IR 05000461/2009006
Download: ML090760965
Text
March 17, 2009
Mr. Charles Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Road Warrenville IL 60555
SUBJECT: CLINTON POWER STATION, EVALUATION OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000461/2009006(DRS)
Dear Mr. Pardee:
On February 13, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications Inspection at your Clinton Power Station. The enclosed report documents the inspection results, which were discussed on February 13, 2009, with Mr. F. A. Kearney and other members of your staff. This inspection examined activities conducted under your license as they relate to safety and to compliance with the 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, no findings of significance were identified. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/ Robert Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-461 License No. NPF-62
Enclosure:
Inspection Report No. 05000461/2009006(DRS)
w/Attachment:
Supplemental Information DISTRIBUTION: See next page Letter to Mr. Charles Pardee from Mr. Robert Daley dated March 17, 2009.
SUBJECT: CLINTON POWER STATION, EVALUATIONS OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000461/2009006 (DRS) cc w/encl: Site Vice President - Clinton Power Station Plant Manager - Clinton Power Station Manager Regulatory Assurance - Clinton Power Station Senior Vice President - Midwest Operations Senior Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director - Licensing and Regulatory Affairs Manager Licensing - Clinton, Dresden and Quad Cities Associate General Counsel Document Control Desk - Licensing Assistant Attorney General J. Klinger, State Liaison Officer, Illinois Emergency Management Agency Chairman, Illinois Commerce Commission Letter to Mr. Charles Pardee from Mr. Robert Daley dated March 17, 2009.
SUBJECT: CLINTON POWER STATION, EVALUATIONS OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000461/2009006(DRS) cc w/encl: Site Vice President - Clinton Power Station Plant Manager - Clinton Power Station Manager Regulatory Assurance - Clinton Power Station Senior Vice President - Midwest Operations Senior Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director - Licensing and Regulatory Affairs Manager Licensing - Clinton, Dresden and Quad Cities Associate General Counsel Document Control Desk - Licensing Assistant Attorney General J. Klinger, State Liaison Officer, Illinois Emergency Management Agency Chairman, Illinois Commerce Commission DISTRIBUTION: Tamara Bloomer RidsNrrDorlLpl3-2 RidsNrrPMClinton Resource RidsNrrDirsIrib Resource Mark Satorius Kenneth OBrien Jared Heck Allan Barker Carole Ariano Linda Linn DRSIII DRPIII Patricia Buckley Tammy Tomczak ROPreports@nrc.gov DOCUMENT NAME:G:\DRS\Work in Progress\CLINTON 2009-006 DRS AKD.doc Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII NAME ADahbur:ls RDaley DATE 03/05/09 03/17/09 OFFICIAL RECORD COPY U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-461 License No: NPF-62 Report No: 05000461/2009006(DRS)
Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station Location: Clinton, IL Dates: January 26, 2009 through February 13, 2009 Inspectors: Alan Dahbur, Senior Reactor Inspector (Lead) Caroline Acosta, Senior Reactor Inspector George M. Hausman, Senior Reactor Inspector Observer: Jasmine Gilliam, Reactor Engineer Approved by: R. Daley, Chief Engineering Branch 3 Division of Reactor Safety (DRS)Enclosure
SUMMARY OF FINDINGS
IR 05000461/2009006 (DRS); 01/26/2009 - 02/13/2009; Clinton Power Station; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications. This report covers a two-week announced baseline inspection on Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications. The inspection was conducted by Region III based engineering inspectors. Based on the results of this inspection, no findings of significance 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 4, dated December 2006.
A. NRC-Identified
and Self-Revealed Findings
===Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity No findings of significance were identified.
B. Licensee-Identified Violations
No findings of significance were identified.===
2
REPORT DETAILS
REACTOR SAFETY
Cornerstone:
Initiating Events, Mitigating Systems, and Barrier Integrity
1R17 Evaluation of Changes, Tests, or Experiments and Permanent Plant Modifications
.1 Evaluation of Changes, Tests, or Experiments
a. Inspection Scope
From January 26, 2009 through February 13, 2009, the inspectors reviewed two safety evaluations (SEs) performed pursuant to 10 CFR 50.59 to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 15 screenings and two equivalency evaluations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:
- the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;
- the safety issue requiring the change, tests or experiment was resolved;
- the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and
- the design and licensing basis documentation was updated to reflect the change. The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, "Guidelines for 10 CFR 50.59 Implementation," Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments." This inspection constituted two samples of evaluations and 17 samples of changes as defined in IP 71111.17-04.
b. Findings
No findings of significance were identified.
.2 Permanent Plant Modifications
a. Inspection Scope
From January 26, 2009 through February 13, 2009, the inspectors reviewed 13 permanent plant modifications that had been installed in the plant during the last three years. This review included in-plant walkdowns for portions of the modified Emergency Diesel Generator Exhaust System and Emergency Diesel Generator Fuel Oil Day Tank System. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:
- the supporting design and licensing basis documentation was updated;
- the changes were in accordance with the specified design requirements;
- the procedures and training plans affected by the modification have been adequately updated;
- the test documentation as required by the applicable test programs has been updated; and
- post-modification testing adequately verified system operability and/or functionality. The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an attachment to this report. This inspection constituted 13 permanent plant modification samples as defined in IP 71111.17-04.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
.1 Routine Review of Condition Reports
a. Inspection Scope
From January 26, 2009 through February 13, 2009, the inspectors reviewed Corrective Action Process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent pant modifications and evaluations for changes, tests, or experiments issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report. Enclosure 3
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1 Exit Meeting Summary
On February 13, 2009, the inspectors presented the inspection results to Mr. F. A. Kearney, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- F. A. Kearney, Site Vice President
- M. E. Kanavos, Plant Manager
- R. D. Weber, Site Engineering Director
- J. D. Ellis, Work Management Director
- J. T. Conner, Operation Director
- C. VanDenburgh, Nuclear Oversight Manager
- D. J. Kemper, Regulatory Assurance Manager
- J. M. Stovall, Radiation Protection Manager
- J. W. Rappeport, Chemistry Manager
- C. S. Williamson, Security Manager
- R. A. Schenck, Manager Site Project Manager
- B. D. Bunte, Sr. Manager Design Engineering
- R. S. Frantz, Regulatory Assurance Representative
- M. Hager, Engineering
- J. Wilcox, Engineering
- N. Evans, Engineering Nuclear Regulatory Commission
- C. Kemker, Senior Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED Opened, Closed, and Discussed None Attachment 1
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
- Inclusion of a document on this list does not imply NRC
acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
- 10
- CFR 50.59 EVALUATIONS Number Description or Title Date or Revision
- CL-2007-E-005 Application of TRACG04 for Stability Analysis December 12, 2007CL-2007-E-012 SF and RH Modes for Refueling Cavity Fill April 05, 2007
- 10
- CFR 50.59 SCREENINGS Number Description or Title Date or Revision
- CL-2006-S-035 Revise the RCIC High Steam Flow Isolation Time Delay Revision 0
- CL-2006-S-041 Control Room HVAC Supply Fan B
(0VC03CB) and Motor Replacement Revision 0
- CL-2007-S-014 Disconnect Leads for Circuit Breaker 252-AT1AA1 Relay 74-AT1AA1 to Bypass Alarm to Window 1D on MCR
- Panel 1H13-P877-14A Revision 0
- CL-2007-S-015 RC & IS - Disconnect SOLA Transformers to the Branch Junction Modules (BJMs) and Convert the
- 20Vac UPS Power Supply to the Rod Gang Panel from Dual Fuse to the Original Single Fuse Configuration (EC363051) Revision 0
- CL-2007-S-019 Bypass Limit Switch Contacts of RCIC Steam Line Outboard Isolation Valve 1E51-F064 (EC365827) Revision 0
- CL-2007-S-022 Relocate Testing Requirements from
- ORM 2.1.2 to USAR 4.6.3.1.1.5 Revision 1
- CL-2007-S-023 Compensatory Measure #1 of Operability Evaluation #629127-02 and revision to
- CPS 9080.01, 02 & 03, D001, 002, & 003. Revision 0
- CL-2007-S-026 Revise TS Bases B 3.5.3, RCIC System, Applicable Safety Analyses Revision 1
- CL-2007-S-053 Revise Rod Block Testing Requirements Revision 1 Attachment 2
- CFR 50.59 SCREENINGS Number Description or Title Date or Revision TR 4.2.1.1, TR 4.2.3.1, and TR 4.2.5.1 in the Operational Requirements Manual (ORM)
- CL-2008-S-011 Address Concern with location of DIV 3 DG Grounding Resistor Revision 0
- CL-2008-S-018 Add a Justification on How Penetration
- GDC 56 Revision 0
- CL-2008-S-022 Add Time Delay Relays and Replace Control Switches to IA System Containment Isolation Valves Logic to Prevent Inadvertent Scram on Momentary Loss of Power to Valve Solenoids (EC331623) Revision 0
- CL-2008-S-028 Change in SX System Conditions with Freeze Seals in Place/EC372215 R/0 Revision 0
- CL-2008-S-029 Bypass the Remote Control and Indication of the Steam Jet Air Ejector 1B Valve (1B21-F304B) Revision 0
- MODIFICATIONS Number Description or Title Date or RevisionEC
- 358900 Division 1 SX Water Hammer Vacuum Breakers for VX Revision 04
- EC 359920 Replacement for
- CVE-1 Relays in Safety Switchgears Revision 0
- Pump Motor Revision 0
- EC 361378 Replace WS Relief Valve 1WS167A with Higher Setpoint Revision 0
- DIV I, II, and III Revision 1
- EC 331623 Add Time Delay Relays and Replace Control Switches to IA System Containment Isolation Valves Logic to Prevent Inadvertent Scram on Momentary Loss of Power to Valve Solenoids
(CL-2008-S-022) Revision 0
- EC 358492 Provide Specific Details for Replacement of the Bucket in MCC A, 1AP29E Cub 2A, SSW System 1A Isolation Valve 1SX014A, with a Spectrum Bucket in Support of
- EC 330624 (N/A) Revision 0
- EC 363051 RC & IS Reliability Single Fuse & SOLA
- Transformer Retirement (CL-2007-S-015) Revision 0 Attachment 3
- MODIFICATIONS Number Description or Title Date or RevisionEC
- 365827 Bypass Limit Switch Contacts of RCIC Steam Line Outboard Isolation Valve 1E51-F064 (T-Mod) (CL-2007-S-019) Revision 0
- EC 366719 Provide Alternate Design for Replacing the ITE/Gould Type J10 Relays Installed in the
- MCCs 0AP56E, 0AP57E, 1AP95E and 1AP96E Located in the Harsh Environmental Zones (N/A) Revision 0
(Replacement for ITE J10 & J13 Relays) (Ref:
- Nutherm Test Report
- EGC-9785R, Rev. 1)
(N/A) Revision 0
- EC 382198 Determine If Alternate GE CR120BD Relay Contact Chatter Is Acceptable for Unit Substation 1A &1B Applications and Determine If Any Calculations are Impacted Revision 0
- ITEM EQUIVALENCY EVALUATIONS Number Description or Title Date or Revision Evaluation
- 57906 Item Equivalency Evaluation for the
- GE CR120BD04341 Relay, Cat.
- ID 1423706-1 Revision 0 Evaluation 54017 Item Equivalency Evaluation for a Temperature Switch Catalog
- ID 1415242-1 Revision 0
- CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION Number Description or Title Date or RevisionIR
- 00870983 10
- CFR 50.59 Screening Could not Be readily Retrieved January 23, 2009IR
- 00873987 Procedure 5286 Not Revised for DG Day Tank 1C Low Alarm CHG January 30, 2009IR
- 00874061 NRC Question Regarding 50.59 Screening for
- ORM Change January 30, 2009IR
- IR 00879332 Weakness Identified in 10
- CFR 50.59 Screening Document February 11, 2009IR
- 00879750 NRC MOD & 50.59 Inspection Identified
- 00880020 Weakness Identified in 10CFR50.59
- Screening Document February 12, 2009
- IR 00878838 Typing Error in
- EC 366719 February 10, 2009Attachment 4
- CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION Number Description or Title Date or RevisionIR
- 00879377 2009-50.59 Insp. - NRC ID'D Vague EQ App Statement February 11, 2009 CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
- IR 00531090 Clarify Tech Spec Bases for LCO 3.5.3 "RCIC" September 14,2006IR
- 00588586 USAR Description Incorrect for Containment Penetration February 07, 2007
- IR 00629127 CDBI FASA DG Day Tank Discrepancies on
- CALC-IP-C-0111 & SAR May 14, 2007
- IR 00669650 Errors Found in New S&L CALC Rev. for
- DO Day Tank Setpoint September 10, 2007IR
- 00695303 CDBI Potential Common Mode Design Deficiency of Diesel Gen November 6, 2007
- IR 00697048 CDBI- Div 3 DG Grounding Resistor Housing is not Ventilated November 09, 2007IR
- 00736316
- IR 00778187 1SX70A Near Code Required Minimum May 21, 2008
- IR 00870918 QRT Review Identifies Weakness in 10
- CFR 50.59 Screening Documents
- January 23, 2009
- IR 00627562 Abnormal Voltage Indicated During Surveillance May 10, 2007
- DRAWINGS Number Description or Title Date or Revision M05-1060 P&ID Suppression Pool Clean-up and Transfer (SF) Sht. 1 X M05-1035 Diesel Gen Aux System (DG) Starting Air Exhaust & Combustion Sys AE M05-1052 Shutdown Service Water (SX), Sht. 004 V M05-1056 Plant Service Water (WS) AH
- PROCEDURES Number Description or Title Date or Revision
- CPS 3810.01 Diesel Generator Fuel Oil Transfer Pump Operability Revision 1e
- CPS 9080.03 Diesel Generator 1C Operability- Manual and Quick Start Operability Revision 29a
- CPS 5286 Low Fuel Level (Day Tank or Storage Tank) Revision 27f Attachment 5
- PROCEDURES Number Description or Title Date or Revision
- CPS 9861.05 Water Local Leak Rate Testing Revision 24e
- CPS 9430.30 NSPS Untested Islands/ Calibration 1-999 Second Time Delay Revision
- 38
- CC-AA-403 Maintenance Specification: Selection and Control of Freeze Seal Location Revision 5
- CPS 4007.03 Rod Drop Revision 8d
- CPS 4301.01 Earthquake Revision 13c
- CPS 4304.01 Flooding Revision 4e
- OPERABILITY EVALUATIONS Number Description or Title Date or Revision
- 629127-02 Operability Evaluation for Day Tank
(1DG01KA, 1DG01KB and 1DG01KC) Revision 1
- OTHER DOCUMENTS/REFERENCES Number Description or Title Date or Revision
- EQ-CL023 Checklist for Environmental Qualification for Mechanical and Electrical Equipment June 30, 2008
- EGC-9785R Nutherm Qualification Report on General Electric Auxiliary Relay Type CR120B & CR120BD
- October 28, 2005
- DC-DG-01-CP Diesel Generators Design Criteria Revision 8
- WO 01104865 Work Document - OP PMT
- Perform
- CPS 9861.09D011 September 25, 2008Calculation 85-479 Diesel Exhaust Rupture Disc 0A
- Attachment 6
- 7
LIST OF ACRONYMS
- USED [[]]
ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations
CNO Chief Nuclear Officer
DRS Division of Reactor Safety
EC Engineering Change
- PA [[]]
RS Public Available Records System