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Safety Insp Rept 50-461/86-10 on 860127-31 & 0203-07.No Violations,Deviations or Safety Significant Issues Noted. Major Areas Inspected:Tmi Action Plan Requirements & Action on Previous Insp Findings
	ML20214E318
Person / Time
Site:	Clinton
Issue date:	03/03/1986
From:	Gwynn T, Scheibelhut C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20214E301	List: IR 05000461/1986010; ML20214E299;
References
	RTR-NUREG-0737, RTR-NUREG-737, TASK-***, TASK-TM 50-461-86-10, NUDOCS 8603070258
	Download: ML20214E318 (9)
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a U.S. NUCLEAR REGULATORY COMMISSION

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Report No. 50-461/86010(DRP)

Docket No. 50-461 License No. CPPR-137 Licensee:

Illinois Power Company 500 South 27th Street

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Decatur,.IL. 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Cond ted: Jan ary 27-31 and February 3-7, 1986 r

Inspector:

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Approved By:

T. P. Gwynn, Chie M4N41 M86 Reactor Projects Section IB Date

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Inspection Summary Inspection on January 27-31 and February 3-7, 1986 (Report No. 50-461/86010(DRP))

Areas Inspected: Routine safety inspection by a Regional Inspector of applicant actions on previous inspection findings and evaluation of applicant action with regard to Three Mile Island action plan requirements. This inspection involved a total of 72 inspector-hours onsite by one NRC inspector and includes 0 inspector-hours during off-shifts.

Results: Of the two areas inspected no violations, deviations or safety significant issues were identified.

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DETAILS 1.

Persons Contacted Illinois Power Company (IP)

K. A. Baker, Supervisor', Inspection and Enforc'ement Interface

J. G. Cook, Assistant Manager, Clinton Power Station

E. J. Corrigan, Director, Quality Engineering and Verification

W. C. Gerstner, Executive Vice President

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P. Hall, Vice President, Nuclear

E. W. Kant, Assistant Manager, Nuclear Station Engineering

J. E. Loomis, Construction Manager

J. A. Miller, Director, Startup Programs

J. S. Perry, Manager, Nuclear Program Coordination

R. F. Schaller, Director, Nuclear Training

F. A. Spangenberg, Manager, Licensing and Safety

J. W. Wilson, Manager, Clinton Power Station Baldwin Associates (BA)

J. L. Thompson, Manager, Quality Engineering WIPC0/Soyland Power

J. Greenwood, Manager, Power Supply

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Denotes those attending the exit meeting.

The inspector also contacted others of the construction project and operations staff.

2.

Safety Evaluation Report Follow-Up Inspection Items (92701)

The Office of Nuclear Reactor Regulation (NRR) requested that Region III confirm that the applicant has acceptably implemented certain confirmatory issues as described in the Safety Evaluation Report (SER) for the Clinton Power Station (NUREG-0853) with Supplements 1 through 4).

In Inspection Reports No. 50-461/85005 and No. 50-461/85015, these items were listed as Open Items and entered into the Region III tracking system for future inspection. Reported below are the results of the inspection of certain of the items.

a.

(0 pen) Open Item (461/85015-06):

"SER, Paragraph 13.6 - Verify Nuclear Steam Supply System vendor review of low power testing, power ascension, and emergency operating procedures is complete prior to fuel load."'

In Paragraph 3.j of this report, the inspector determined that the vendor had reviewed the low power testing procedures. The inspector reviewed General Electric Company (GE) letters IP-2464, dated

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October 30, 1984, and IP-2501, dated December 20, 1984. These letters transmitted GE's comments on the Clinton emergency operating procedures.

The inspector must determine if GE has reviewed the power ascension procedures. Therefore this item remained open.

b.

(Cicsed) Open Item (461/85005-42):

"SSER2, Paragraph 7.5.3.5 -

Verify that modifications to satisfy the applicant's commitments related to TMI Item II.K.3.27 have been made."

The inspector verified that these modifications were made.

See Paragraph 3.w of this report.

No violations or deviations were identified.

3.

Evaluation of Applicant Action with Regard to Three Mile Island (TMI)

Action plan Requirements (25401)

The NRC Office of Inspection and Enforcement issued Temporary Instruction (TI) 2514/01, Revision 2, dated December 15, 1980, to supplement the Inspection and Enforcement Manual. The TI provides TMI-related inspection requirements for operating license applicants during the phase between prelicensing and licensing for full power operation.

It is divided into two parts. Part I lists requirements that must be closed prior to fuel load.

Part 2 lists requirements that must be closed prior to full power operation. Part I of the T1 was used as the basis for inspection of the following TMI items found in NUREG-0737, " Clarification of TMI Action Plan Requirements."

a.

(0 pen) Item I.A.1.1:

" Shift Technical Advisor." The applicant was to provide on-shift engineering and accident assessment advice for the shift supervisor in the form of a shift technical advisor.

In 1981, the NRC performed an extensive review of the Clinton Power Station (CPS) organizational structure and staffing plans. That review included a review of the applicant's plans for complying with the requirements of NUREG-0737.

The results of that review, as documented in NUREG-0853, Safety Evaluation Report (SER) for the CPS, indicated that the applicants plans for staffing CPS with shift technical advisors (STAS) were acceptable.

Inspection of the applicant's implementation of the commitments contained in the CPS SER was documented in Inspection Report No. 50-461/86008. That inspection identified one unresolved item concerning the qualification and training of CPS STAS. This item remains open pending resolution of that item.

b.

(Closed) Item I.A.1.2:

" Shift Supervisor Responsibilities." The applicant was to minimize the administrative responsibilities of the shift supervisor that detract from his responsibility for assuring safe operation of the plant. As delineated in Paragraph a, above, this item was closed in Section 13.1.2 of the SER.

CPS No. 1401.01, Operations Department Organization, Responsibilities and Minimum

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Qualifications, Revision 5 dated August 29, 1985, identifies the organizational structure of-the plant operations department. That organization includes a Shift Supervisor and two Assistant Shift Supervisors; a Line Assistant Shift Supervisor who is responsible for supervision of control room operations; and a Staff Assistant Shift Supervisor who is responsible for shift administrative tasks.

This is consistent with the TMI Action Plan. Observation of the present control room staff indicated that each of the five operating shifts was staffed with a Staff Assistant Shift Supervisor, c.

(Closed) Item I.A.I.3:

" Shift Manning." The applicant must meet

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the shift manning requirements for normal operation as delineated in NUREG-0737. As delineated in Paragraph a, above, this item was closed in Section 13.1.2 of the SER.

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(Closed) Item I.B.I.2:

" Independent Safety Engineering Group." The applicant was required to establish an on-site independent safety engineering group to perform independent reviews of plant operations.

The item was also tracked as Open Item 461/85016-02 that contains the same requirements as the TMI item.

Item 461/85016-02 was closed in Inspection Report No. 50-461/85035; therefore this item is also closed.

The requirements of this TMI Action Plan item were incorporated in the CPS Technical Specifications, Specification 6.2.2.1.

CPS No. 1401.03, Call-Out and Recall of. Standby Personnel, Revision 6 date'd'May 2, 1985, provides the administrative controls to implement the technical specification requirements. The inspector verified I

that this procedure was scheduled to be reviewed in detail during a routine NRC inspection. This item is closed.

(Closed) Item I.C.2: " Shift Relief and Turnover Procedures." The

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applicant was to provide a procedure that formalizes the shift turnover process with checklists and logs to be filled out by the

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outgoing shift to inform the oncoming shift of vital plant conditions.

The inspector reviewed Operating Administrative Procedure (QAP)

1401.04S, " Shift Turnover and Relief." Revision 2, dated November 8, 1982.

Included with this procedure are forms 1401.04 F001, " Shift Turnover and Relief - Status Report," 1401.04 F002, " Equipment Status Check," and 1401.04 F003, " Plant Operator Checklist." The review revealed that the procedure meets the intent of the requirement delineated in NUREG-0737.

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(Closed) Item I.C.3: " Shift Supervisor Responsibilities." The command duties, responsibilities, and authorities of the shift supervisor and the control room operators shall be clearly defined and the personnel trained in them.

This item is also an SER confirmatory item tracked as Open Item 461/85005-30.

In Inspection

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Report No. 50-461/85065 the item was reviewed by an inspector.

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While the majority of the requirements were found to be met satisfactorily, the item was left open pending resolution of some training deficiencies. Therefore, this item is considered closed

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with the training deficiencies tracked under Open Item 461/85005-30.

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(0 pen) Item I.C.4:

" Control Room Access." Control room access shall be limited to those individuals who are responsible for the direct operation of the nuclear power plant, technical advisors for operational support and predesignated NRC personnel. The applicant prepared the following procedures to cover the requirements:

1401.05, " Main Control Room - Conduct of Personnel," Revision 3, dated November 4, 1982.

1001.01, "Clinton Power Station Organization, Responsibilities and Minimum Qualifications," Revision 4, dated November 16, 1985.

The inspector's review of 1401.05 showed that Section 8.1,

" Authorization for Entry," clearly establishes the authority and responsibility for control room access.

The review of 1000.01 showed that while Section 8.4, " Succession of Station Responsibility" defined a succession of responsibility in the case of a station emergency, no succession of responsibility was delineated in the case of incapacitation of a member of the operating crew. The CPS Final Safety Analysis Report (FSAR) in Section 13.1 indicates that such a succession of responsibility will be promulgated. Therefore this item remains open until a procedure is revised to contain such a line of succession.

h.

(0 pen) Item I.C.5:

" Procedures for Feedback of Operating Experience Plant Staff." Procedures shall be established to assure that operating information pertinent to plant safety originating both within and outside the utility is continually supplied to operators and other personnel and is incorporated into training and retraining programs. To assure that operating experience is properly incorporated, the applicant prepared Licensing and Safety Procedure L.1, " Feedback Program," Revision 0, dated January 20, 1986, to assure that information originating within or outside of the utility is properly supplied to plant operators and incorporated into training programs.

The inspector reviewed Procedure L.1 and found it adequate to meet the requirements for information originating within or without the organization.

However, certain administrative procedures are necessary for implementation of L.1 with respect to information originating within the organization. The inspector found that QAP 1006.04, " Review of Operating Experiences," is scheduled to be deleted and the provisions incorporated 'into procedures 1016.01,

" CPS Condition Reports," and 1016.04, " CPS Licensee Event Reports ( LER). " Since none of these steps have been taken, the item remains open until the pertinent CPS procedures have been amended to accommodate Procedure L.1.

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(0 pen) Item I.C.6:

" Guidance on Procedures for Verifying Correct Performance of Operating Activity." Plant procedures shall be prepared to assure that an effective system of verifying the correct performance of operating activities is provided as a means of reducing human errors and improving the qualify of normal operations.

This item

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is also an SER confirmatory item tracked as Open Item 461/85005-32.

In Inspection Report No. 50-461/85032, an inspector reviewed the actions taken to close item 461/85005-32. That report indicated that the item remained open pending revision of an Operational Administrative Procedure and subsequent inspector review and a general review of operating procedures by the NRC. Therefore, this item remains open.

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(Closed) Item I.C.7:

"NSSS Vendor Review of Procedures." Low power, power ascension, and emergency procedures shall be reviewed by the reactor supplier to verify the adequacy of the procedures.

TI2514/01 requires verification of NSSS review of startup (i.e., low power) procedures prior to fuel load.

Paragraph 2.a of this report covers the vendor review of power ascension and emergency procedures.

The inspector reviewed Startup Administrative Procedure (S/P)-14,

" Test Procedure Development," Revision 4, dated December 7, 1985 and SAP-22, " Joint Test Group," Revision 1, dated October 29, 1985 and found that they contain the requirement for review of the startup procedures by the NSSS vendor, the General Electric (GE) company. A review of a number (four) of startup procedures disclosed the GE representative's signature in the " reviewed by" section on the cover page.

In an interview with the startup superintendent, it was determined that all of the startup procedures had been written by CPS personnel and reviewed by the GE representative.

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(Closed) Item II.D.1:

" Performance Testing of Relief and Safety Valves." Reactor coolant system safety and relief valves shall be given qualification testing under expected operating conditions for design basis transients and accidents.

Through the Boiling Water Reactor Owner's Group (BWROG), generic tests were performed to demonstrate the functional capability of the valves.

Plant specific conditions were calculated by the applicant to show the functional capability of the valves and associated discharge piping at CPS.

All of the results were reviewed by NRR.

Section 5.2.2 of the SER discussed the results of the testing program and plar.t specific calculations and considered them acceptable.

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(Closed) Item II.D.3: " Direct Indication of Relief Valve Position."

Reactor coolant system safety and relief valves shall be provided with a positive position indication in the control room derived from a reliable valve position detection device or a reliable indication of flow in the discharge line. The applicant has provided a diverse system by installing piezoelectric accelerometers and thermocouples on the discharge piping downstream of the valves.

Section 7.3.3.1 of the SER accepts this arrangement. The inspector verified by direct observation that the accelerometers and thermocouples were installed on the valve discharge piping. Annunciators and indicators are provided in the control room.

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(0 pen) Item II.E.4.1: " Dedicated Hydrogen Penetration." Hydrogen recombiners for postaccident use located external to the containment shall have dedicated containment penetration systems that meet the single failure requirements of General Design Criteria 54 and 56 of l

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Appendix A to 10 CFR 50. The procedures for the use of the combustible gas control system following an accident that results in a degraded core and release of radioactivity to the containment must be reviewed and revised, if necessary.

The applicant provided a redundant hydrogen recombiner system utilizing dedicated penetrations and meeting single failure criteria in the original design.

Section 6.2.7 of the SER accepted the design. The inspector verified by direct observation that the supply and return containment penetrations are dedicated to the hydrogen recombiner piping only and are located (180 apart) on the containment wall to meet single failure criteria. The hydrogen recombiners are located in separate shielded rooms for the same purpose. The inspector reviewed Operations Procedure 3316.01F, Revision 0, dated December 12, 1979, " Operation of the Hydrogen Recombiner System." The procedure was classified as " exempt" which indicates that it is not subject to periodic review or revision.

This item remains open until the hydrogen recombiner procedures are revised and the procedures reviewed by the inspector, n.

(Closed) Item II.F.2:

" Inadequate Core Cooling Instruments."

Applicants shall provide a description of any additional instrumentation or controls proposed for the plant to supplement existing instrumentation in order to provide an unambiguous, easy to interpret indication of inadequate core cooling.

The BWROG generic evaluation of this item indicated that no additional instrumentation beyond the existing water level instrumentation was necessary to accomplish the intent of this item. Section 4.4.2 of Supplemant 4 to the SER agreed with this position. Therefore additional instrumentation or controls are not necessary at CPS.

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(0 pen) Item II.K.1.5:

" Safety-Related Valve Position." This item is a subset of the requirements set forth in Item I.C.6 (see Paragraph 1, above).

It remains open until I.C.6 is closed.

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(0 pen) I+.em II.K.1.10:

" Operability Status." This item is a subset of the requirements set forth in Item I.C.6 (see Paragraph 1, above).

It remains open until I.C.6 is closed.

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(Closed) Item II.K.1.22:

" Auxiliary Heat Removal Procedures." For boiling water reactors, the automatic and manual actions for proper functioning of auxiliary heat removal systems when the feedwater system is not operable should be described.

Tne applicant provided this information in the FSAR. Section 5.4.2 of the SER sets forth NRR's acceptance of the information.

r.V (Closed) Item II.K.1.23:

" Reactor Vessel Level Instrumentation."

For boiling water reactors, all uses and types of reactor vessel level indication for both automatic and manual initiation of safety systems should be described.

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The applicant provided this information in the FSAR.

Section 7.3.2.2 of the SER sets forth NRR's acceptance of the information. Also, refer to Item II.F.2 described in Paragraph n, above.

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(Closed) Item II.K.3.13b:

" Automatic Restart of the RCIC System on Low Reactor Water Level." The RCIC system shall be modified to automatically restart on low reactor water level af ter tripping from a high reactor water level. This item is identical to SER confirmatory item 85005-06.

Since 85005-06 was closed in Inspection Report No. 50-461/85065, this item is also closed.

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(Closed) Item II.K.3.15:

" Modify Break Detection Logic to Prevent Spurious Isolation of RCIC." This item is identical to SER confirmatory item 85005-07.

Since 85005-07 was closed in Inspection Report No. 50-461/85065, this item is also closed, u.

(Closed) Item II.K.

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" Automatic Switchover of RCIC Suetions."

The RCIC system suction shall switch automatically from the RCIC tank to the suppression pool upon low RCIC tank level.

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This feature was part of the original design as described in the CPS FSAR.

Section 5.4.1 of the SER indicated acceptance of the design. The inspector reviewed preoperational test procedure (PTP)-RI-01, Reactor Core Isolation Cooling System, Revision 0 dated April 29, 1983.

PTP-RI-01 tests the proper function of the

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l automatic RCIC suction switchover logic.

That logic test was scheduled for performance in late February 1986.

The inspector verified that the routine NRC inspection program includes witnessing of this test performance and verification of test results.

(Closed) Item II.K.3.24:

" Adequacy of Space Cooling for HPCS and

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l RCIC Systems." Long-term operation of the RCIC and HPCS systems may l

require space cooling to maintain the pump-room temperatures within allowable limits. Applicants should verify the acceptability of the consequences of a complete loss of alternating-current power.

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RCIC and HPCS systems should be designed to withstand a complete l

loss of offsite alternating-current power to their support systems,

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including coolers, for at least two hours.

l The applicant's original design provided space cooling and support

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system power supplies from dedicated onsite emergency power sources (emergency diesel generators and batteries). That design was reviewed and accepted by the NRC in the CPS SER, Section 9.4.5.

The inspector verified by direct observation that a sample of the space cooling and support systems for the RCIC and HPCS systems were l

provided power from dedicated onsite emergency power sources.

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(Closed) Item II.K.3.27:

" Provide Common Reference Level for Vessel Level Instrumentation." All reactor pressure vessel level

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instrumentation should be referenced to the same point.

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The applicant modified his scheme to use a point 15 inches above the bottom of the steam dryer skirt as the common reference point for level measurement instrumentation. The fuel zone instruments which reference the top of the active fuel have dual scales with the other scale based on the common reference level. Section 7.5.3.5 of Supplement 2 of the SER found this an acceptable response of the requirement.

The inspector visited the control room and determined that the readouts of the level measurement instrumentation were in accordance with the FSAR.

No violations or deviations were identified.

4.

Exit Interview The inspector met with the resident inspector and applicant representatives (denoted in Paragraph 1) at the conclusion of the inspection on February 7, 1986. The resident inspector summarized the. scope and findings of the inspection. The applicant acknowledged the inspector's findings.

The applicant did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.

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IR 05000461/1986010

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