NRC 95001 supplemental inspection to address a White violation associated with a HPCS vortexing issue were adequate (CLINTON POWER STATION NRC SUPPLEMENTAL INSPECTION REPORT NO. 05000/2007009, ML072710132).

The team concluded that the station had been effective at maintaining the corrective maintenance system backlog at a relatively low number (i.e., nine). The team determined that the stations elective maintenance backlog had been relatively constant over the past five years (i.e., 2000-3000 items). The station noted and questioned the binning of a degraded B reactor recirculation pump seal given its degraded characterization, heightened station awareness, and declining trend. The inspectors verified that the station had current plans to replace this seal during their next refueling outage.

Findings No findings of significance were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys OE program.

Specifically, the inspectors reviewed implementing OE program procedures, attended CA program meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were effective and timely implemented.

A list of the documents reviewed is included in the Attachment to this report.

b. Assessment The inspectors concluded that the station appropriately considered industry and NRC OE information for applicability, and used the information for corrective and preventative actions to identify and prevent similar issues. The inspectors assessed that OE was appropriately applied and lessons learned were communicated and incorporated into plant operations.

Findings No findings of significance were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected focused area self-assessments (FASA), check-in self assessments, root cause effectiveness reviews, and Nuclear Oversight (NOS) audits.

The inspectors evaluated whether these audits and self-assessments were being effectively managed, were adequately covering the subject areas, and were properly capturing identified issues in the CAP. In addition, the inspectors also interviewed licensee staff regarding the implementation of the audit and self-assessment programs.

A list of the documents reviewed is included in the Attachment to this report.

b. Assessment The inspectors concluded that self-assessments, NOS audits, and other assessments were typically critical, thorough, and effective at identifying issues. The inspectors concluded that these audits and self-assessments were generally completed in a methodical manner by personnel knowledgeable in the subject area. Corrective actions associated with the identified issues were implemented commensurate with their safety significance.

The inspectors concluded that, in general, effectiveness reviews were conducted in-depth to ensure that corrective actions were effective for significant issues. One exception was noted and is described below. In addition, the inspectors identified one process weakness in conducting effectiveness reviews. Specifically, the inspectors identified that the stations effectiveness review process did not require an effectiveness review to be performed on interim corrective actions. Rather, the scope of the effectiveness review is limited to the effectiveness of assigned and completed final corrective actions. Therefore, the timeframe between an issue (e.g., an SCAQ) and the completion of the final corrective actions is not reviewed to evaluate the effectiveness of any interim corrective actions. This timeframe could be up to several months depending on the time taken to conduct the appropriate causal evaluation, and approve and implement the final corrective action(s). The inspectors noted a vulnerability to this process is that this review would therefore not identify inadequate interim corrective actions that could be utilized from a lessons-learned perspective or used to identify existing weaknesses in the finalized corrective actions.

• The inspectors identified that the station did not conduct an adequate collective effectiveness review related to an SCAQ described in NCV 2008-02-07, Failure to Barricade and Lock a Locked High Radiation Area and AR 00726499.

The inspectors identified three specific issues:

o The station determined that the root cause related to this NCV was a failure to enforce fleet and industry posting requirements by radiation protection (RP) management. The station determined that this root cause had resulted in inadequate posting standards and a lack of sensitivity to radiological controls. According to station procedure LS-AA-125-1004, Revision 4, Effectiveness Review Manual, the purpose of a collective effectiveness review is to determine whether the associated CAs or CAPRs eliminated the cause or reduced the recurrence rate to an acceptable level. The collective effectiveness review focused narrowly on recurrence rate since the completion date of the CAPRs and not on elimination of the root cause.

o Additionally, step 4.1.2 of this procedure states that these reviews should analyze and document satisfactory implementation of CAP and Exelon Nuclear Event Report (NER) fleet-wide actions and their affect on the overall fleet intent of the original action. This was not performed for (NER) LS-08-006, LaSalle County Station Secured High Radiation Area Found not Posted/Controlled.

o Lastly, step 4.2.4 of this procedure states that the effectiveness review should, evaluate each action individually, and then evaluate the broader scope of the CAPRs to determine whether the actions were collectively effective in correcting the issue. . . The broader scope evaluation was not performed.

Based on these issues, the inspectors determined that this effectiveness review did not follow the stations effectiveness review procedural requirements. Therefore, the inspectors concluded that this effectiveness review was incomplete, and therefore inadequate. The inspectors determined that these discrepancies were individually and collectively a minor issue because of the overall effectiveness of the corrective actions following their implementation and improvements made by RP management with enforcing the fleet and industry posting requirements. The station entered this issue into the CAP, (AR 00909560).

Findings No findings of significance were identified.

.4 Assessment of Safety Conscious Work Environment (SCWE)

a. Inspection Scope

The inspectors interviewed selected members of the Clinton station staff to determine if there were any impediments of a SCWE. In addition, the inspectors discussed the implementation of the Employee Concerns Program (ECP) with the ECP coordinators, and reviewed ECP 2007 - 2009 activities to identify any emergent issues or potential trends. Licensee programs to publicize the CAP and ECP programs were also reviewed. In addition, the inspectors assessed the licensees SCWE through the reviews of the facilitys ECP implementing procedures, discussions with coordinators of the ECP, interviews with personnel from various departments, and reviews of ARs. The inspectors also reviewed the results from the August 2007 station safety culture survey.

b. Assessment The inspectors determined that the conditions at the Clinton station were conducive to identifying issues. The staff was aware of and generally familiar with the CAP and other station processes, including the ECP, through which concerns could be raised. Staff interviews identified that issues could be freely communicated to supervision, and that several of the individuals interviewed had previously initiated ARs. In addition, a review of the types of issues in the ECP indicated that site personnel were appropriately using the CAP and ECP to identify issues. The inspectors interviewed the ECP coordinators and concluded that the individuals were focused on ensuring all site individuals were aware of the program, comprehensive in their review of individual concerns, and used the CAP and ECP to appropriately resolve issues. The team noted that the ECP coordinators proactively sought out employee concerns by randomly conducting approximately 100 interviews a year with station employees.

The inspectors noted that the station does not have an anomalous AR process (i.e., paper process) and relies on the ECP to fulfill that function. That is, if an employee wanted to identify an issue to the station directly but did not want her/his identity known, then the employee would have to call the Exelon ECP hotline. The inspectors determined that this phone call could result in an employee leaving a message on an answering machine if a person was not available to answer the call. Using a process outside of the nominal CAP and leaving a safety concern on an answering machine could both be viewed as additional barriers an employee would have to overcome to ensure an issue is known if the employee did not want their identity revealed.

Findings No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

On April 17, 2009, the inspectors presented the inspection results to Mr. Kearney, and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

F. Armetta, Engineering Corrective Action Program Coordinator

D. Brendley, Training Manager

M. Byrd, System Engineer

R. Chickering, Corrective Action Program Administrator

S. Clary, Engineering Programs Manager

T. Conner, Operations Director

C. Culp, Generic Letter 89-13 Program Engineer

T. Danley, In-Service Testing (IST) Program Engineer

A. Darelius, Emergency Planning Manager

J. Domitrovich, Maintenance Director

J. Ellis, Work Management Director

R. Frantz, Regulatory Assurance

G. Halverson, System Manager

N. Hightower, Radiation Operations Manager

M. Honzell, Simulator Coordinator

D. Hupp, Maintenance Planning

T. Husted, System Manager

C. Kelley, Maintenance Programs

M. Knapp, On-Line Work Control

D. McMillan, System Engineer

S. Lakebrink, Senior Staff Engineer

K. Leffel, Operations Support Manager

M. Otten, Operations Training Manager

M. Kanavos, Plant Manager

F. Kearney, Site Vice President

J. Peterson, Regulatory Assurance

M. Reandeau, Shift Operations Superintendent

D. Shelton, Shift Manager

M. Stickney, Corrective Maintenance Optimization

J. Stovall, Radiation Protection Manager

J. Ufert, Fire Marshall

C. VanDenburgh, Nuclear Oversight Manager

M. Vandermyde, Reactor Engineering Supervisor

R. Weber, Engineering Director

C. Williamson, Security Manager

J. Wemlinger, Operations Corrective Action Program Coordinator

LIST OF ITEMS

Opened

None

Closed

None Attachment