IR 05000461/2005009: Difference between revisions

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| issue date = 01/30/2006
| issue date = 01/30/2006
| title = IR 05000461-05-009, on 10/01-12/31/2005, Amergen Energy Company LLC, Clinton Power Station, Post Maintenance Testing and Surveillance Testing
| title = IR 05000461-05-009, on 10/01-12/31/2005, Amergen Energy Company LLC, Clinton Power Station, Post Maintenance Testing and Surveillance Testing
| author name = Ring M A
| author name = Ring M
| author affiliation = NRC/RGN-III/DRP/RPB1
| author affiliation = NRC/RGN-III/DRP/RPB1
| addressee name = Crane C M
| addressee name = Crane C
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000461
| docket = 05000461
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:January 30, 2006 Mr. Christopher President and Chief Nuclear Officer
[[Issue date::January 30, 2006]]
 
Mr. Christopher President and Chief Nuclear Officer


Exelon Nuclear
Exelon Nuclear
Line 29: Line 26:
4300 Winfield Road
4300 Winfield Road


Warrenville, IL 60555
Warrenville, IL 60555SUBJECT:CLINTON POWER STATION NRC INTEGRATED INSPECTION REPORT 05000461/2005009
 
SUBJECT: CLINTON POWER STATION NRC INTEGRATED INSPECTION REPORT 05000461/2005009


==Dear Mr. Crane:==
==Dear Mr. Crane:==
Line 64: Line 59:
the Clinton Power Station Facility.
the Clinton Power Station Facility.


C. Crane-2-
C. Crane-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document


Room or from the Publicly Available Reco rds (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
Room or from the Publicly Available Reco rds (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
Line 71: Line 65:
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
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
Sincerely,
 
/RA/Mark A. Ring, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62Enclosure:Inspection Report No. 05000461/2005009 w/Attachment: Supplemental Informationcc w/encl:Site Vice President - Clinton Power Station Plant Manager - Clinton Power Station
===Enclosure:===
Inspection Report No. 05000461/2005009
 
===w/Attachment:===
Supplemental Informationcc w/encl:Site Vice President - Clinton Power Station Plant Manager - Clinton Power Station


Regulatory Assurance Manager - Clinton Power Station
Regulatory Assurance Manager - Clinton Power Station
Line 152: Line 141:
==REACTOR SAFETY==
==REACTOR SAFETY==


===Cornerstone:===
===Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency===
Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness1R01Adverse Weather (71111.01)
 
Preparedness1R01Adverse Weather (71111.01)


====a. Inspection Scope====
====a. Inspection Scope====
Line 1,277: Line 1,267:


===Closed===
===Closed===
: [[Closes finding::05000461/FIN-2005009-01]]NCVFailure to provide adequate maintenance and work
05000461/2005009-01NCVFailure to provide adequate maintenance and work
instruction is a performance deficiency
instruction is a performance deficiency05000461/2005009-02NCVFailure to correctly identify and correct the cause of
: [[Closes finding::05000461/FIN-2005009-02]]NCVFailure to correctly identify and correct the cause of
the 2005 125 VDC circuit failure was a performance
the 2005 125 VDC circuit failure was a performance


deficiency
deficiency
: Discussed NONE  
Discussed NONE  
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
The following is a list of documents reviewed during the inspection.
: Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety but rather that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort.
: Inclusion of a document on this list does not imply NRC acceptance of the document or
any pat of it, unless this is stated in the body of the inspection report.
==Section 1R01: Adverse Weather==
: WC-AA-107, Seasonal Readiness; Revision 1
: CPS 1860.01, Cold Weather Operations; Revision 6a
: CPS 1860.01C001, Cold Weather Preparation Checklist; Revision 5a
: CPS 1860.01C003, Cold Weather Heater and Heat Trace Operability Checklist; Revision 0b
: IR 399014,2005 CPS Winter readiness exceptions open/tracked; November 15, 2005
: Prompt Investigation
: 430053, Main Condenser Tube Leak; December 2, 2005
: IR 430132, Condenser inspection showed one shared tube, seven tubes plugged;
: December 3, 2005
: IR 284934, Repeat condenser tube leak after work in C1R09; December 21, 2004
: CCA 291519, Condenser tube leak causes additional radiation exposure; March 2, 2005
==Section 1R04: Equipment Alignments==
: CPS 3313.01; Low pressure core spray (LPCS); Revision 15c.
: CPS 3313.01V001; Low pressure core spray valve lineup; Revision 13.
: CPS 3313.01V002; Low pressure core spray instrument valve lineup; Revision 8a.
: CPS 3313.01E001; Low pressure core spray electrical lineup; Revision 11a.
: OP-AA-108-103; Locked equipment program; Revision 1.
: CPS 3501.01, High voltage auxiliary power system; Revision 25e
: CPS 3501.01E001, High voltage auxiliary power system electrical lineup; Revision 13
: USAR section 3.11, Environmental qualification of mechanical and electrical equipment;
: Revision 11
==Section 1R05: ==
: Fire Protection Clinton's Updated Safety Analysis Report, Appendix E, "Fire Protection Evaluation Report"
==Section 1R11: Licensed Operator Requalification==
: LS-AA-126-1001; Licensed operator requalification training NRC Pre 71111.11 Inspection Focused Area Self-Assessment Report; dated August 28, 2005
: TQ-AA-106-0304; Attachment 1; Clinton Power Station 2004 - 2005 Licensed operator
requalification training Program Classroom Summary; Revision 2
: TQ-AA-106-0304; Attachment 2; Clinton Power Station 2004 - 2005 Licensed operator
requalification training Program Simulator Summary; Revision 2
: TQ-AA-106-0304; Attachment 3; Clinton Power Station 2004 - 2005 Licensed operator
requalification training Category Subject Hours Distribution; Revision 2
: TQ-AA-106-0304; Attachment 4; Clinton Power Station 2004-2005 Licensed operator
requalification training Category Distribution; Revision 2
: TQ-AA-106-0304; Attachment 5; Clinton Power Station Licensed operator requalification training
: Examination Question Distribution; Revision 2
: TQ-AA-210-4102; Performance Review Committee Data Sheet; Various Clinton Power Station Simulator Feedback Form; Various
: Requalification Examinations (Operating) - Various; 2004 - 2005
: Requalification Examinations (Written) - Various; 2003 - 2005
: Clinton Power Station Simulator Test Procedure and Results - Various; 2003 - 2005
: Simulator Malfunction Test (MF) procedures/results; Multiple
: Simulator Certification Testing Schedule; Current, 2005
: Simulator Work Requests (SWRs); Multiple
: Cycle 10 Core Performance Testing; Current, 2005
: Root Cause Report
: 345115; "High Initial License Training Exam Failure Rate for Clinton Power
: Station Initial license training Class 04-01" and Corresponding Corrective Actions.
==Section 1R12: Maintenance Rule Implementation==
: MR database, Scoping/Risk significance - summary report for VR system - containment building
: HVAC
: WO 476681, Containment building differential pressure not controlling in band in filtered mode;
: November 9, 2005
: WO 835639, Numerous problems with manipulating continuous containment purge -
: 1HS-VR101; October 11, 2005
: WO 475271,
: EQ-CL024-23 Replace solenoid valve 1FSVR109A; August 29, 2005
: WO 839799, 1VR07CA breaker failed to trip; August 25, 2005
: WO 521259,
: EQ-CL070 Replace o-rings, rod seals, and t-seals - 1VR006B; October 17, 2005
: IR 342859; 1VR07CB fan tripped when shifting; June 10, 2005
: IR 344364; 1VR07CB one time fuse replacement; June 15, 2005
: IR 360014, MCR annunciator 5043- 1A HI TEMP CT BLG CCP SUP AIR; August 4, 2005
: IR 360293, Numerous problems when manipulating CCP - 1HS-VR101; August 5, 2005
: IR 352107, 1VR07CB tripped on startup on CCP in filtered mode; August 11, 2005
: IR 362181, Excessive stroke time for 1VR 006B; August 11, 2005
: IR 362362, 1VR07CA tripped on first attempt in manual mode; August 12, 2005
: IR 364014, 1VR07CA breaker failed to trip; August 17, 2005
: IR 371427, 0VQ02CB failed to start w/CCP in filtered mode auto; September 8, 2005
: IR 376598, CCP failed to run in filtered mode, 0VQ24YB failed to open; September 22, 2005
: IR 392769, CCP failed to start in unfiltered mode; October 31, 2005
: IR 394409, 0VQ02CB shutdown when starting CCP in filtered mode; November 3, 2005
: IR 396149, Containment d/p controlling below alarm setpoint for 5042-7C; November 8, 2005
: IR 396480; CCP continues to fail to operate in filtered mode (auto); November 8, 2005
: IR 294111; Potential level 3 scram setpoint process measurement error
: IR 297921: Evaluate scram frequency reduction committee recommendation
: IR 302395; Disable the level 3 scram with the mode switch in shutdown
: IR 305130 E02-1RP99-021 and 024 GETARS CH'S 286 -289
: IAW 24A1287 (Disparity exist
between documents)
: IR 310064; Work order reschedule due to lack of needed EC
: IR 314700 1c71N652B ATM improperly marked per operator AID 90-02
: IR 318549 RPS procedure needs information on RPT bypass
: IR 332656 1SIRP009; local output frequency meter sticking
: IR 334655; Troubleshooting reveals several inverter anomalies
: IR 347100; 1C71N650A; As found out of specification on 9030.01C023
: IR 355523 ATM calibration not reset to as left tolerance
: 4
==Section 1R15: Operability Evaluations==
: IR 00264610 "Failure of Division II Diesel Generator DC Oil Pumps to Keep Running"
: IR 00264856 "Summary of Events and Repairs to Division II Diesel Generator DC Lube Oil
: Pumps"
: IR 00264857 "Division II Diesel Generator High Resistance Fuse Connection"
: IR 00274008 "Extent of Condition Action for Blown F5-1 Fuse in 1PL12JB"
: IR 00274013 "Extent of Condition Action - Inspect 1AP61EB/C B-Contacts"
: CPS 3506.01, "Diesel Generator and Support Syst ems (DG)", Section 8.2.8 "Testing the DC
: Lube Oil Pumps Auto-Start Feature," Revision 31b
: Technical Specifications 3.8.1, "AC Sources - Operating"
: Clinton's Archival Operations Narrative Logs for 10/18-19/2004
: IR 429583, NRC SSD&PC RCIC tank vortex issue; December 1, 2005
: Operability evaluation
: 429583-02, NRC SSD&PC RCIC tank vortex issue; Revision 000
: Calc IP--0384, Evaluation of vortex in the RCIC storage tank; Revision 1/A
: DWG M06-1079, Reactor core isolation cooling piping; Revision AL
: Calc
: VYC-1844, Vermont Yankee, HPCI and RCIC vortex height; Revision 0
: IR 389791, 1E22-F015 HPCS suppression pool suction failed to indicate full open:
: October 25, 2005
: IR 392614, 9051.02 procedure doesn't address re-stroking the valve; October 31, 2005
: IR 396862, Dual indication on 1E22-F015; November 9, 2005
: ECR 372640, October 28, 2005
==Section 1R16: Operator Workarounds==
: OP-AA- 102-103, Rev. 1, "Operator Work-Around Program"
: CPS 3104.01,"Condensate/Condensate Booster (CD/CB)," Rev. 25a
: IR 329215, "OTDM Fails to Process Hotwell Setpoint Change Per CC-AA-112"
: OP-AA-102-103, Rev. 1, "Operator Work-Around Program"
: EC 350535, "FW Setpoint Set Down Change"
: ECR 372141, "Shop Request Per C. Henderson, Method to Align RT Flanges without Cutting
: Out Flanges (IE Apply Heat to Draw into Alignment).
: This is for RT Reject Bypass Line Orifice"
: IR 244257, "Changes in FW System Result in Poor Level Control Post Scram"
: IR 264090, "1FW01KA - Perform Adjustment to Valve Gear Settings"
: IR 299159, "1G33D001 RT Reject Bypass Orifice Small Leak"
: IR 327160, "1G33D001 (RT Orifice Flange) Leak Worsening"
: IR 361403, "TDRFP 1B LP Stop Valve did not Open when Feed Pump was Reset"
: IR 378860, "Unexpected alarm 5130-2E Regen Gas Dryer Heatup Temp Failure"
: IR 388235, "Design Issue: Valve Trim for WS Reg Valve 1WS026"
: WO 747188, "CT 1FW01KA - Adj Valve Gear
: WO 777396, "Water from Unknown Source Running into Suppression Pool"
: WO 780559, "Replace 1WS026 Turb Lube O
il Cooler Temp Control Valve"
: WO 793588, "Perform Loop Cals for Hotwell Level Loops 1CD057 and 1CD068"
: WO 803554, "Setpoint S et Down Change per EC 350535"
: WO 803556, "Modify SJAE 6" Bypass Line and Control Logic per EC 347137"
: WO 841875, "Inspect
: TDRFP-B LP Control Valve Poppets & Linkages"
: WO 860301, "Unexpected Alarm 5130-2E Regen Gas Dryer Heatup Temp Failure"
==Section 1R19: Post Maintenance Testing==
: WO 668279, Electrical maintenance troubleshoot/rework/adjust to restore sat operation;
: November 8, 2005
: WO 818454, OP PMT 1C41C001B return to service, verify op w/no oil leak; November 9, 2005
: IR 202999, SLC pump B started 15 seconds later than expected (9015.02); February 20, 2004
: CPS 9067.01,"Standby Gas Treatment System Train Flow/Heater Operability", Rev 30b
: WO 701994, "Hydramotor Preventative Maintenance"
: WO 701995, "Hydramotor Preventative Maintenance"
: WO 760183, "EQ-CL044-02 Perform Annual EQ Hydramotor PM"
: WO 760184, "EQ-CL044-01 Perform Annual EQ Hydramotor PM"
: EC 358727, Bypass high water temperature switch 1TS-DG255 trip function for the division III
diesel generator; Revision 0
: WO 869003-07, EM troubleshoot division III diesel generator tripped during 9080.03;
: November 21, 2005
: WO 869003-09, EM install temp mod on division III EDG water temp switch EC 358272;
: November 22, 2005
: IR 426309, Div 3 diesel generator tripped during 9080.03; November 21, 2005
: WO 859003-01, Replace/Calibrate 1TSDG255 due to trip of div 3 DG; November 25, 2005
: WO 859003-08, Reland trip lead lifted in task 7 for K12 relay; November 25, 2005
: WO 869003-10, Remove temp mod
: EC 358272 to restore the high water temperature switch
: 1TS-DG255 (S11) trip function for the div-III diesel generator; November 25, 2005
: CPS 9065.02D001, Secondary containment integrity data sheet; Revision 29
: IR 427027, 9065.02 Secondary containment integrity enhancement; November 23, 2005
: IR 427050, VG Train B oscillations; November 23, 2005
: WO 657204,
: OP 9065.02 OP secondary containment integrity; January 18, 2004
: WO 655681, IM Flow indication oscillating +/- 400 scfm; November 22, 2005
: CPS 3319.01, Standby gas treatment; Revision 15c
: CPS 9065.02, Secondary containment integrity; Revision 29a
==Section 1R22: Surveillance Testing==
: WO 833100, 9051.02A21; OP high pressure core spray valve operability (stoke time);
: October 24, 2005
: CPS 9051.02; High pressure core spray valve operability test; Revision 38c.
: IR 389791, 1E22-F015; High pressure core spray suppression pool suction failed to indicate full
open; October 25, 2005
: IR 392614, 9051.02; Procedure doesn't address re-stroking the valve; October 31, 2005
: TCCP
: 357546; Install temporary power supply as a backup to power supply Item 69 in panel
==1PA0 5J==
==Section 1R23: Temporary Plant Modifications==
: EC 358272, Bypass high water temperature switch 1TS-DG255 trip function for the division III
diesel generator; Revision 0
: WO 869003, Troubleshoot div 3 diesel generator tripped during 9080.03; November 21, 2005
: IR 426309, Div 3 diesel generator tripped during 9080.03; November 21, 2005


==Section 1EP4: Emergency Action Level and Emergency Plan Changes==
: Clinton Power Station Annex to the Exelon Standardized Emergency Plan; Revision 7
==LIST OF ACRONYMS==
USEDACEapparent cause evaluationADAMSAgency wide Documents Access and Management System
ALARAas low as is reasonably achievable
CRcondition reports
EDGemergency diesel generator
HEPAhigh efficiency particulate air
IMCInspection Manual Chapter
IRissue reports
LPCSlow pressure core spray
NCVnon-cited violation
NRCNuclear Regulatory Commission
MRMaintenance Rule
NEINuclear Energy Institute
ORMOperations Requirements Manual
OSCOperational Support Center
PARSPublicly Available Records
: [[PI]] [[performance indicator]]
: [[RP]] [[radiation protection]]
SDPSignificant Determination Process
TSTechnical Specifications
: [[USARU]] [[pdated Safety Analysis Report]]
}}
}}

Revision as of 00:07, 14 July 2019

IR 05000461-05-009, on 10/01-12/31/2005, Amergen Energy Company LLC, Clinton Power Station, Post Maintenance Testing and Surveillance Testing
ML060310367
Person / Time
Site: Clinton Constellation icon.png
Issue date: 01/30/2006
From: Ring M
NRC/RGN-III/DRP/RPB1
To: Crane C
Exelon Generation Co, Exelon Nuclear
References
IR-05-009
Download: ML060310367 (37)


Text

January 30, 2006 Mr. Christopher President and Chief Nuclear Officer

Exelon Nuclear

Exelon Generation Company, LLC

4300 Winfield Road

Warrenville, IL 60555SUBJECT:CLINTON POWER STATION NRC INTEGRATED INSPECTION REPORT 05000461/2005009

Dear Mr. Crane:

On December 31, 2005, the US Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Clinton Power Station. The enclosed report documents the

inspection findings which were discussed on January 12, 2006, with Mr. R. Bement and other

members of your staff.

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

Based on the results of this inspection, the inspectors identified two findings of very low safety significance (Green). Both of these findings involved violations of NRC requirements.

However, because these violations were of very low safety significance and because the issues have been entered into the licensee's corrective action program, the NRC is treating

these issues as non-cited violations, in accordance with Section VI.A.1 of the NRC's

Enforcement Policy.

If you contest the subject or severity of a non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear

Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, US Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Lisle, IL 60532-4352; the Director, Office of Enforcement, US Nuclear

Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at

the Clinton Power Station Facility.

C. Crane-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Reco rds (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at

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

Sincerely,

/RA/Mark A. Ring, Chief Branch 1 Division of Reactor Projects Docket No. 50-461 License No. NPF-62Enclosure:Inspection Report No. 05000461/2005009 w/Attachment: Supplemental Informationcc w/encl:Site Vice President - Clinton Power Station Plant Manager - Clinton Power Station

Regulatory Assurance Manager - Clinton Power Station

Chief Operating Officer

Senior Vice President - Nuclear Services

Vice President - Operations Support

Vice President - Licensing and Regulatory Affairs

Manager Licensing - Clinton Power Station

Senior Counsel, Nuclear, Mid-West Regional Operating Group

Document Control Desk - Licensing

SUMMARY OF FINDINGS

IR 05000461/2005009; AmerGen Energy Company

LLC; 10/01/2005 - 12/31/2005; Clinton Power Station; Post Maintenance Testing and Surveillance Testing.

This report covers a 3-month period of baseline resident inspection and announced baseline inspections on radiation protection, emergency preparedness and licensed operator requalification. The inspection was conducted by Region III inspectors and the resident inspectors. Two Green findings involving two non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using

Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be "Green" or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.Inspector-Identified and Self Revealing Findings

Cornerstone: Mitigating Systems

Green.

A self-revealing finding involving a non-cited violation (NCV) of Technical Specification 5.4.1 "Procedures," was identified. On September 30, 2005, the

Division III emergency diesel generator failed to properly run following maintenance activities, due to the inadequate maintenance instructions. The inadequate maintenance instructions resulted in air being trapped in the governor oil system during the replacement of the governor's servo booster motor. The licensee determined that this issue was the result of a maintenance planner's failure to follow administrative guidelines for technical review during the development of the maintenance instructions.

This issue resulted in extended outage and unavailability time for the emergency diesel generator.

The inspectors determined that despite the fact that the issue involved work in progress, this issue was more than minor because the finding affected the Mitigating

Systems Cornerstone objective of ensuring the availability of mitigating systems to prevent undesirable consequences. The issue resulted in the emergency diesel generator being unavailable for longer than expected by the plant staff. Following the initial maintenance run of the diesel generator, operators declared that the diesel generator was available for use if needed to respond to an event. Corrective actions by the licensee included developing lesson-learned information to share with other maintenance planners. Additionally, the licensee planned to add technical guidance related to venting air from the diesel governor to the diesel maintenance training material. The finding also affected the cross cutting area of human performance since the licensee's maintenance personnel failed to request technical guidance from the site engineering staff as directed by the licensee's administrative procedures.

(Section 1R19)

3*Green. The inspectors identified a finding involving a non-cited violation for inadequate corrective action. The licensee's failure to properly identify and correct a degraded electrical circuit in 2004, involving a high resistance connection on a fuse holder, resulted in the Division II emergency diesel generator subsystem being vulnerable to electrical circuit failure if called upon to complete its support function. The high resistance connection was caused by degraded grease-like material and dirt. This issue also resulted in the Division II diesel generator failure during a subsequent surveillance test. The inspectors determined that the finding was greater than minor because the finding affected the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to prevent undesirable consequences.

The Division II emergency diesel generator 125 VDC system is a backup to the AC oil system in case of a loss of offsite power.

Offsite power was not lost, therefore, there was not an actual loss of safety function for the diesel. Corrective actions by the licensee included replacing the fuse and fuse holder and expediting actions to address the extent of condition relative to the as-found condition of the fuse and fuse holder. The finding also affected the cross cutting area of problem identification and resolution since the licensee failed to adequately address the degraded circuit condition in a timely manner. (Section 1R22)

B.Licensee-Identified Violations

No findings of significance were identified.

4

REPORT DETAILS

Summary of Plant Status

The plant operated at approximately 95.5 percent rated thermal power (maintaining 103 percent electrical output) throughout most of the inspection period. On November 18, 2005, reactor

power was reduced to 85 percent to reseat a potentially stuck open moisture separator reheater

relief valve. On November 19, 2005, plant operators returned reactor power to 95.5 percent.

On December 2, 2005, operators lowered reactor power to 49 percent in response to a ruptured

main condenser tube and returned power to 95.5 percent on December 4, 2005. On

December 18, 2005, operators lowered reactor power to 90 percent for a planned rod pattern

adjustment (All rods out). Power was restored to 95 percent on December 18, 2005, and

maintained there through the end of the inspection period.1.

REACTOR SAFETY

Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency

Preparedness1R01Adverse Weather (71111.01)

a. Inspection Scope

The inspectors reviewed the licensee's seasonal readiness preparation checklist for cold weather and to verify that it adequately covered risk-significant equipment and ensured

that the equipment was in a condition to meet the requirements of Technical

Specifications (TS), the Operations Requirements Manual (ORM), and the Updated Safety Analysis Report (USAR) with respect to protection from low temperatures. The

inspectors verified that minor issues identified during the inspection were entered into

the licensee's corrective action system by reviewing the associated Condition Reports (CR). The inspectors conducted more detailed system reviews and walkdowns for the

reactor core isolation cooling storage tank and service air compressor intake. The

inspectors also reviewed several issue reports related to main condenser tube leaks that

seem to occur more frequently at the onset of cold weather. These issue reports and

other documents reviewed during the inspection are listed at the end of this report. This

activity represents one inspection sample.

b. Findings

No findings of significance were identified.

51R04Equipment Alignments (71111.04).1Complete Semi-Annual

a. Inspection Scope

The inspectors conducted a complete system alignment inspection of the low pressure core spray (LPCS) system. This system was selected based on its high risk significance

and mitigating systems function. The inspectors reviewed plant procedures, drawings, and the USAR to identify proper system alignm ent and visually inspected system valves, instrumentation, and electrical supplies to verify proper alignment, component

accessibility, availability, and current material condition. The inspectors also completed

a review of corrective action documents, work orders, and operator work around and

challenges to ensure there were no current operability concerns with the system.

Documents reviewed during this inspection are listed in the Attachment. These activities

completed one inspection sample.

b. Findings

No findings of significance were identified..2Partial Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of accessible portions of divisions of risk-significant mitigating systems equipment during times when the divisions were of

increased importance due to the redundant divisions or other related equipment being

unavailable. The inspectors utilized the valve and electric breaker checklists listed in the to verify that the components were properly positioned and that support

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

of the components and observed operating paramet ers of equipment to verify that there were no obvious deficiencies. The inspectors reviewed outstanding work orders and CR

associated with the divisions to verify that those documents did not reveal issues that

could affect division function. The inspectors used the information in the appropriate

sections of the USAR to determine the functional requirements of the systems. The

documents listed at the end of this report were also used by the inspectors to evaluate

this area. The inspectors performed two samples by verifying the alignment of the

following divisions:*Auxiliary power system*Reactor core isolation cooling system

b. Findings

No findings of significance were identified.

61R05Fire Protection (71111.05Q)

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of fire fighting equipment, the control of transient

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

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

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

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

could cause a plant transient, or their impact on the licensee's ability to respond to a

security event. The inspectors used the documents listed at the end of this report to

verify that fire hoses and extinguishers were in their designated locations and available

for immediate use, that fire detectors and sprinklers were not obstructed, that transient

material loading was within the analyzed limits, and that fire doors, dampers, and

penetration seals appeared to be in satisfactory condition. The inspectors verified that

minor issues identified during the inspection were entered into the licensee's corrective

action program.

The inspectors reviewed portions of the licensee's fire protection evaluation report and the USAR to verify consistency in the docum ented analysis with installed fire protection equipment at the station.

The inspectors completed four samples by inspection of the following areas:Fire zone A - 1a: Elevation 707' 6", General Access Area (North)Fire zone A - 2a: Elevation 707' 6", RCIC Pump RoomFire zone A - 6: Elevation 707' 6", General Access Area (South)Fire zone CB-6a: Elevation 800' Main Control Room Complex

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11).1Facility Operating History

a. Inspection Scope

The inspectors reviewed the plant's operating history from January 2004 through October 2005 to assess whether the licensed operator requalification training program

had identified and addressed operator performance deficiencies at the plant.

b. Findings

No findings of significance were identified.

7.2Licensee Requalification Examinations

a. Inspection Scope

The inspectors performed a biennial inspection of the licensee's licensed operator requalification training test/examination program. The operating examination material

reviewed consisted of four operating tests, each containing approximately two dynamic

simulator scenarios and approximately five job performance measures. The written

examinations reviewed consisted of four written examinations, each containing

approximately 35 questions. The inspectors reviewed the annual requalification

operating test and biennial written examination material to evaluate general quality, construction, and difficulty level. The inspectors assessed the level of examination

material duplication from week-to-week during the current year operating test, and

compared the operating test material from this year's operating tests (2005) with last

year's operating tests (2004). The annual operating tests were conducted in

September/October/November 2004 and S eptember/October/November 2005. The examiners assessed the amount of writt en examination material duplication from week-to-week for the written examination administered in

September/October/November 2005. The ins pectors reviewed the methodology for developing the examinations, including the licensed operator requalification training

program two year sample plan, probabilis tic risk assessment insights, previously identified operator performance deficiencies, and plant modifications.

b. Findings

No findings of significance were identified..3Licensee Administration of Requalification Examinations

a. Inspection Scope

The inspectors observed the administration of a requalification operating test to assess the licensee's effectiveness in conducting the test. The inspectors evaluated the

performance of one shift crew in parallel wi th the facility evaluators during two dynamic simulator scenarios and evaluated various licensed crew members concurrently with

facility evaluators during the administration of several job performance measures. The

inspectors assessed the facility evaluators' ability to determine adequate crew and

individual performance using objective, meas urable standards. The inspectors observed the training staff personnel administer the operating test, including conducting

pre-examination briefings, evaluations of operator performance, and individual and crew

evaluations upon completion of the operating test. The inspectors evaluated the ability

of the simulator to support the examinations. A specific evaluation of simulator

performance was conducted and documented under Section 1R11.9, "Conformance

With Simulator Requirements Specified in 10 CFR 55.46," of this report.

b. Findings

No findings of significance were identified.

8.4Examination Security

a. Inspection Scope

The inspectors observed and reviewed the licensee's overall licensed operator requalification examination security program related to examination physical security (e.g., access restrictions and simulator considerations) and integrity (e.g., predictability

and bias). The inspectors also reviewed the facility licensee's examination security

procedure, any corrective actions related to past or present examination security

problems at the facility, and the implementation of security and integrity measures (e.g., security agreements, sampling criteria, bank use, and test item repetition)

throughout the examination process.

b. Findings

No findings of significance were identified..5Licensee Training Feedback System

a. Inspection Scope

The inspectors assessed the methods and effectiveness of the licensee's processes for revising and maintaining its licensed operator requalification training program up to date, including the use of feedback from plant events and industry experience information.

The inspectors reviewed the licensee's quality assurance oversight activities, including

licensee training department self-assessment reports. The inspectors evaluated the

licensee's ability to assess the effectiveness of its licensed operator requalification

training program and the licensee's ability to implement appropriate corrective actions.

b. Findings

No findings of significance were identified..6Licensee Remedial Training Program

a. Inspection Scope

The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the previous biennial requalification examinations and the training

planned for the current examination cycle to ensure that the licensee addressed

weaknesses in licensed operator or crew performance identified during training and

plant operations. The inspectors reviewed remedial training procedures and individual

remedial training plans.

b. Findings

No findings of significance were identified.

9.7Conformance With Operator License Conditions

a. Inspection Scope

The inspectors reviewed the facility and individual operator licensees' conformance with the requirements of 10 CFR Part 55. The inspectors reviewed the facility licensee's

program for maintaining active operator licenses and to assess compliance with

10 CFR 55.53

(e) and (f). The inspectors reviewed the procedural guidance and the

process for tracking on-shift hours for licensed operators and which control room

positions were granted watch-standing credit for maintaining active operator licenses.

The inspectors reviewed the facility licensee's licensed operator requalification training

program to assess compliance with the requalification program requirements as

described by 10 CFR 55.59 (c). Additionally, medical records for 16 licensed operators

were reviewed for compliance with 10 CFR 55.53 (i).

b. Findings

No findings of significance were identified..8Annual Operating Test Results

a. Inspection Scope

The inspector reviewed the overall pass/fail results of the annual operating examination which consisted of job performance measure and simulator operating tests (required per

10 CFR 55.59(a)(2)) administered by the licensee. The inspectors reviewed the overall

pass/fail results for the biennial written examination (required per 10 CFR 55.59(a)(2))

administered by the licensee. The overall results were compared with the significance

determination process in accordance with NRC Manual Chapter 0609I, "Operator

Requalification Human Performance Significance Determination Process (SDP)." This

represented one sample.

b. Findings

No findings of significance were identified..9Conformance With Simulator Requirements Specified in 10 CFR 55.46

a. Inspection Scope

The inspectors assessed the adequacy of the licensee's simulation facility (simulator) for use in operator licensing examinations and for satisfying experience requirements as

prescribed in 10 CFR 55.46, "Simulation Facilities." The inspectors also reviewed a

sample of simulator performance test records (i.e., transient tests, scenario test and

discrepancy resolution validation test), simulator discrepancy and modification records, and the process for ensuring continued assurance of simulator fidelity in accordance

with 10 CFR 55.46. The inspectors reviewed and evaluated the discrepancy process to

ensure that simulator fidelity was maintained. Open simulator discrepancies were

reviewed for importance relative to the impact on 10 CFR 55.45 and 55.59 operator 10 actions as well as on nuclear and thermal hydraulic operating characteristics. The inspectors conducted interviews with members of the licensee's simulator staff about the

configuration control process and completed the IP 71111.11, Appendix C, checklist to

evaluate whether or not the licensee's plant-referenced simulator was operating

adequately as required by 10 CFR 55.46

(c) and (d).

b. Findings

No findings of significance were identified..10Quarterly Resident Inspector Review

a. Inspection Scope

The inspectors reviewed licensed-operator requalification training to evaluate operator performance in mitigating the consequences of a simulated event, particularly in the

areas of human performance. The inspectors evaluated operator performance attributes

which included communication clarity and formality, timely performance of appropriate

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

senior reactor operator oversight and command and control.

Crew performance in these areas was compared to licensee management expectations and guidelines as presented in the following documents:*ESG-LOR-85 - "Loss of 6.9 kV Bus 1B, ATWS - Drywell Leak"*ESG-LOR-74 - "Steam Leak, Drywell Leak, Figure N Blowdown"

  • OP-AA-101-111, "Roles and Responsibilities of On-shift Personnel," Rev 0
  • OP-AA-103-102, "Watchstanding Practices," Rev 2
  • OP-AA-104-101, "Communications," Rev 1
  • OP-AA-106-101, "Significant Event Reporting," Rev 2 The inspectors also assessed the performance of the training staff evaluators involved in the requalification process. For any weaknesses identified, the inspectors observed that

the licensee evaluators also noted the issues and discussed them in the critique at the

end of the session. The inspectors verified all issues were captured in the training

program and licensee corrective action process.

These activities completed two inspection samples.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12Q)

The inspectors reviewed the effectiveness of the licensee's maintenance efforts in implementing the Maintenance Rule (MR) requirements, including a review of scoping, goal-setting, performance monitoring, short and long-term corrective actions, and current

equipment performance problems. Systems were selected based on their designation 11 as risk significant under the maintenance rule, or being in the increased monitoring (MR category (a) (1)) group. In addition, the inspectors interviewed the system engineers

and maintenance rule coordinator. The inspectors also reviewed condition reports and

associated documents for appropriate identification of problems, entry into the corrective

action system, and appropriateness of planned or completed actions. The documents

reviewed are listed at the end of the report. The inspectors completed two samples by

reviewing the following:*Reactor protection system*Containment ventilation system and continuous containment purge systemb.Findings No findings of significance were identified.

1R13 Maintenance Risk Assessment (71111.13)

The inspectors observed the licensee's risk assessment processes and considerations used to plan and schedule maintenance activities on safety-related structures, systems, and components, particularly to ensure that maintenance risk and emergent work

contingencies had been identified and resolved. The inspectors completed five samples

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

activities or work weeks:*Emergency reserve auxiliary transformer system outage*Standby liquid control (both trains) inoperable due to the performance of limit switch maintenance on 1C41-F031 (WO# 668279)*Division I diesel generator ventilation fan control in pull-to-lock to support troubleshooting activities concurrent with planned maintenance on division 1

essential switchgear heat removal (WR# 189992)*Cumulative review of licensee risk management assessments following transfer of 1B1 Bus to the reserve auxiliary tr ansformer and then back to the emergency reserve auxiliary transformer for pos t maintenance test on 1AP09EC synch check relay as directed by WO# 758834-02, division II standby gas treatment

system out of service for planned maintenance, and division II essential

switchgear heat removal fan and chiller out of service for planned maintenance*Licensee risk assessment activities and redundant system protection activities following a trip of the division III diesel during a monthly runb.Findings No findings of significance were identified.

1R14 Non-routine Evolutions (71111.14)

a. Inspection Scope

The inspectors reviewed personnel performance during planned and unplanned plant evolutions and selected licensee event reports focusing on those involving personnel 12 response to non-routine conditions. The review was performed to ascertain that operator responses were in accordance with the required procedures. In particular, the

inspectors completed one sample by reviewing personnel performance during the

following plant event:*Plant Operations activities in response to main condenser tube failure

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed the following operability determinations and evaluations affecting mitigating systems to determine whether operability was properly justified and

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

had occurred. The inspectors completed three samples of operability determinations

and evaluations by reviewing the following:*Division II diesel generator - failure of division II DC oil pumps to keep running due to a high current overload on F5-1 fuse*Reactor core isolation cooling tank vortex issue

  • High pressure core spray suppression pool suction valve

b. Findings

No findings of significance were identified.

1R16 Operator Workarounds (71111.16)

.1 Review of selected workaround issue

a. Inspection Scope

The inspectors assessed the following operator workaround issue to determine the potential effects on the functionality of the corresponding system:*Condensate pump suction pressure - condensate pump suction pressure is degraded During this inspection, the inspectors reviewed the technical adequacy of the workaround documentation against the updated safety analysis report and other design

information to assess whether the workaround conflicted with any design basis

information. The inspectors compared the information in abnormal or emergency

operating procedures to the workaround information to ensure that the operators

maintained the ability to implement important procedures when needed.

13 This represented one inspection sample.

b. Findings

No findings of significance were identified..2Semi-annual Review of the Cumulative Effects of Operator Workarounds

a. Inspection Scope

The inspectors reviewed all operator workarounds and challenges to identify any potential effect on mitigating systems ability to function as required during emergencies

and ensure that operators would be able to respond in a correct and timely manner to

plant transients and accidents. The inspectors utilized procedure OP-AA-102-103, "Operator Work-Around Program," revision 1, during the review. The inspectors also

reviewed issue reports and work orders related to corrective actions to remove the

workarounds or compensatory actions.

The inspectors completed one sample by reviewing the following workarounds and challenges: *N66-D006B off gas regenerator dryer thermostatic trap*1FW01 PB turbine-driven reactor feed pump 1B

  • 1WS026 turbine oil cooler temperature control valve
  • Condensate pump suction pressure
  • 0WE01FA (B) [C] radwaste filters A (B) [C]

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the post maintenance testing activities associated with maintenance or modification of important mitigating, barrier integrity, and support

systems that were identified as risk significant in the licensee's risk analysis. The

inspectors reviewed these activities to ve rify that the post maintenance testing was performed adequately, demonstrated that the maintenance was successful, and that

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

maintenance and engineering department personnel and reviewed the completed post

maintenance testing documentation. The inspectors used the appropriate sections of

the TS and USAR, as well as the documents listed at the end of this report, to evaluate

this area.

14 Testing subsequent to the following activities was observed and evaluated to complete seven inspection samples:*Reviewed completed CPS 3412.01, Essential switchgear heat removal, followingcompletion of WO# 752802, 1SX202A relief valve and 1SX110BA pipe

replacement*Electrical Maintenance troubleshoot/rework/adjust to restore sat operation, standby liquid control test tank outlet valve limit switch WO# 668279*Standby Gas Treatment Train B - containment draw down test following work to correct flow oscillations WO# 657204, OP 9065.02 OP secondary containment

integrity; January 18, 2004, and WO# 655681, IM Flow indication oscillating

+/- 400 scfm; November 22, 2005*Division III diesel generator high water temperature switch replacement

  • Reviewed Section 8.14.18 of CPS 9061.06C014 to ensure post maintenance testing adequacy following removal of deluge line flange and reinstallation of spool piece for 1SX073B standby gas treatment 1B deluge valve*Reviewed CPS 3412.01, Essential switchgear heat removal, following completion of WO #616616, circuit breaker and bucket replacement*Reviewed results of CPS 8731.12 following rod control and information system transponder card replacement WO# 647415

b. Findings

Introduction

A self-revealing Green finding involving a non-cited violation (NCV) of Technical Specification 5.4 "Procedures," was identified. On September 30, 2005, the

Division III emergency diesel generator (EDG) failed to properly run following

maintenance activities, due to inadequate maintenance instructions. The licensee

determined that this issue was the result of a maintenance planner's failure to follow

administrative guidelines for technical review during the development of the

maintenance instructions. This issue resulted in extended outage and unavailability time

of the EDG.

Discussion

On September 30, 2005, the Division III EDG was started for a maintenance run following a system outage window. During the initial start of the EDG, the start sequence was normal. Followup adjustments were then made on a newly

installed shutdown solenoid. The licensee's operations staff declared the diesel

generator available if needed to response to an event. The licensee's online risk profile

changed from "Yellow" to "Green." At this time compensatory actions such as the

establishment of protected system pathways were removed.

During subsequent starts, the EDG exhibited abnormal starting indication. While starting the EDG for post maintenance test, the licensee observed a starting time of greater than

12 seconds. Additionally, unusual speed and voltage variations occurred when

operators made adjustments to the diesel voltage regulator while the diesel was running.

A licensee investigation determined that due to a lack of technical rigor for EDG shutdown solenoid and servo booster replacement, the work instructions performing

these tasks contained inadequate guidance which allowed air to be trapped in the servo 15 booster motor. The servo booster motor is a part of the governor. The air trapped on the oil side of the governor's operating piston resulted in the governor not being able to

perform its designed function. This issue resulted in lengthening the time in which the

Division III EDG was unavailable and inoperable.

The licensee's investigation also determined that the work instructions failed to contain adequate instructions for venting or draining air from the governor following the

replacement of the servo booster. The licensee concluded that this issue would not

have occurred if the work planner responsible for the work instructions would have

contacted the appropriate engineering staff per the licensee's "Performance Centered

Maintenance" (MA-AA-716-210) procedure. This procedure required the maintenance

planner to route the work instructions to the licensee's engineering staff for a formal

review of technical information.

Analysis:

Failure to provide adequate maintenance and work instruction is a performance deficiency. The inspectors compared this finding to the findings identified

in Appendix E, "Examples of Minor Issues," of IMC 0612, "Power Reactor Inspection

Reports," dated September 30, 2005, to determine whether the finding was minor. The

inspectors determined that no example contained in Appendix E was applicable to this

situation. The inspectors then reviewed this finding against the guidance contained in

Appendix B, "Issue Dispositioning Screening," of IMC 0612. The inspectors determined

that despite the fact that this issue involved work in progress, this issue was more than

minor because the finding affected the Mitigating Systems Cornerstone objective of

ensuring the availability of mitigating systems to prevent undesirable consequences.

The issue resulted in the emergency diesel generator being unavailable for longer than

expected by the plant staff. Following the initial maintenance run of the diesel generator

operators declared that the diesel generator was available for use, if needed to respond

to an event. At this time, a number of compensatory actions such as the establishment

of protected system pathways were eliminated. The inspectors completed a Phase 1

significance determination of this issue using IMC 0609, "Significance Determination

Process," Appendix A, Attachment 1, dated November 22, 2005. The inspectors

selected the Mitigating Systems Cornerstone. The inspectors answered "no" to all five

questions. Therefore, the inspectors concluded that this issue was a finding of very low

safety significance (Green).

Enforcement:

Technical Specification 5.4.1, states that written procedures shall be established, implemented, and maintained covering the applicable procedures

recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

Appendix A of Regulatory Guide 1.33, recommends that procedures for performing

maintenance that can affect the performance of safety-related equipment should be

properly preplanned and performed in accordance with written procedures, documented

instructions, or drawings appropriate to the circumstances.

Contrary to the above, the licensee's procedures for performing maintenance on the Division III EDG were inadequate, in that, the work instruction did not prevent air from

being trapped in the servo booster motor and did not vent the air following the servo

booster replacement. On September 30, 2005, the licensee's failure to have adequate

maintenance procedures resulted in the diesel generator not operating properly. This

was a violation. Corrective actions by the licensee included developing lesson-learned 16 information so issues surrounding this finding would be shared with other licensee staff.

Additionally, the licensee planned to add technical guidance related to venting air from

the diesel governor to the licensee's diesel maintenance training material.

The finding also affected the cross cutting area of human performance since the licensee's maintenance personnel failed to request formal technical guidance from

engineering staff as directed by licensee administrative procedures. Because the finding

has been captured by the licensee's corrective action program (CR 379980), this violation is being treated as a non-cited violation (NCV 05000461/200509-01(DRP))

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

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors witnessed selected surveillance testing and/or reviewed test data to verify that the equipment tested using the surveillance procedures met the TS, the ORM, the USAR, and licensee procedural requirements, and demonstrated that the equipment

was capable of performing its intended safety functions. The activities were selected

based on their importance in verifying mitigating systems capability and barrier integrity.

The inspectors used the documents listed at the end of this report to verify that the

testing met the frequency requirements; that the tests were conducted in accordance

with the procedures, including establishing the proper plant conditions and prerequisites;

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

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

and engineering department personnel regarding the tests and test results.

The inspectors evaluated the following surveillance tests to complete six inspectionsamples:*CPS 9051.02 "High Pressure Core Spray Valve Operability Surveillance"*CPS 9431.04C20, "Reactor Protection System Reactor Water Level" WO # 686384-01*CPS 9057.02 "Secondary Containment Integrity"

  • CPS 9080.02 "Diesel Generator 1B Operability - Manual Quick Start Operability"
  • CPS 9080.03 "Diesel Generator 1C Operability - Manual Quick Start Operability"

b. Findings

Introduction

The inspectors identified a Green finding involving a non-cited violation for inadequate corrective action. The licensee's failure to properly identify and correct a

degraded electrical circuit in 2004, resulted in the Division II EDG subsystem being

vulnerable to electrical circuit failure if called upon to complete its support function. This

issue also resulted in a Division II EDG failure during a subsequent surveillance test.

Discussion

On October 18, 2004, a blown fuse in the electrical circuit that supplies 125 VDC power to the Division II EDG DC oil pumps starter resulted in the failure of the

pumps to operate. The Division II diesel generator was declared inoperable.

17 In Apparent Cause Evaluation (ACE) 267857, the licensee determined that the apparent cause of the F5-1 fuse failure was due to a high current overload combined with

potential fatigue of the fuse. However, the ACE also concluded that discoloration in the

F5 fuse holder could not be characterized as a high resistance point. The high current

condition was determined to be caused by high inrush current. The ACE stated that the

manufacturer does not recommend this fuse type for significant inrush current.

Corrective actions included an evaluation to change the fuse type and an evaluation to

do thermography on the fuse block during subsequent performance of CPS 3506.01.

The evaluation concluded that no change of fuse was necessary and thermography was

not viable. No other actions were recommended to determine the cause of the fuse

failure. On November 14, 2005, the Division II EDG DC oil pumps again failed to start during performance of CPS 3506.01 due to a failure of the 125 VDC circuit. This circuitry also

powered the fuel priming pump and the field conditioning relay. During the investigation

the licensee determined that the failure of the circuit was caused by a high resistance

electrical connection within the F5 and F5-1 fuse block.

Exelon PowerLabs report, CPS 83658 "Failure analysis of an ITE Gould, #FP32, 30A fuse block" concluded that dust and dirt accumulation internal to the fuse block stab

connection area in combination with accumulated, dried grease-like material that

provided a collection point for the dust and dirt caused the fuse block to fail. The

PowerLabs report could not determine whether the grease-like material was from the

fuse block manufacturer or not. The fuse block was original plant equipment. The

PowerLabs report indicated that it was evident based on the amount of dust and dirt

accumulated on the fuse block cover, that the environment in which the fuse was

installed was very dusty, and there were a number of passages on the fuse block that

would allow dust to accumulate.

An Apparent Cause Evaluation (ACE 398451) completed by the licensee stated that based on the results of the 2005 event and the PowerLabs report results, it was clear

that the degraded internal fuse block connection existed in 2004 and most probably was

the initiator of the 2004 event as well. Based on this information, the inspectors

concluded that the high resistance condition remained in the diesel circuitry for over a

year despite there being signs that it existed following the first failure.

The inspectors concluded that failure of Apparent Cause Evaluation 264857 to properly identify the cause of high resistance in the fuse connection resulted in a repetitive failure

of the Division II 125V DC oil pumps (turbo soak back and circulating pumps) auto-start

feature during the performance of CPS 3506.01.

Following a review of the PowerLabs report and ACE 398451, the inspectors were concerned with the licensee's extent of condition review and subsequent corrective

actions related to this issue. The inspectors noted that the ACE contained no

information that addressed why this particular fuse and fuse holder was unique or had a

higher susceptibility of being found in this degraded condition (dried grease and dirt on

contacts). As a result of questions by the inspectors related to extent of condition and

subsequent corrective actions, the licensee developed actions to examine other fuse 18 and fuse holders in the Divisions I and III 125 VDC electrical circuitry in an expedited manner.

Analysis:

Failure to correctly identify the cause of the 2004 Division II EDG 125 VDC circuit failure was a performance deficiency. The inspectors determined that the finding

was greater than minor in accordance with IMC 0612, "Power Reactor Inspection

Reports," Appendix B, "Issue Disposition Screening," issued September 30, 2005. This

issue was greater than minor because the finding affected the Mitigating Systems

Cornerstone objective of ensuring the availability, reliability, and capability of mitigating

systems to prevent undesirable consequences. The inspectors evaluated this finding

using Manual Chapter 0609, "Significance Determination Process," Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations,"

Phase 1 screening associated with the Mitigating Systems Cornerstone. The 125 VDC

system is a backup to the AC oil system in case of a loss of offsite power. Offsite power was not lost, therefore, there was not an actual loss of safety function for the diesel.

This was a Green issue.

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, states that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are

promptly identified and corrected. Contrary to the above, following a failure of the

Division II EDG 125 VDC circuit on November 14, 2004, the licensee failed to identify

and correct the deficiency that caused the failure. This was a violation. Corrective

actions by the licensee included replacing the fuse and fuse holder and expediting

actions to address the extent of condition relative to the as-found condition of the fuse

and fuse holder.

The finding also affected the cross-cutting area of problem identification and resolution since the licensee failed to adequately address the degraded circuit condition in a timely

manner. Because the finding has been captured by the licensee's corrective action

program (CR 398451), this violation is being treated as a non-cited violation (NCV 05000461/2005-09-02(DRP))

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

1R23 Temporary Plant Modifications (71111.23)

a. Inspection Scope

The inspectors reviewed temporary plant modifications to verify that the instructions were consistent with applicable design modification documents and that the

modifications did not adversely impact system operability or availability. The inspectors interviewed operations, engineering and maintenance personnel as appropriate and

reviewed the design modification documents and the 10 CFR 50.59 evaluations against

the applicable portions of the USAR. The documents listed at the end of this report were

also used by the inspectors to evaluate this area.

The inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified temporary modification problems were being entered into

the program with the appropriate characterization and significance. The inspectors also 19 reviewed the licensee's corrective actions for temporary modification related issues documented in selected condition reports. The condition reports are specified in the list

of documents reviewed. The inspectors completed two inspection samples by reviewing

the following temporary modifications:*Install temporary power supply as a backup to power supply Item 69 in panel 1PA05J*Division III emergency diesel generator high water temperature switch

b. Findings

No findings of significance were identified.1EP4Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The inspectors performed a screening review of Revision 7 of the Clinton Power Station Annex to the Exelon Standardized Emergency Plan to determine whether the changes

made in Revision 7 decreased the effectiveness of the licensee's emergency planning.

The screening review of this revision did not constitute an approval of the changes and, as such, the changes are subject to future NRC inspection to ensure that the emergency

plan continues to meet NRC regulations.

These activities completed one inspection sample.

b. Findings

No findings of significance were identified.1EP6Drill Evaluation (71114.06)

a. Inspection Scope

The inspectors observed the emergency response activities associated with drills and focused training conducted on December 12, and 15, 2005. Specifically, the inspectors

verified that the emergency classification and simulated notifications were properly

completed, and that the licensee adequately critiqued the training. Additionally, the

inspectors observed licensee activities during the site accountability drill in the

designated assembly area at the Operational Support Center (OSC) to ensure the drill

was conducted in accordance with licensee procedures. The inspectors reviewed issue

reports generated as a result of the drill and discussed these discrepancies with the site

emergency preparedness manager. The inspectors completed two inspection samples

by observing these emergency preparedness evolutions:*Site accountability drill*Table-top drill scenarios CPS PI #'s 3 & 4

b. Findings

20 No findings of significance were identified.2.

RADIATION SAFETY

2OS1Access Control To Radiologically Significant Areas (71121.01).1Review of Licensee Performance Indicators for the Occupational Exposure Cornerstone

a. Inspection Scope

The inspectors reviewed the licensee's occupational exposure control cornerstone Performance Indicators (PIs) to determine whether or not the conditions surrounding the

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

action program for resolution. This review represented one sample.

b. Findings

No findings of significance were identified.

.2 Plant Walkdowns and Radiation Work Permit Reviews

a. Inspection Scope

The inspectors reviewed procedures and methods for controlling airborne radioactivity areas to evaluate barrier integrity and engineering controls performance (e.g., high

efficiency particulate air (HEPA) ventilation system operation) and to determine if there

was a potential for individual worker internal exposures of greater than 50 millirem

committed effective dose equivalent. There were no airborne areas created as a result

of major activities observed during the inspection. This review represented one sample.

The adequacy of the licensee's internal dose assessment process for internal exposures greater than 50 millirem committed effective dose equivalent was assessed. There were

no internal exposures greater than 50 millirem. This review represented one sample.

b. Findings

No findings of significance were identified..3Problem Identification and Resolution

a. Inspection Scope

The inspectors reviewed the licensee's self-assessments, audits, licensee event reports, and special reports related to the access control program to determine if identified

problems were entered into the corrective action program for resolution. This review

represented one sample.

The inspectors reviewed corrective action reports related to access controls and high radiation area radiological incidents (non-performance indicators identified by the 21 licensee in high radiation areas less than 1R/hr). Staff members were interviewed and corrective action documents were reviewed to determine if follow-up activities were

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

to safety and risk based on the following:*Initial problem identification, characterization, and tracking*Disposition of operability/reportability issues

  • Evaluation of safety significance/risk and priority for resolution
  • Identification of repetitive problems
  • Identification of contributing causes
  • Identification and implementation of effective corrective actions
  • Resolution of non-cited violations (NCVs) tracked in the corrective action system
  • Implementation/consideration of risk significant operational experience feedback This review represented one sample.

The inspectors evaluated the licensee's process for problem identification, characterization, and prioritization and determined if problems were entered into the

corrective action program and resolved. For repetitive deficiencies and/or significant individual deficiencies in problem identification and resolution, the inspectors determined

if the licensee's self-assessment activities were capable of identifying and addressing

these deficiencies. This review represented one sample.

The inspectors reviewed licensee documentation packages for all PI events occurring since the last inspection to determine if any of these PI events involved dose rates

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

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

personnel access. There were no PI events occurring since the last inspection. This

review represented one sample.

b. Findings

No findings of significance were identified..4Job-In-Progress Reviews

a. Inspection Scope

Radiological work in high radiation work areas having significant dose rate gradients was reviewed to evaluate the application of dosim etry to effectively monitor exposure to personnel and to verify that licensee controls were adequate. These work areas

involved areas where the dose rate gradients were severe which increased the necessity

of providing multiple dosimeters and/or enhanced job controls. This review represented

one sample.

b. Findings

No findings of significance were identified.

22.5High Risk Significant, High Dose Rate and Very High Radiation Area Controls

a. Inspection Scope

The inspectors held discussions with the radiation protection manager concerning high dose rate/high radiation area and very high radiation area controls and procedures, including procedural changes that had occurred since the last inspection, in order to

determine if any procedure modifications did not substantially reduce the effectiveness

and level of worker protection. This review represented one sample.

The inspectors discussed with Radiation Protection (RP) supervisors the controls that were in place for special areas that had the potential to become very high radiation

areas during certain plant operations, to determine if these plant operations required

communication beforehand with the RP group, so as to allow corresponding timely

actions to properly post and control the radiation hazards. This review represented one sample.The inspectors conducted plant walkdowns to evaluate the posting and locking of entrances to high dose rate and very high radiation areas. This review represented one sample.

b. Findings

No findings of significance were identified.2OS2As Low As Is Reasonably Achievable Planning And Controls (ALARA) (71121.02).1Problem Identification and Resolutions

a. Inspection Scope

The licensee's corrective action program was reviewed to determine if repetitive deficiencies in problem identification and resolution were being addressed. This review

represented one sample.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES (OA)

4OA1 Performance Indicator Verification

.1Radiation Safety Strategic Area

a. Inspection Scope

The inspectors reviewed the licensee draft data collections used to prepare submittals for two PIs. The inspectors used PI guidance and definitions contained in Nuclear 23 Energy Institute (NEI) Document 99-02, Revision 3, "Regulatory Assessment Performance Indicator Guideline," to evaluate the accuracy of the PI data. As part of the

inspection, the documents listed in Appendix 1 were utilized to evaluate the accuracy of

PI data. The inspectors' review included, but was not limited to, conditions and data

from logs, licensee event reports, condition reports, and calculations for each PI

specified.

The following PIs were reviewed:

  • Occupational Exposure Control Effectiveness, for the period of January 2005 through October 2005*RETS/ODCM Radiological Effluent Occurrence, for the period of September 2004 through July 2005

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Initial License Examination Root Cause

a. Inspection Scope

The inspectors reviewed the Clinton Power Station initial license training root cause analysis for poor performance on the NRC initial license examination conducted in

July 2005 for correct identification of the causes of initial license training applicant

performance. The inspectors compared applicant experience/background with initial

license training program admission requirements. The inspectors reviewed the training

program used to prepare the applicants for the initial operator license examination. The

inspectors reviewed applicant written examination/quiz grades and performance reviews

associated with their simulator control room integrated plant operations training. The

inspectors reviewed the results of performance review committees and performance

review boards for compliance with station procedures and initial license training program

academic requirements. The inspectors interviewed several station operations

instructors, licensed operators, operations management, and training management to

determine their understanding of program requirements, initial license training candidate

progress, and the initial license training lead instructor contribution to the program. The

inspectors reviewed the recommended corrective actions contained within the root

cause analysis for adequacy and accuracy.

b. Findings

Discussion

The inspectors determined that the root cause analysis was thorough and identified the causes of poor performance by the initial operator license applicants. The

inspectors determined that the applicants met all entrance requirements into the license

class without exception. One clarification was received from Region III to ensure one

applicant met all license requirements. The training program had been successfully 24 used to train previous license classes and the initial license training lead instructor was attempting to emulate previous successful license classes by implementing the same

schedule and program previously used. The inspectors determined that station

management had failed to adequately support an inexperienced initial license training

lead trainer during a critical portion of the license class training program. During that

time the station's training director and operation's training manager were not present at

the site to provide oversight for the initial license training program. The initial license

training lead trainer had to make several critical decisions without the guidance of an

experienced manager, and lacking experience, made decisions that resulted in a class

inadequately prepared to take the NRC's initial license examination. The initial license

training lead trainer's decisions resulted in remediation training not being completed in a

timely manner with a resultant inadequate knowledge base upon which the applicants

could build additional knowledge. Because of the lack of management supervision and

initial license training lead trainer inexperience, inadequate documentation was provided

to performance review boards to have applicants removed from the initial license training

program. The inspectors noted that comments concerning the operational relevance of

some of the written examination questions during the station's internal review were

dismissed without adequate follow-up on the part of the examination author and others

on the examination security agreement. The inspectors determined that the root cause

analysis had discovered the failure causes for the poor performance and made accurate

recommendations for corrective actions to prevent recurrence of the poor performance

issues. The inspectors determined that if the recommended corrective actions are fully

implemented and maintained, a recurrence of the poor performance will be avoided.

.2 Review and Assessment of Issue Report for Trends, Rigor, and Common-Cause

Attributes

a. Inspection Scope

The inspectors noted a slight increase in the number of plant issues involving equipment reliability. Some of these issues resulted in issue reports (IR) being generated by the

licensee. The inspectors reviewed issue reports with a focus on instrument

out-of-tolerance IR with approved evaluations from January 2004 through

November 2005.

b. Findings

No findings of significance were identified. However, the inspectors noted that the licensee failed to follow and meet the intent of the instrument trending program as

described in licensee administrative procedure ER-AA-520 "Instrument Trending

Program." Specifically, the licensee engi neering staff failed to meet the management and program expectations to have the trending report and engineering analysis

completed 60 days after completion of a refueling outage. This expectation promotes a

timely review and evaluation of instrumentation issues such as suitability for application.

Timely evaluations would allow for adequate planning and work scheduling for

replacement of unreliable instrumentation.

Specifically, Section 4.4 of ER-AA-520, "instrument performance trending," stated that once per operating cycle, engineering would run a trend report on the condition report 25 database. The procedure required system managers to review the report and evaluate instruments associated with their systems. Evaluations for what should be considered

an adverse trend would be included in this report. This procedure also required that site

design engineering evaluate the trend report for indication of common mode failures

once per operating cycle and perform a drift analysis for those instruments in the

As-Found/As-Left program. The procedure directed site design engineering to update

the drift analysis for the make/model groups. Any issues identified related to common

mode failures or instrumentation issues that would affect the drift analysis required

corrective actions be created to correct the issue. As stated in ER-AA-520, this

procedure provided the administrative proce ss for the instrument trending program and it also provided control of the As-Found/As-left analysis program. This program

maintained the analysis conducted as part of the 24-month cycle extension project as

required by Generic Letter 91-04.

The licensee adopted ER-AA-520 in 2002 during Cycle 9. On November 16, 2005, inspectors requested a copy of the instrument trending program analysis completed in

accordance with ER-AA-520. The licensee had not completed a finalized trend report or

instrument analysis as directed by ER-AA-520. When questioned by the inspectors on

why this report had not been completed, the licensee stated that the instrument trend

report analysis was not completed due to poor program ownership by design

engineering management.

The inspectors' review of the corrective acti on system did not identify any evidence of an actual loss of safety function of any mitigating system due to an out-of-tolerance

instrumentation issue. The ninth refueling cycle ended February 2004, and the tenth

refueling cycle will end on January 30, 2006. Therefore, the licensee has until that time

to be in compliance with the procedural requirement.4OA6Meetings.1Exit Meeting The inspectors presented the inspection results to Mr. Robert Bement and other members of licensee management at the conclusion of the inspection on

January 12, 2005. The inspectors asked the licensee whether any materials examined

during the inspection should be considered proprietary. No proprietary information was

identified..2Interim Exit Meetings Interim exits were conducted for:

  • Emergency Preparedness inspection with Mr. M. Friedman on December 1, 2005
  • Biennial Operator Requalification Program Inspection with Mr. R. Bement, Clinton Power Station Site Vice President, on November 23, 2005.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

R. Bement, Site Vice President
M. McDowell, Plant Manager
J. Cunningham, Work Management Director
R. Davis, Radiation Protection Director
R. Frantz, Regulatory Assurance Representative
M. Friedman, Emergency Preparedness Manager
M. Hiter, Access Control Supervisor
W. Iliff, Regulatory Assurance Director
C. VanDenburgh, Nuclear Oversight Manager
J. Domitrovich, Maintenance Director
D. Schavey, Operations Director
J. Madden, Chemistry Manager
C. Williamson, Security Manager
R. Peak, Site Engineering Director
W. Carsky, Shift Operations Superintendent
M. Baetz, Licensed Operator Requalification Training Group Lead
J. Lindsey, Training Director
A. Bailey, Operations Training Manager

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

05000461/2005009-01NCVFailure to provide adequate maintenance and work

instruction is a performance deficiency05000461/2005009-02NCVFailure to correctly identify and correct the cause of

the 2005 125 VDC circuit failure was a performance

deficiency

Closed

05000461/2005009-01NCVFailure to provide adequate maintenance and work

instruction is a performance deficiency05000461/2005009-02NCVFailure to correctly identify and correct the cause of

the 2005 125 VDC circuit failure was a performance

deficiency

Discussed NONE

LIST OF DOCUMENTS REVIEWED