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 | | author name = Ring M | ||
| author affiliation = NRC/RGN-III/DRP/RPB1 | | author affiliation = NRC/RGN-III/DRP/RPB1 | ||
| addressee name = Crane C | | 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 | ||
Mr. Christopher President and Chief Nuclear Officer | |||
Exelon Nuclear | Exelon Nuclear | ||
| Line 29: | Line 26: | ||
4300 Winfield Road | 4300 Winfield Road | ||
Warrenville, IL | Warrenville, IL 60555SUBJECT: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- | 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 | |||
Inspection Report No. 05000461/2005009 | |||
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=== | ||
05000461/2005009-01NCVFailure to provide adequate maintenance and work | |||
instruction is a performance | instruction is a performance deficiency05000461/2005009-02NCVFailure 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 | |||
==LIST OF DOCUMENTS REVIEWED== | ==LIST OF DOCUMENTS REVIEWED== | ||
}} | }} | ||
Revision as of 00:07, 14 July 2019
| ML060310367 | |
| Person / Time | |
|---|---|
| Site: | Clinton |
| 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
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
- (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
- 1G33-D001 reactor water cleanup orifice letdown to main condenser
- 1B21-F437A steam jet air ejector 1A steam inlet control valve bypass
- 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 9053.01C001 "Residual Heat Removal Loop A Valve Operability"
- 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
- 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