IR 05000461/1987006
| ML20212G645 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/27/1987 |
| From: | Hare E, Hasse R, Hopkins J, Little B, Love R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212G609 | List: |
| References | |
| 50-461-87-06, 50-461-87-6, NUDOCS 8703050384 | |
| Download: ML20212G645 (12) | |
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U.S. NUCLEAR REGULATORY COMISSION
REGION III
Report so. 50-461/87006(DRS)
Docket ha. 50-461 License No. NPF-55 Licenset:
Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facili:. Name:
Clinton Nuclear Power Station, Unit 1
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Insper:'on At:
Clinton Site, Clinton, Illin is Inspe::"on Conducted: January 26 through February 3, 1987 27/[7 Inspe:::*s:
R.
. Hasse
[J7//J R. S. Lovp.
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Date 27/87 B.
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Date adL&a C
NNf0 E. A.
are Date d /@
J[A. Hopkins 37/~<A f 7 l
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1/6
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b7M7 Apprci+: By:
M. P. Phillias, Chief Operational )rogram Section Date Accongrying Pers:,nel:
W. G. Kennedy, NRR l
P. C. Goodman, NRR l
l Inspe:: ion Summary Inspe:: ion on January 26 through February 3. 1987 (Report No. be-461/8/006(DR5))
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Areas Inspected:
Special announced safety inspection to determine if Emergency operating Procedures (E0Ps) were prepared and validated in accordance with the approved Procedures Generation Package, to follow up on previous NRC inspection findings in this area, and to follow up on an allegation in the area of plant modifications.
The Emergency Operating Procedures inspection was conducted in accordance with IE Temporary Instruction TI 2515/79.
Results: Two violations were identified with examples of each:
(1)_ violation of Technical Specification 6.8.1.b - failure to establish, implement, and-maintain E0Ps in accordance with Technical Guidelines or Procedure Writers Guide (Paragraph 4.b.(3)); (2) failure to identify the cause of conditions adverse to quality and effect corrective action - allegation follow up (Paragraph 2) and failure to correct identified E0P validation de'iciencies (Paragraph 4.b.(3)).
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DETAILS 1.
Persons Contacted Illinois Power Company (IP)
- T. Riley, Licensing and Safety
- J. Hall, Plant Technical G. Lakach, Licensing and Safety T. Warnick, Licensing and Safety
- K. Baker, Licensing and Safety
- J. Wilson, Manager, CPS
- R. Morgenstern, Director, Plant Technical
- F. Spangenberg,isor,ger, tenance PlanningLicensing and Safety Mana R. Hoem, Superv Main W. Donovan, Compliance Specialist U.S. NRC P. Gwynn, SRI, CPS
- P. Hiland, RI, CPS
- W. Kennedy, NRR
- P.
Goodman NRR
- C.Paperiello,ief,ProjectsBranch1 Acting Deputy Regional Administrator, RIII
- R.Warnick,ief,Section1B,DRP,RIII Ch RIII
- R.
Knop, Ch
- T. Burdick,ief, Operations Branch, RIIIChief, Operator Licensing Section, RIII
- C. Hehl, Ch Other personnel were contacted as a matter of routine during the inspection.
- Participated in the exit interview held by telecon on February 3, 1987.
2.
Followup on Allegation (Closed) Allegation (RIII-86-A-0197):
Inadequate review of plant modifications for impact on surveillance procedures. An individual contacted the NRC and stated that:
(1), plant modifications IS-7 and tation (C&I) surveillance procedures, (2) pact on Controls and Instrumen-the IA-12 were not adequately reviewed for im feedback mechanism to the organization responsible for the preparation of C&Isurveillanceprocedures,and(3)aConditionReport(CR 1-86-10-169)
identifying this problem had been invalidated on a questionable basis.
The inspector determined that these statements were valid.
The CPS modification program requires that any impact on surveillance procedures resulting from a modification be identified on a " Detailed Impact Assessment Form." This form is the mechanism for identifying items requiring completion arior to releasing a modification for operations and modification closure.
T1e inspector reviewed the " Detailed Impact Assessment Forms" for modifications IS-7 (addressing the original modification package and
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threesupplements)andIA-12.
None of the forms identified any impact on C&I surveillance procedures.
Further, the inspector verified that seven procedures had been impacted (identified in Condition Report CR 1-86-10-169)
and one new surveillance procedure (CPS No. 9456.04) was required to be generated (identified in the allegation).
Discussions with Maintenance Department personnel indicated that the Detailed Impact Assessment Forms were not normally routed to C&I personnel (part of the Maintenance Department)' and impacts on C&I surveillance procedures could " fall through the crack.
This situation was being corrected.
The inspector reviewed CR 1-86-10-169 to determine if it had been properly dispositioned.
As noted above, the CR identified seven C&I surveillance procedures that had been impacted by modifications IS-7 and IA-12 but were not identified by the impact assessments performed for these modifications.
The CR had been invalidated on the basis that the modifications were still open and since operations knew what procedures needed to be modified, no program violation had occurred.
In fact, a program violation had occurred since procedure CPS 1003.01 " Design Control and Modifications" requires in Sections 8.1.3.5 and 8.2.3.5 that impacted procedures be identified on the
" Impact Assessment Forms." The disposition of the CR failed to determine why (root cause) the impact assessments failed to identify the impacted groceduresoreffectanycorrectiveactionasrequiredbyCPS 1016.01, Condition Reports." CPS No. 1016.01 requires that the root cause of the condition be identified and corrective action taken to preclude recurrence.
The failure to determine the cause of this condition adverse to quality and effect corrective action is considered a violation of 10 CFR Part 50 Appendix B, Criterion XVI, which requires that for significant conditions adverse to quality, the root cause be determined and corrective action takentoprecluderecurrence(461/87006-01A).
3.
Followup on Previous Inspection Findings (Closed)UnresolvedItem(461/86072-04):
Problems identified during the reviewofEmergencyOperatingProcedures(EOP).
This item was opened in Inspection Report 50-461/86072 as the result of an earlier inspection of E0Ps by the resident inspector.
The concerns identified in this unresolved item have been included in new items opened in this report and unresolved item (461/86072-04) is considered closed.
The disposition of the specific concerns are as follows:
Required operator actions not included in referenced document -
Violation (461/87006-02).
E0Ps were not prepared per the Plant-specific Writers Guide (P-SWG) -
Violation (461/87006-02).
Inconsistent use of flow charts - Unresolved Item (461/87006-04).
- Corrective action plan for CR 1-85-11-107 - Violation (461/87006-018).
- Lack of reference section in E0Ps - Unresolved Item (461/87006-04).
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4.
Emergency Operating Procedures
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EmergencyOperatingProcedures(EOPs)haveundergonesignificantchanges as a result of the 1979 accident at the Three Mile Island facility.
The new E0Ps are. required to be symptom oriented rather than event oriented.
Generic Letter 82-33, " Requirements ~For Emergency Response Capability" (Supplement 1 to NUREG-0737) required all licensees and applicants to submit to the NRC for approval a Procedure Generation Package (PGP)
describing their plan for developing the upgraded E0Ps.
The PGP consists of four parts:
Plant-specific Technical Guideline (P-STG)~- the technical basis for
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the new E0Ps Plant-specific Writers Guide (P-SWG) - the details of the s)ecific-
methods to be used by the licensee in preparing)the E0Ps (Tie P-SWG is entitled Emergency Procedure Guidelines (EPG byCPS.)
A description of the program for verification and validation (V&V)
of the E0Ps'
A description of the program for training operators on the E0Ps
The )urpose of this inspection was to determine if the licensee's E0Ps had aeen prepared and validated in accordance with their NRC approved PGP. This was accomplished by a detailed comparison of a sample of E0Ps against the approved PGP.
a.
Documents Reviewed The following documents were reviewed during this inspection:
(1) CPS No. 1005.01, " Preparation, Review, Approval, and Implementation of and Adherence to Station Procedures and Documents," Revision 20.
(2) CPS No. 1450.00, " CPS Emergency Procedure Guidelines,"
Revision 1.
(3) CPS No. 4401.01, " Level Control Emergency," Revision 7.
(4) CPS No. 4402.01, " Containment Control Emergency," Revision 5.
(5) CPS No. 4403.01, "Cooldown Emergency," Revision 4.
(6) CPS No. 4404.01, " Reactivity Control Emergency," Revision 3.
(7) CPS No. 4406.01, " Secondary Containment / Radioactivity Release Control Emergency," Revision 2.
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' Inspection Results The inspectors 1 determined that the 1icensee's E0Ps were not.
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Specifically, differences between the P-STG and the E0Ps were Lidentifiedthathad~no'documentedjustification,theE0Pswerenot
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.and revisions to the EOPs were not always validated in-accordance w list of specific examples.of all-identified-deficiencies is included as an-appendix to.this-report.
The resultant concerns are discussed-in the following paragraphs:
Plant' Specific Technical Guidelines (1)
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The P-STG provides the controlled technical basis for the E0Ps-and the E0Ps should be consistent with that basis.
If a licensee basedhisP-STGontheGenericTechnicalGuidelines(GTG)
previously approved by the NRC, they'were required to identify in
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-the PGP any potentially safety signif.icant deviations from-the GTG-andprovideajustificationforeachdeviation.
Deviations'
madesubsequent.toPGPapprovalweresubjecttotheprovisionsof~
10 CFR.50.59. The process for effecting a change in an E0P is to revise the P-STG under the provisions of 10 CFR 50.59 and then revise the E0P to be consistent with the P-STG.
Practically, these are concurrent changes and the critical aspect is the documentationofthejustificationandbasisforthechangeto maintain a current basis for the E0Ps.
The inspectors found many examples where the E0Ps did not reflect the content of the P-STG.
These examples are listed in the Appendix.
The most significant example-is.an entry condition into CPS No. 4406.01, " Secondary Containment / Radioactivity Release Control Emergency."~ The P-STG(andGTG)listoneoftheentryconditionsas" secondary containment differential pressure >0 psid(referencedto atmosphere).
Revision 2 of CPS No! 4406.01 lists this entry condition as " differential pressure at or above'+ 0.125" WG."
Adocumentedjustificationorbasisforthisdifferencecould not be found.
A review of the 10 CFR 50 59 evaluations for this procedure indicated that any evaluation of this difference had not been documented as part of those evaluations.
The inspectors were particularly concerned with this example in
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that loss of secondarycontainmentintegrity(rupture)would
preclude reaching a positive pressure differential.
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failure to prepare E0Ps in accordance with the P-STG and
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pro)erly control changes thereto is considered a violation of L
TecinicalSpecification6.8.1.b(461/87006-02).
As noted above the licensee failed to explicitly address this F
issueinthe10CFR50.59evaluationsperformedforthisE0P.
l Therefore, no documented basis existed for concluding that no unreviewed safety question was generated as a result of the
change.
This represents another example of the failure to meet the requirements of 10 CFR 50.59 as depicted in violation
i 461/86053-02d documented in Inspection Report No. 50-461/86053
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and underscores the scope of this problem within the licensees organization.. The specific example noted above appears to=have the potential for presenting an unreviewed safety question and-its 'esolution will be tracked as an Unresolved Item r-(461/86007-03) pending completion of a documented licensee evaluation of this issue.
(2) Plant-Specific Writers' Guide
.The.P-SWG provides the details of how the E0Ps will be prepared.
In oart, it provides the control of human factors
. issues in E0P ' format and presentation.
The inspectors determined that the E0Ps had not been consistently prepared in accordance with the P-SWG. The examples are listed in the Appendix.
The licensee was aware of this fact through an audit of E0Ps performed by the CPS Licensing and Safety Organization.
The reason for the inconsistency was partially due to the fact that the current P-SWG was completed subsequent to the original revisions of the E0Ps. The licensee had decided not to upgrade the E0Ps to the P-SWG until Revision 4 of the GTG was ap3 roved by the NRC since this would also require E0P revisions.
T1e schedule for NRC approval of Revison 4 of the GTG is now indefinite.
The licensee must upgrade the E0Ps to the current P-SWG on a definite schedule. The failure of the E0Ps to be maintained consistent with the P-SWG is a violation of Technical Specification 6.8.1.b (461/87006-02).
.(3) E0P Verification and Validation Thepurposeoftheverificationandvalidation(V&V)effortis to ensure the technical adequacy and useability of the'E0Ps.
The inspectors' review of this area identified three concerns:
(a) The V&V effort was inadequate to provide complete assurance that the E0Ps were technically complete.
For example:
(1) CPS No. 4404.01, " Reactivity Control Emergen y," d states in. step 4.1.4, "If Boron cannot be in ecte with SLC System then inject Boron into the R V using RCIC Storage Tank.
Refer to CPS No. 3314.01, Standby Licuid Control (SC)." A review of CPS No. 3314.01 incicated that Baron injection via the RCIC Storage Tank was not addressed by that procedure.
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(2)
Step 4.1.2 of CPS No. 4401.01 lists the water le pumpsforHPCS,LPCS/RHR,andRHRB/Casalternake injectionsystemsintotheRPV.
There are no
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(3) Step 4.2.'3 identifies the RPV head vent as one means of depressurizing the RPV.
No instructions are given in the E0P nor is there a procedure referended
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describing the method to depressurize in tMs manner.
The fact that the head vent discharge path must;be-aligned to be consistent with the position of the MSIVs is a concern that must be included in such an instruction or procedure.
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Technical specification 6.8.1.b requires that written procedupes be established and maintained to implement the requirements of
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NUREG-0737 and its supplement.
The requirements of NUREG-0737 and the supplement include the establishment of emergency operating procedures that are consistent with both the P-STG and P-SW.
The failure of these procedures to provide the,
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appropriate instructions is a violation of Technical Specifidation 6.8.1.b(461/87006-02).
These examples of violations are a direct result of failure to implement the verification and validation program the licensee committed to perform as stated in A endix 0 of the CPS Final Safety Analysis Report.
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(b)pp&Vactivitiesarenotbeingconductedorcontrolledas
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(1) CPS Condition Report No. 1-85-11-107 dated November 8, S
1985, documented the fact that Emergency Operating verificatio(E0P) revisions were not receiving Procedure n and validation consistent with the
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original E0P.
The licensee revised the procedure controlling E0P revisions, CPS No. 1005.01 (Revision 17) to require that E0P revisions receive the applicableV&Vorthatthereasonfornotperforming V&V be documented in the safety evaluation for that revision.
The licensee identified seven revised E0Ps.
which had not received the required V&V.
As of
January 30, 1987 the V&V activities had not been performedandCP5CRNo.1-85-11-107 remains open.
461/86072,ifiedinUnresolved (2) NRC Inspection Report No.
Paragraph 12.
" Emergency Procedures Review," ident
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Item 461/86072-04 that E0P revision package CPS
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No. 4401.01,ith CPS No. Revision 7, had not been processed in
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accordance w 1005.01, Revision 17(procedure, CR No.1-85-11-107)part of the corrective adtion for revision issued as
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Specifically the licensee failed to document the basis for omitting,the V&V review on
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CPS No. 1005.06F001 Safety Evaluation Form (10 CFR 50.59 review).
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The licensee, in res)onse to the NRC finding, performed a review of other E0) revision packages processed after the issuance of Revision 17 (CPS No. 1003.01) and determined that the Safety Evaluation Form for revision to E0P 4402.01 also lacked the roquired basis for
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T omitting the V&V review. The licensee documented these
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. deficiencies (4402.01 and 4401.01) on CPS Condition Report No.- 1-87,-01-069.
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The' inspector's review of this Condition Report and E0P revision deficiencies. packages identified additional CPS No. 1005.01, Appendix C requires
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tnat,the results of the E0P revision review be
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documented on CPS No. 1005.01F001 (CPS Procedure Review Form).
The results of the revision review was not documented on the procedure review forms for-revisions to E0P No. 4401.01, Revision 7 and E0P p
No. 4402.01, Revision 5.
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The licensee's failure to effectivel implement their corrective G ction proprin'in respo:se to identi ied deficiencies is considered a violation of 10 CFR Part 50, Appendix B, i
Criterion XVj (461/87005-018).
(c) AlicenseeauditperformedytheLicensingandSafety Organization indicated various problems with the use of t'ie calculations supporting the P-STG and E0Ps which were not identified during previous V&V efforts.
These li
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p(roblenis are documented in the licensee's audit report.
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Interefficy n'emo Y-203729).
!s The problems identified in the audit included differences n '.
between the res'ults of cilculations performed in support of
'A the E0Ps and the actua1' values used in the E0Ps.
In some cases this may have resulted from the undocumented addition of inargins. Other problems included differences betweri calculated results and values included in the technical spacifications and inaccurate reproduction of graphs in tte E0Ps.
The inspectort found no additional problems in this area.
The completion of corrective action-on this item is
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considered an Unresolved Item (461/87006 05).
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..(4). Operator Training and Precedure Useability The inspectors evaluated the adequacy of the operator's ability to implement the E0Ps.
This was accomplished by witnessing a control room crew respond to three accident scenari s using the
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plant simulator and a control roo:n walkdown to determine if control room labelling and E0P terminology were consistent.
The operators were able to use the E0Ps with no difficulty and ap) eared to be well trained in their use.
No control room -
EO) terminology differences were identified.
The inspectors determined that in general the operators had received training consistent with that describ'd in the PGP.
The inspectors e
identified one concern in the training area.
The E0P training
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commitments included in the PGP were not made a formal constraint on the operator initial training )rogram.
The licensee agreed to correct this by including the )GP as a reference in the formal training program description.
This will be tracked as an Open Item (461/87006-06).
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Open Items
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Open items are matters which have been discussed with the licensee which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both.
An Open Item disclosed during
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the inspection is discussed in Paragraph 4.b.(4).
6.
Unresolved Items Unresolved items are matters about which more information.is required in order to ascertain whether they are acceptable items, violations, or
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deviations. Unresolved items disclosed during the inspection are discussed inParagraphs4.b.(1)and4.b.(3).
7.
Exit Interview The inspectors held an exit interview with licensee representatives (denoted in Paragraph 1) via telecon on February 3, inspection.
1987. The insaectors summarized the purpose,. scope and findings of the T1e licenseestatedthattheli(elyinformationalcontentofthereportwould contain no proprietary information.
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Appendix A.
' Differences Between E0Ps and P-STG (EPG)
1.
CPS No. 4402.01, Step 3.1.1 does not require scram on stuck open relief valve per P-STG.
2.
The addition of Step 3.1.5 to CPS No. 4402.01 and P-STG is not justifiedinP-STG.
3.
Step.3.3.2 of CPS No. 4402.01 is not in P-STG.
4.
Caution statement #22 does not appear prior to Step 3.6.8 of CPS No. 4402.01 per P-STG.
5.
Step 3.5 of-CPS Nc. 4404.01 does not appear in P-STG.
6.
Steps 4.5.5 and 4.7.7 of CPS No.-4404.01 state control rod drive differential pressures different from the P-STG.
7.
Entry condition (b) of CPS No. 4406.01 uses fuel building exhaust radiation level vs. area radiation levels used in P-STG.
8.
Step 3.2.3 of CPS No. 4406.01 uses a condition of "a General Emergency has been declared" vs. "offsite radioactivity release rate approaches or exceeds the release rate which requires a General Emergency" as used in the P-STG.
9.
CPS No. 4406.01 uses an entry condition of secondary containment pressure differential is +0.125" psid vs. P-STG entry condition of
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> 0" psid.
10.
The pressure range given in Step 3.3.3 of CPS No. 4401.01 does not
. agree with that given in P-STG (RC/L4.b).
11.
Step C2-1 of P-STG was not included in Step 4.2 of CPS No. 4401.01.
12.
Step 4.2.2 of CPS No. 4401.01 is not the same as Step C2-3 of P-STG.
13.
The contingencies listed in Step 4.2.5 of CPS No. 4401.01 are not c
the same as those in the P-STG, Section C2-6.
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B.
Differences Between E0Ps and P-SWG
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1.
Step 4.1.6 of CPS No. 4404.01 contains a conditional clause in an If/Then action statement which is not consistent with the P-SWG.
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CPS No. 4406.01 and other E0Ps contain no reference sect' ion as required by the P-SWG.
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-The first note preceeding Step 3.1.1 of CPS No. 4406.01 should be an If/Then action statement.
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The first two cautions in Step 4.4 of CPS No. 4406.01 do not meet-
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the P-SWG definition of cautions.
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The second action; item of Step 4.1.2 of CPS No. 4406.01 includes a condition step not-formatted per the P-SWG.
6.
CPS No. 4406.01 uses many action verbs not defined in the P-SWG (e.~g.,.per, perform, enter, execute).
7.
-CPS No. 4406.01 does not use an asterisk to identify action steps that must be performed sequentially as required by the P-SWG.
8.
Step 3.4 of CPS 4401.01 contains~a caution not formatted as a caution as required by the P-SWG.
9.
CPS No. 4401.01, Section 6 does not include the intent and scope of the E0P as required by the P-SWG.
10.
CPS No. 4401.01 uses the verb " increase" several times.
The P-SWG forbids its use.
C.
Examples of Inadequate Verification / Validation of E0Ps Step'B/C" water leg pumps as alternative RPV injection systems. lists t 4.1.2 of CPS No.-4401.01 1.
RHR No procedures are referenced for this action nor does the E0P address the potential need to manually open the check valves downstream of these low head pumps.
2.
Step 4.2.3 of CPS No. 4401.01 references the use of the RPV head vent as a means of depressurizing the RPV.
No instructions are given or procedure referenced for aligning the vent exhaust path.
3.
Table 1 in Step 3.2 of CPS No. 4402.01 references a drywell temperature of 545 f.
A temperature of 545 F cannot be read on existing control room instrumentation.
4.
Step 4.1.4 of CPS No. 4404.01 refers the operator to CPS No. 3314.01 toinjectBoronviatheRCICStorageTank.
CPS No. 3314.01 contains no instructions for performing this activity.
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