IR 05000461/1993005
| ML20035E016 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/08/1993 |
| From: | Burgess B, Doornbos R, Langstaff R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20035E012 | List: |
| References | |
| 50-461-93-05, 50-461-93-5, NUDOCS 9304140184 | |
| Download: ML20035E016 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report No. 50-461/93005(Oks)
Docket No. 50-461 License No. NPF-62 l
Licensee:
Illinois Power Company i
500 South 27th Street l
Decatur, IL 62525
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Facility Name: Clinton Power Station
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i Inspection At: Clinton Site, Clinton, IL 61727 Inspection Conducted: March 15 - 24, 1993 Inspectors:
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' Ronald A. Langstaff, RIYl'
Dite '
Lead Inspector n;u Y srLJm)
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RoprL.
Dgornbos,RIII Dste '
J. DeBor, Consultant Science and Engineering Associates J
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Approved By:
ao Bruce L. Burghss, (Nief Date Operational Programs Section Inspection Summarv Inspection on March 15-24. 1993 (Report No. 50-4dl/93005(DRS))
l Areas InsDected: Routine, announced safety inspection to verify that the l
Clinton Emergency Operating Procedures (E0Ps) were technically correct and useable, and that the E0P program was sufficient to maintain the quality of E0Ps. Areas in which. weaknesses were identified from a previous E0P Team Inspection (Report 50-461/91006) were specifically reviewed. The inspection was conducted in accordance with Inspection Procedure 42001.
Results: No violations were identified.
Four previously identified Open Items were closed. One previously identified violation was closed. One Open Item concerning the licensee's plans for upgrading plant labeling was identified. The E0Ps were technically correct and useable. The ECP program was sufficient to maintain the quality of E0Ps.
9304140184 930409 PDR ADOCK 05000461 j.
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Inspection Summary
1 Considerable improvement in the quality or E0P support procedures was identified. Significant improvements to the E0P program were a direct result of features which were added. These additional features included a.
l derivation document detailing the transition from the plant specific e
technical guidelines (PSTG) to flowcharts; e
writer's guide for E0P support procedures, V&V program procedure for E0P support procedures.
e Plant labeling was considered adequate. Although components were labeled, the labels v:ere difficult to read. Consequently, delays in performing E0P related
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tasks could result from difficulty in identifying components.
For example, it took an operator several minutes to locate a valve during a procedure j
walkthrough.
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l REPORT DETAILS 1.
Persons Contacted Illinois Power Company (IP)
J. Cook, Vice President and Plant Manager W. Bousquet, Director, Plant Support Services W. Clark, Director, Plant Maintenance R. Frantz, Sr. Licensing Engineer K. Grooms, Supervisor, Program Monitoring, Quality Assurance S. Guron, Project Engineer C. Hattes, Principal Assistant, Executive Support R. Kerestes, Director, Nuclear Safety & Analysis T. Landin, E0P Coordinator J. Miller, Manager, Nuclear Station Engineering D. Morris, Director, Quality Assurance A. Mueller, Director, Maintenance & Technical Training J. Neuschwanger, Asst. Director, Plant Operations H. Nodine, Supervisor, Procedures P.. ' hares, Director, Licensing Pruitt, Nuclear Program Assessor, Quality Assurance l
J. dipek, Supervisor, Regional Regulatory Interface
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F. Spangenberg, Manager, Licensing and Safety J. Taylor, Director, Administration E. Turner, Nuclear Program Controller D. Walters, Auditor, Quality Assurance R. Wyatt, Manager, Quality Assurance P. Yocum, Director, Plant Operations U.S. Nuclear Reaulatory Commission. Reaion III B. Burgess, Chief, Operational Programs Section All of the above individuals attended the exit meeting held on March 24, 1993. Other people were contacted during the inspection including members of the licensee's operations, training, and quality assurance staffs.
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2.
Action on Previously Identified Items The following items are closed based on the results of this inspection.
a.
(Closed) Open Item (461/91006-1):
7eaknesses existed in Emergency Operating Procedure (EOP) support procedures.
Support procedures were found to be generally good during this inspection.
b.
(Closed) Open Item (461/91006-2): Weaknesses existed in the verification and validation (V&V) program procedures. The V&V program procedures were found to be sufficient to ensure the
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quality of E0Ps are maintained. The addition of a V&V procedure for support procedures contributed towards the improvement.
c.
(Closed) Violation (461/91006-3): V&V was inadequate.
Through a review of the E0P procedures during this inspection, it was evident that an acceptable level of V&V had been performed.
d.
(Closed) Open Item (461/91006-4):
E0P flowcharts were not consistent with the Plant Specific Technical Guidelines (PSTG).
The E0P flowcharts were found to be generally consistent with the PSTG during this inspection.
e.
(Closed) Open Item (461/91006-5):
E0P writer's guide for flowcharts was deficient and there was no writer's guide for E0P support procedures. The E0P flowchart writer's guide was revised and a writer's guide was developed for support procedures.
Both writer's guides were found to be acceptable during this l
inspection.
l 3.
Emeraency Operatina Procedures The inspectors concluded that Clinton's E0Ps were technically correct
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and usable. This conclusion was based on review of a sample of E0P l
flowcharts and support procedures.
The review included desktop l
technical reviews and walkthroughs of procedures. Specific results of l
the review were:
l a.
Flowcharts: No examples were identified where a flowchart was l
incorrect. The flowcharts conformed to the formatting conventions l
established by the writer's guide. The inspectors considered the i
revised arrangement of flowchart E0P-8, " Secondary Containment i
i Control," Revision 21, to be an improvement.
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b.
SuDDort Procedures: The inspectors noted considerable improvement in the quality and usability of support procedures. However, one technical error was identified.
Details of the improvements and the technical error are:
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(1)
Examples of noted improvement were:
e Location information for where actions were to be j
performed was evident in the procedures.
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e Descriptions of components matched plant labeling exactly. No exceptions were identified.
e Special tools and equipment required to perform tasks were identified in the procedures.
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e Some valve lineups were separated from the body of the procedure and split into different sections according to who would likely perform the lineups (e.g., control room operators versus non-licensed operators).
The inspectors considered this feature to be beneficial and an improvement.
(2)
One technical error of minor safety significance was identified in procedure CPS 4411.03, "E0P Injection / Flooding Sources," Revision 0.
The procedure listed valve ISX184A to be shut instead of valve ISX184B in Lineup 2 of Appendix B.
Failure to shut the correct valve would have reduced injection flow intended for the reactor vessel under some conditions. However, the safety significance of the error was considered minor because the reactor vessel would have i
still received adequate injection flow.
l 4.
Walkthrouah Observations During procedure walkthroughs, several items were identified which could affect the performance of E0P related tasks. The items observed were:
a.
Plant labelina: Plant labeling of components was considered adequate, but poor. No improvement in labeling from that identified during the E0P Team Inspection (Report 50-461/91006)
was evident. Although all components referenced by support j
procedures were labeled, the raised lettering on the metal tags
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l used for labeling was small and difficult to read.
In some cases, the tags were painted which made it difficult to identify the tags from a distance.
For most components, the number had been marked on the body using felt tip marker in addition to the metal tags.
Delays in performing E0P related tasks could result from difficulty in identifying components.
For example, it took an
operator several minutes to locate valve IWS077B referenced by Lineup 2, Appendix B of CPS 4411.03.
In this case, the valve was located high above the floor and did not have supplemental felt i
tip pen markings to identify it.
To address labeling concerns, the licensee had developed a program for upgrading the existing labeling. However, at the time of this inspection, the licensee had not developed a schedule or set any priorities as to what labeling would be upgraded first. The inspectors requested the licensee to provide the NRC with a l
written response addressing the following:
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e a brief description of their plans for upgrading plant labeling;
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e a schedule for when the labeling would be upgraded for E0P i
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e a description of any priorities which have been established for upgrading plant labeling.
The licensee's response will be tracked as an Open Item
(461/93005-01).
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I b.
Control Room Labelina Discrepancies: Several control room discrepancies were identified as follows:
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(1)
Chart recorder 821-R615 used 0 inches as the reference for top of active fuel (TAF) contrary to -162 inches used by the
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E0Ps, the safety parameter display system (SPDS), and other
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instrumentation in the control room. The licensee agreed to add a scale which uses -162 inches as TAF to the chart recorder and evaluate removing the scale which uses 0 inches as TAF.
j (2)
The fission product monitoring subsystem recorder E31-R620 did not have labeling to identify the parameters associated with the three pens. The licensee agreed to provide
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additional labeling.
(3)
The label was missing for the reactor core isolation cooling i
(RCIC) pump flow controller,1E51-R600. The licensee agreed l
to replace the label.
l (4)
Multiple terms were used for the tank which supplied water
to the high pressure core spray (HPCS) and RCIC systems.
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The use of multiple terms could be confusing during the use I
of E0Ps--especially during communications with offsite
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organizations. Examples of the different terms for this tank and their use were:
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CST, Condensate Storage Tank, as used on control panel i
mimics (the inspectors noted that there was another I
" CST" tank which provided water to the condensate system);
e RCIC Storage Tank, as used in step 8.1.7.2 of procedure CPS 3309.01, "High Pressure Core Spray (HPCS)," Revision 7; e
HPCS Storage Tank, as used in step 8.1.7.2.2 of procedure CPS 3309.01, to match control panel labeling for a valve.
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During the inspection, operations personnel also used the terms "HPCS/RCIC storage tank" and "ECCS storage tank" to describe this tank. The licensee did not agree that the use of multiple terms for this tank was potentially confusing.
c.
Emeroency Liahtina: Many areas of the plant appeared to not have emergency lighting installed. No change in the status of I
installed emergency lighting from that identified during the previous E0P Team Inspection (Report 50-461/91006) was evident.
However, the licensee did have portable lighting, such as flashlights, available to perform E0P related tasks.
The licensee stated that their installed emergency lighting met
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the regulatory requirements of Appendix R.
The inspectors
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acknowledged that the licensee's approach was acceptable.
l However, inspectors requested that the licensee consider the l
adequacy of installed emergency lighting for those emergency procedures most likely to be used when normal lighting is not available, such as during a station blackout, and for those procedures which require an operator to be stationec' in a remote location for an extended period.
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Trainino: Training on E0P support procedures was considered acceptable. The operators accompanied on walkthroughs were familiar with how to use the support procedures and were able to i
locate equipment specified by the procedures.
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E0P Supportina Documentation
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l The inspectors concluded that supporting documentation which described i
the technical bases for the E0Ps was acceptable and had improved from
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that identified during the previous E0P Team Inspection (Report 50-461/91006). This conclusion was based on a technical review of the supporting documentation for a sample of E0P flowcharts.
In response to NRC concerns, the licensee developed a derivation document, " CPS Emergency Operating Procedure Derivation Document,"
Revision 0.
This document ic. proved documentation of flowchart differences by describing the transition from PSTG to flowcharts. The document provided assurance that the technical content of the PSTG was maintained in the transition.
Although the overall quality of supporting documentation had improved, j
two examples wera identified where documentation was weak:
j a.
No justification was provided for E0P flowchart steps which bypassed the Reactor Water Clean Up (RWCU) system regenerative i
heat exchanger. This was contrary to PSTG steps RC/P-2 and RC/Q-5.1.
In this case, the flowcharts were technically correct but the PSTG had not been updated to reflect the current philosophy regarding bypassing the regenerative heat exchanger. The licensee agreed to update their PSTG.
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b.
No technical justifications were provided in the deviation documentation for deletion of references to a sampling proceoure in PSTG steps SP/L-1 and RC/P-2. The justifications provided merely stated that no such sampling procedure existed at Clinton instead of providing the technical basis why sampling was not
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required. The inspectors concluded that Clinton's technical basis
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for not performing sampling was acceptable. The licensee agreed l
to revise their justifications to provide a technical basis.
6.
E0P Proaram
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e The inspectors concluded that the licensee's program for maintaining the quality of their E0Ps was acceptable. Details of the review are:
a.
Writer's Guides:
Both writer's guides, for E0P flowcharts and for
support procedures, were considered acceptable.
l The flowchart writer's guide, " CPS Emergency Operating Procedure Writer's Guide," Revision 1, provided sufficient restrictive j
guidance associated with technical content, whil9 providing
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flexibility in issuance. The revised writer's guide added more convention usage details and reflected flowchart formatting
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improvements.
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To address concerns from the E0P Team Inspection (Report l
50-461/91006), the licensee developed a writer's guide for E0P support procedures, Appendix B to CPS 1005.09, " Emergency
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Operating Procedure Program and Preparation," Revision 4.
The
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writer's guide provided sufficient restrictive guiriance necessary j
to ensure E0P support procedure consistency and quality equivalent
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to that of the flowcharts. The format of the support procedures
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appeared to work well for the operators during walkthroughs.
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b.
Verification and Validation: The program for V&V was considered j
sufficient to ensure the quality of flowcha-ts and support
procedures.
In response to a violation, the licensee developed a j
V&V procedure for support procedures, CPS 1005.12, "EOP Support
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Procedure Verification and Validation Program," Revision O.
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inspectors considered the new procedure to be adequate to ensure the quality of support procedures.
Evaluations of comments i
generated during the V&V process were sufficiently thorough to ensure appropriate disposition. Although the quality of the V&V
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performed had improved, some problems were identified by the
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inspectors which should have been identified and corrected by the
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V&V process.
Because few problems were identified, the inspectors did not consider these problems to be indicative of significant programmatic weaknesses. The problems identified by the inspectors were:
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a technical error concerning an incorrect valve number for a valve lineup (discussed in paragraph 3.b(2));
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e lack of a scale using -162 inches TAF consistent with procedures and other instrumentation on a water level chart recorder (discussed in paragraph 4.b(1));
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e lack of labeling to identify the parameters associated with specific pens on a three pen chart recorder (discussed in i
paragraph 4.b(2)).
7.
Self-Assessment and Ouality Verification i
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Quality Assurance (QA) involvement in the area of E0Ps was adequate.
i The observations identified by QA demonstrated that the audits were of i
sufficient depth and scope. Most items identified by QA were appropriately resolved by licensee management. However, licensee
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management had not taken advantage of an opportunity for improvement in
one instance.
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Audit Q38-92-04, conducted in January 1992, identified that access to
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some E0P related valves underneath deckplates was blocked due to
equipment on the deckplates. The NRC inspectors concurred with licensee i
management's response to the audit in that the procedure could be
performed because the valves were readily accessible from below.
Consequently, there was no requirement that the deckplates be labeled to
discourage people from storing equipment on the them. However, NRC
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walkthroughs of the area identified that opportunity for improvement
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existed in that 1) the procedure which referenced the valves did not j
mention access from the floor below and 2) due to poor labeling, some of i
the valves could not be readily identified without the use of a ladder.
8.
Open Items
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Open items are matters which have been discussed with the licensee, will
be reviewed further by tiie inspectors, and involve some action on the part of the NRC or the licensee or both. One Open Item was identified during this inspection and is discussed in paragraph 4.a.
9.
Exit Meetina The inspectors met with licensee representatives (denoted in Paragraph 1) on March 24, 1993. The inspectors summarized the purpose, scope, and findings of the inspection and the likely informational content of the inspection report. The licensee acknowledged this information and did not identify any information as proprietary.
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