IR 05000461/1999004
| ML20206J766 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 05/05/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206J751 | List: |
| References | |
| 50-461-99-04, 50-461-99-4, NUDOCS 9905120325 | |
| Download: ML20206J766 (39) | |
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t U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No:
50-461 License No:
NPF-62 Report No:
50-461/99004(DRS)
Licensee:
lilinois Power Company Facility:
Clinton Nuclear Power Station Location:
Route 54 West Clinton,IL 61727 Dates:
March 1 - April 7,-1999 Inspectors:
M. E. Bielby, Team Leader - Region ill R. M. Bailey, Assistant Team Leader - Region 111 S.' P. Ray, Senior Resident inspector - Prairie Island J. T.' Adams, Resident inspector - Braidwood i
J. A. Clark, Resident inspector-Perry
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B. C. Dickson, Resident inspector'- Dresden M. S. Freeman, Resident Inspector - Oconee P. L. Lougheed, Regional Inspector - Region ill J. D. Maynen, Resident inspector - DC Cook
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N. Merriweather, Regional Inspector - Region ll D. J. Wrona, Resident inspector - Monticello
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Approved by:
D. E. Hills, Chief Operations Branch
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Division of Reactor Safety i
9905120325 990505 E
,i PDR ADOCK 05000461
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EXECUTIVE SUMMARY Clinton Nuclear' Power Station, Unit 1
NRC Inspection Report 50-461/99004(DRS)
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~An operational readiness assessment team performed an announced inspection during the weeks of March 1,1999, and March 29,1999. The team evaluated the effectiveness of the Clinton Power Station (CPS) operators to safely operate the facility. The inspection focused on the licensee's operational activities and included two separate periods of continuous 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of control room and plant observations by NRC inspectors. The inspectors identified four non-cited violations (NCV) of Nuclear Regulatory Commission (NRC) requirements during the inspection.
Operations
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provided sufficient detail to support the conclusion that the associated equipment was operable. However, in one instance, the operators did not promptly pursue an operability question with the only operable emergency diesel generator and performed other unrelated work before conducting a surveillance test on the emergency diesel generator.
The safety impact of this situation was minimal because the licensee eventually declared the emergency diesel generator operable based on an appropriate operability determination. (Section O1.2)
in general, the operators properly used and adhered to procedures. However, during a
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control rod venting evolution, the inspectors identified that, contrary to procedure, a control room supervisor failed to directly supervise reactivity manipulations for several minutes. This failure to follow procedure was a non-cited violation. (Section 01.3)
Shift staffing consistently met procedural requirements. In general, the main control
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room operators conducted informative individual turnovers and briefings in a formal manner with all participants attentive to the information presented. (Section 01.4) -
The main control room operators understood the reasons for all lit annunciators on the
main control room panels. However, the inspectors noted inconsistent operator response to expected alarms, including failures to properly anno'unce alarms, during the first week of the inspection. After the inspectors identified this concem to licensee management, alarm response performance improved and was appropriate during the second onsite week of the inspection. (Section 01.5)
The control room supervisors, main control room operators, and work control supervisors
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were knowledgeable of technical specification requirements for various plant operational '
modes.' These individuals correctly interpreted technical specifications associated with
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attemating current power sources and the availability of shutdown cooling. The operators promptly recognized degraded plant conditions and correctly implemented p
technical specifications following identification of several emergent equipment problems.
(Section O1.6).
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Main control room personnel correctly and consistently used three-part communication
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techniques with very few exceptions. When communications errors occurred, main 2'
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i control room personnel promptly corrected them to ensure that communications standards were met. Formal and consistent pre-job briefings contained pertinent information necessary for the safe operation of the plant. However, the inspectors noted that one of the eight pre-job briefings observed did not include specific actions for malfunctions and unexpected conditions, and licensee personnel did not clearly state termination criteria during the briefing. (Section O1.7)
The main control room operators' narrative logs were complete and accurate. However,
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the inspectors also concluded that the log taking process was cumbersome and required the "B" reactor operator to spend the majority of the shift making log entries.
(Section 01.8)
J The inspectors identified two instances in which the licensee did not maintain
non-narrative operations records rigorously. A non-cited violation was identified conceming a failure to perform a quarterly temporary modification audit and the licensee would have been untimely in performing a quarterly out-of-service annunciator audit had the inspectors not intervened. (Section 01.8)
During the first onsite inspection week, a lack of rigor in the work control supervisors'
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review of work packages and questioning of work group personnel resulted in the approval of poor work packages and the failure to communicate ongoing work activities
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to the operators and subsequently, frequent challenges to the operators. As a result, the main control room operators were not always aware of expected alarms and research was necessary to answer their questions regarding plant activities. After the inspectors
~ identified this concem to licensee management, the screening of work packages and the t
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- questioning of work group personnel improved and was appropriate during the second-week of the inspection. (Section 01.9)
The operators responded appropriately to malfunctioning equipment. The licensee
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properly identified and classified action requests as main control room deficiencies when appropriate. (Section O2.1)
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- The inspectors concluded that the operator.workarounds, operator challenges, and the
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main control room deficiencies that would not be resolved prior to unit startup would not significantly complicate plant operations. The inspectors concluded that the licensee had established an adequate program to identify, track, and resolve operator workarounds l
and main control room deficiencies. Consequently, NRC Manual Chapter 0350 Case
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Specific Checklist Restart item IV.1, " Establish Program to Reduce and Maintain Main Control Room Deficiencies," was closed by the NRC Oversight Panel.
(Sections O2.1and O8.1)
l The inspectors determined that the operations procedures reviewed, with only a few L
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exceptions,' were adequate to perform the intended tasks. These exceptions included a
- control rod scram time surveillance test procedure which failed to direct the withdrawal of subsequent control rods under the existing plant configuration and an emergency diesel
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generator surveillance test procedure which failed to ensure that acceptable frequency and voltage requirements could be met. The inspectors considered these inadequate
- procedures to constitute non-cited violations. (Section O3.1)
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. Operators properly implemented safety system tagout activities. However, the inspectors identified some problems with the procedural guidance contained in Procedure CPS No. 1014.01, " Safety Tagging," and with operator understanding of the procedural guidance. These included a lack of guidance for disabling vane-type air operated valves without accumulator air bleed valves; a lack of procedural understanding by operators for safety tag placement on electrical breakers; a lack of procedural guidance for on/off electrical breakers with non-functioning mechanical interlocks; and a lack of administrative guidance for documenting an annual field verification of active safety tagouts. (Section O3.2)
A control room supervisor on one of the three crews observed by the inspectors during
the first week of the inspection exhibited several instances of command and control deficiencies. These deficiencies included: a failure to follow up on questionable work
' activities, a failure to consider plant configuration when issuing directions to operators, and a lack of supervision of control rod movements. After the inspectors' identified this concem to licensee management, all the control room supervisors on the four crews observed during the second week of the inspection exhibited an appropriate level of command and control. However, the inspectors observed instances of an excessive number of personnel in the control room horseshoe area during both weeks of the inspection. (Section 04.1)
The control room' supervisors and operations shift management reviewed, approved, and
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controlled the surveillance test result packages in accordance with the survedlance test
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- control program procedures. (Section 07.1)
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Report Details
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Summary of Plant Status The licensee maintained the unit in a cold shutdown condition, Mode 4', for the duration of the inspection period. The inspectors observed operations activities and operational aspects of maintenance and testing activities that the licensee conducted in preparation for unit startup.
1. Operations
Conduct of Operations 01* OpiW Comments
Ucing inspection Procedure (IP) 93802, the inspectors conducted two separate
tEsessments of operations activities each of which incorporated a continuous 72-hour main control room observation period.' The following sections of this report each describe the inspectors' observations and evaluation pertaining to specific operational performance areas.
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The licensee grouped the Clinton Power Station (CPS) No.1401 series of procedures into a single volume, the Conduct of Operations Manual. The Conduct of Operations Manual consisted of the following procedures and revisions and is referenced several times in this report:
CPS No.1401.01, " Operating Philosophy," Revision 30; I
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CPS No.1401.02, " Operations Department Organization, Duties, and l
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Responsibilities," Revision 6;
' CPS No.1401.03," Control Room Professionalism," Revision 7;
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_ CPS No.1401.04, " Shift Tumover and Relief," Revision 3;
CPS No.1401.05, " Operator Logs and Records," Revision 0;-
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CPS No.1401.06," Procedures and Operator Aids," Revision 5;
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CPS No.1401.07, " Communicating information," Revision 0;
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CPS No.1401.09," Control of System and Equipment Status," Revision 1;
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CPS No.1401.11. " Planning and Control of Evolutions," Revision 0; k
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CPS No.1401.12 " Shift Management Oversicht," Revision 0;
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CPS No.1401.13, * Operations Department Training and Qualifications,"
Revision 0; and l
CPS No.1401.15, " Alarm and Transient Response," Revision 0.
- 01.2 Ooerability Determination Process -
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Insoection Scooe (93802)
The inspectors reviewed the licensee's implementation of the safety system operability f
process.
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Observations and Findinas The inspectors reviewed 12 operability determinations which had been written by operations personnel. The licensee concluded in all 12 operability determinations that the affected system or component was operable.
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Division 2 Emeroency Diesel Generator Ooerability
. The inspectors were concemed that the operators were not aggressively pursuing the resolution of an operability concern with the division 2 emergency diesel generator (EDG). At the time, the division 2 EDG was the only operable emergency power source for the plant.
As discussed in Section O3.1 of this report, on February 6,1999, the licensee issued Revision 44 to procedure CPS No. 9080.01, " Diesel Generator 1 A(B) Operability.-
Manual and Quick Start Operability." Revision 44 of the procedure contained narrower acceptance bands for voltage and frequency than in previous revisions.
On March 2 and 3,1999, the operators questioned, based upon previous experience, whether the division 2 EDG would be found to be within the new acceptance bands. The operators did not appropriately fellow-up on these concerns in the shift tumover meetings on the evening of March 2,1999, or the moming of March 3,1999. The licensee gave testing of the division 2 EDG a lower priority than control rod scram time testing which did not involve a current operability concem. The licensee did not accomplish EDG testing until well after the control rod testing and several other production related activities. As discussed in Section O3.1, when the licensee finally tested the EDG, the EDG failed to meet the new acceptance criteria twice and the licensee declared the EDG inoperable.~ The licensee later perfe;med operability evaluation 1-99-03-053-001 and concluded the EDG was operable.. The inspectors reviewed the operability evaluation and agreed with the licensee's operability conclusion and basis. Specifically, the observed frequency with instrument error taken into account j
was within the frequency band specified in the Technical Specifications (TSs).
In this instance, the operators did not take prompt actions to resolve an operability question involving the only operable EDG Plant conditions and' operator workload would have supported testing of the EDG before control rod scram time testing and other work.
Other Ooerability Determinations The inspectors reviewed 11 additional operability determinations and the associated operability evaluations performed by engineering. The inspectors noted that the operability evaluations expanded on the information in the operability determinations. In general, the. operability evaluations provided sufficient detail to support the operability
' determination that equipment was operable; however, in one instance, the evaluation contained information which did not have a clear basis, or assumed a high level of
. familiarity with the underlying subject.~ In operability evaluation 1-99-03-053-OD1, the licensee stated that the impact on the EDG loading was calculated by multiplying the maximum EDG loading by the cube of the change in the frequency, but did not explain
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. the basis for the formula. The inspectors questioned the responsible engineer about the basis and ascertained that the formula was correct.
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Conclusions The inspectors concluded that the licensee's operability determinations and evaluations provided sufficient detail to support the conclusion that the associated equipment was
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operable. However, in one instance the operators did not promptly pursue an operability question with the only operable EDG and performed other unrelated work before conducting a surveillance test on the EDG. The safety impact of this issue was minimal because the licensee eventually declared the EDG operable based on an appropriate operability determination.
01.3 Procedure lmolementation a.
Inspection Scooe (93802)
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The inspectors assessed the licensed operators' implementation of procedural guidance.
The inspectors also interviewed individual operators to gain an overall understanding of the operators' awareness of procedural guidance. The inspectors referenced the following procedures:
CPS No.1005.01, " Procedures and Documents," Revision 39; and
CPS No.1005.15, " Procedures and Documents: Use and Adherence,"
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Revision 1.
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Observations and Findinos General Comments The inspectors observed operators using the following procedures to perform significant work activities:
CPS No.1000.11, * Work Priority Assignment and implementation," Revision 4;
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- CPS No.1014.01, " Safety Tagging," Revision 26;
a CPS No.1014.06, " Operability Determinations," Revision 4;
CPS No.1016.01, " Condition Reports," Revision 32; a
CPS No.1029.01," Action Request and Maintenance Work Orders," Revision 36;
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CPS No.1029.03, "imphmentation of Fix it Now (FIN) Process," Revision 3;
CPS No.1312.03, "RHR [ residual heat removal) - Shutdown Cooling & Fuel Pool
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- Cooling and Assist," Revision 2; Conduct of Operations Manual, CPS No.1401 procedure series, various
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CPS No.1406.01, " Annunciator Tracking Program," Revision 1;
L CPS No. 2825.37, " ERAT [ Emergency Reserve Auxiliary Transformer) Static
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VAR Compensator Integrated Test," Revision 0;
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CPS No. 3304.01, " Control Rod Hydraulic And Control (RD), Revision 20
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CPS No. 3312.03, " Shutdown Cooling (SDC) & Fuel Pool Cooling and Assist
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(FPC&A), Revision 2;
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CPS No. 3506.01, " Diesel Generator and Support Systems," Revision 25;
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CPS No. 4406.01, " Secondary Containment Control," (EOP 8), Revision 24;
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CPS No. 9053.05, "RHR (residual heat removal]/LPCS (Iow pressure core spray]
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Valve Operability (Shutdown)," Revision 36; CPS No. 9061.04, " Containment / Drywell isolation Automatic Actuation,"
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Revision 37; CPS No. 9080.01, " Diesel Generator 1 A(B) Operability - Manual and Quick Start
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Operability," Revision 44; and Switching Order 218, "De-energization of the Lathem Line," dated March 30,
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in general, the operators properly used and adhered to procedures during system evolutions observed by inspectors. Operators consistently used alarm response procedures for all unexpected alarms and many of the expected alarms in accordance with licensee administrative requirements. Operators used the latest procedure revision during all evolutions observed by the inspectors. However, the inspectors identified the two following instances in which operators did not correctly follow procedures:
Suoervision of Reactivity Manipulations On March 3,1999, the inspectors observed that, during the movement of control rod 24-29 for venting and scram time testing, the control room supervisor (CRS) was laattentive to the rod movement in progress. The CRS was positioned behind the reactor operators (ROs) at the beginning of the rod movement. However, the inspectors identified that the CRS became distracted for several minutes when he looked at several action request (AR) tags during the time that rod 24-29 was both inserted and withdrawn from the core. The inspectors also observed that the same CRS directed the "A" RO to continue control rod (12-33) testing, then tumed away to answer the telephone.
However, the inspectors observed that the "A" RO delayed any control rod testing until the CRS's attention returned to the control panel area. Licensee procedure CPS No.1401.01, " Operating Philosophy," Revision 30, Section 8.2, included responsibilities for reactivity management and stated, in part, that no concurrent activities which could cause a distraction were to be performed by any operator involved in reactivity manipulations, in addition, CPS No.1401.01 specified that the CRS must approve and be directly supervising the reactivity chahge.
Technical Specification 5.4.1.a specified, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A listed responsibilities for safe operation as one of these procedures. The CRS's failure to follow the approved procedural guidance and provide appropriate direct supervision of the reactivity change was considered a violation of the TS. This Severity Level IV violation is being treated as
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a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy.
The licensee's immediate corrective actions included counseling of the CRS by the shift manager (SM) and reminders to the operating crews of the expectations through a night order and crew briefings. The licensee addressed the issue in the corrective action program as Condition Report 1-99-03-254, dated March 18,1999.
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-Control Rod Movement Locaina On March 2 rH 3,1999, the inspectors observed that operators did not log all control rod movemenc Juring control rod venting in preparation for scram time testing. The operators only logged control rod movements as 00/48/00 for each rod that was vented.
These control rod movement log entries did not reflect either the interim control rod movements implemented or the multiple times that each rod was " full out" during the j
venting of the rod.' The licensee's procedure CPS No. 9000.09, " Control Rod Manipulation Logs," Revision 24, specified that all rod motion shall be documented in addition, the procedure also specified a logging requirement for each time the control rod was withdrawn to the " full out" position. The inspectors concluded that the RO's log entries were not consistent with CPS No. 9000.09 requirements.
Technical Specification 5.4.1.a specified, in part, that written procedures shall be i
implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A lists log entries as one of these procedures. The RO's failure to log all interim and " full out" control rod motion
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l was considered a violation of the TS. This failure constitutes a violation of minor significance and is not subject to formal enforcement action. The licensee addressed the issue in the corrective action program as Condition Report 1-99-03-252, dated March 18,
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Conclusions
in general, the operators property used and adhered to procedures. However, during a control rod venting evolution, the inspectors identified that, contrary to procedure, the CRS failed to directly supervise reactivity manipulations for several minutes. This failure -
to follow procedure was a non-cited violation.
01,4 Shift Staffina and Tumover
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inspection Scope (93802)
The inspectors observed and assessed shift staffing, formal shift turnovers, and temporary reliefs of individual main control room (MCR) watchststions. The inspectors referenced the following documents:
Conduct of Operations Manual, CPS No.1401 procedure series, various
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' CPS No.1401.04, " Shift Tumover And Relief," Revision 3;
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. Technical Specification, Section 5.2.2, " Unit Staff;" and
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Updated Safety Analysis Report, Section 13, " Conduct of Operations."
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Observations and Findinos Each plant operating crew consisted of an SM; CRS; "A" RO responsible for the reactivity control panel (P680); "B" RO responsible for the remaining MCR horseshoe and back panel balance of plant controls; field supervisor (FS); work control supervisor (WCS); and shift technical advisor (STA). Non-licensed operations personnel covered
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watches outside the MCR, and extra operations personnel assisted the work control center and with operational evolutions as needed.
Shift Staffina Shift staffing met or exceeded the TS-required and Updated Safety Analysis Report specified levels at all times. Operations personnel assigned to the shift were aware of any additional assignments such as fire brigade members, emergency response communicators, or shutdown EDG operators. The inspectors performed a spot check of proficiency watches for one SRO and one RO. These individuals maintained
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Formal Shift Turnovers Shift tumovers c.onsistently included a one-on-one discussion of plant conditions and a detailed walkdown of the main control panels. The oncoming shift also reviewed operator logs, management directives, and work-in-progress 4tems. The shift supervision met to discuss work priorities, management night orders, equipment status,-
and other operational issues immediately after the individual position tumovers, the entire crew assembled in the MCR to be briefed on the above items as well as specific personnel assignments.
In general, the operators conducted individual turnovers and briefings in a formal manner with all participants attentive to the information presented. For example, during a shift brief one RO expressed a concem with planned work on the condensate system that would result in the introduction of water to the main condenser. This was a valid concem because the main condenser was approaching its maximum capacity. Licensee management or the CRS froquently performed a " check for understanding" at the end of briefings to verify individual watchstander's knowledge of their tumover information.
Temoorary Watch Relief On one occasion on March 4,1999, the inspectors observed a WCS temporarily relieve the CRS for a meal break. The inspectors noted that the WCS did not review any watchstation documentation (i.e., narrative logs, MCR deficiency status, or annunciator status) prior to or following the relief. Upon questioning, the WCS stated that he had not performed any review because it was not a procedural requirement. The WCS also stated that he could not specifically recall the last time that he performed a document review. The inspectors noted that the individual was present at the shift tumover and was aware of unusual plant conditions and work in progress. The licensee's procedure CPS No.1401.04, Section 8.2, " Document Review," Step 8.2.2 b, specified, in part, that
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each operator shall review shift documentation relevant to the watchstation being assumed and that review shall include the narrative log entries covering the period since the last shift worked or the previous four days.
Technical Specification 5.4.1.a specified, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A lists relief turnover as
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one of these procedures. The failure of the WCS to follow the procedure for document review prior to_a shift relief was considered a violation of the TS. This failure constitutes a violation of minor significance and is not subject to formal enforcement action. The '
licensee addressed the issue in the corrective action program as Condition Report No.1-99-04-108, dated April 9,1999.-
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Conclusions.
Shift staffing consistently met procedural requirements. In general, the MCR operators conducted informative individual tumovers and briefings in a formal manner with all participants attentive to the information presented.
01.5 Ooerator Alarm Response a.
Insoection Scooe (93802)
The inspectors observed the operators respond to expected and unexpected MCR annunciators. The inspectors referenced the following documents:
. Conduct of Operations Manual, CPS No.1401 procedure series, various
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revisions.
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Observations and Findinos il During the first inspection week, the inspectors observed that MCR operators inconsistently identified receipt of ex, ected alarms during work evolutions. Some o
operators clearly announced the expected annunciator prior to the alarm, some announced " expected alarm" after it was received, and some acknowledged the alarm without announcing anything. The inspectors identified these observations to operations management during a debrief. Subsequently, during the second inspection week, the -
inspectors observed that operators clearly identified almost all expected annunciators prior to receipt of the alarm.
Through questioning of the operators, the inspectors ascertained that the MCR operators understood the reasons for all lit annunciators on the MCR panels. The operators also responded appropriately to unexpected alarms by promptly notifying the CRS and performing immediate actions, referencing the associated response procedures, and requiring plant operators to investigate the cause of the unexpected alarms. The operators, with one exception, notified the CRS whenever the alarms cleared. In one instance where the operator did not announce the clearing of an alarm, the CRS immediately corrected the operator. Two examples of appropriate operator response to unexpected alarms included:
On March 3,1999, the operators responded to unexpected low safeguards bus
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voltage alarms. The CRS effectively directed the response, and the ROs rapidly pedormed the actions in accordance with the appropriate annunciator response procedure. The load dispatcher informed the operators that a nearby co-generating unit had tripped causing the low voltage condition. The CRS promptly called non-licensed operators to the MCR and provided them
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instructions for manually resetting the voltage tap on the Emergency Reserve Auxiliary Transformer (ERAT). However, the co-generating unit restarted, and
. the voltage retumed to normal before the operators changed the ERAT tap setting. The inspectors observed that when new information arrived in the MCR, the CRS immediately ensured all members of the MCR team were informed simultaneously.
On March 4,1999, an audible P680 panel alarm occurred in the MCR without an
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associated flashing light to Indicate which annunciator was in alarm. The ROs immediately informed the CRS of the condition. Under the direction of the CRS, the operators tested all of the annunciator lights and found no problems. The ROs then reviewed a9 known work in the plant in an effort to determine which alarm might have been received. The MCR operators identified that work was in progress on the off-gas system and one of the off-gas annunciator lights had recently failed to clear. The operators speculated that the alarm could be associated with the off-gas annunciator and documented the finding. Licensee
personnel later determined that the alarm was actually due to a spare
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annunciator location which apparently had a defective alarm card but no light bulbs.
On March 30,1999, during ERAT testing the MCR operators entered the transient annunciator response mode in accordance with CPS No.1401.15, " Alarm And Transient Response." The purpose of the procedure was to allow MCR operators to focus their attention on required actions without being distracted by alarms and to ensure that all alarms were addressed. The inspectors observed the CRS direct actions and observed an extra operator record the large number of annunciators as they alarmed, verify MCR operators addressed those alarms, and verify the alarms cleared at the completion of the ERAT test.
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Conclusion The MCR operators understood the reasons for all lit annunciators on the MCR panels.
However, the inspectors noted inconsistent operator response to expected alarms, including failures to properly announce alarms, during the first week of the inspection.
After the inspectors identified this concem to licensee managenient, alarm response performance improved and was appropriate during the second week of the inspection.
01.6 Ooerations Recoanition of Dearaded Plant Conditions and Technical Soecification Adherence a.
Insoection Scooe (93802)
During their observations of MCR activities, the inspectors evaluated how well operations personnel recognized degraded plant conditions and adhered to TSs. The inspectors conducted walkdowns of the control board configuration and reviewed the licensee's implementation of TSs for existing plant conditions reflected in the control board indications' status. The inspectors referenced the following document:
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Observations and Findinas The inspectors reviewed TS requirements and questioned the MCR operators and WCS about TSs associated with the required off-site AC sources in plant operational condition mode four. The inspectors identified one MCR operator that could not correctly identify the requirements. However, the remainder of MCR operators correctly informed the inspectors that one off-site AC source and one EDG were required. In addition, the CRS informed the inspectors of the TS requirements for plant operational condition modes one, two, and three. The inspectors also verified that the WCS correctly interpreted TS requirements for the shutdown cooling (SDC) suction valves,1E12-F008 and 1E12-F009, prior to tagging out 1E12-F008.
The inspectors noted that the MCR operatort, promptly recognized degraded plant conditions and correctly verified TS compliance following emergent issues including a problem on the Latham 345 kilovolt off-site power source, the loss of B residual heat removal pump discharge pressure after removing the pump from the SDC mode of
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operation, and excessive voltage on the division 2 and division 3 safety-related busses following a reserve auxiliary transformer (RAT) to ERAT transfer. Following the declaration of inoperability for division 2 and division 3 safety-related busses, the inspectors noted that operators correctly verified that TS requirements were met for emergency core cooling systems during plant operational condition mode four.
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Conclusions The _CRSs, MCR operators, and WCSs were knowledgeable of TS requirements for various plant operational condition modes. These individuals enrrectly interpreted TSs
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associated with AC power sources and the availability of SDC. The operators promptly
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recognized degraded plant conditions and correctly implemented technical specifications i
following identification of several emergent equipment problems.
01.7 Shift Communications and Briefinas a.
Insoection Scope (93802)
The inspectors observed the verbal and written communications conducted among various MCR operators and between plant personnellocated outside of the MCR during maintenance and testing evolutions.- The inspectors assessed the operators'
effectiveness at conducting shift tumovers and pre-job briefings and the operators' use of major plant communication systems. The inspectors referenced the following document:
Conduct of Operations Manual, CPS No.1401 procedure series, various
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Observations and Findinos Three-oart Communications
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The inspectors observed that operations personnel used three-part communication techniques during the performance of routine control room activities and infrequent evolutions. The inspectors observed only one instance where a CRS did not correctly
'use three-part communications. However, the SM immediately corrected the CRS and documented the event, inspectors also noted several examples where personnel from other departments did not use three-part communications when communicating with the MCR personnel.. The operators immediately corrected the individuals and insisted on the use of three-part communication techniques.
Pre-lob Briefinos The inspectors observed pre-job briefings for the following evolutions:
I Control rod scram time testing;
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Placing the reactor mode switch in shutdown;
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Surveillance testing of the division 2 EDG;
Rod venting and scram time testing for rod 24-29;
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Surveillance testing of the division 3 EDG;
RAT and ERAT static VAR [ volts-amps-reactivej compensator (SVC) testing;
Restoration of the B fuel pool cooling pump; and i
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]
a-The pre-job briefings routinely included discussions of all significant aspects of the job including contingency plans for malfunctions and unexpected conditions. The licensee
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personnel involved in the briefings actively participated and supervisors frequently performed a " check for understanding" to verify that personnel understood their responsibilities. However, the inspectors noted that a pre-job briefing performed for control rod scram time testing did not include speciiic actions for malfunctions and unexpected conditions, and termination criteria were not clearly stated The briefing was lengthy and did not actively involve the personnel in attendance until a brief question and answer period at the conclusion. The inspectors discussed the briefing with the CRS who acknowledged that the termination criteria were not clearly stated.
Plant Communications Eauioment The inspectors noted disciplined use of the plant paging (Gaitronics) system. Plant personnel made very few unnecessary page announcements. This practice assisted in reducing MCR distractions, especially during shift tumovers, shift briefings, and pre-job briefings. The plant manager informed inspectors that he had recently stressed reducing the use of the paging system.
The inspectors noted that on several occasions plant employees used the MCR emergency telephone number to contact the MCR for a routine call. During one shift, the emergency phone rang on three different occasions within several minutes because the shift manager's phone number had been forwarded to the MCR emergency phone -
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number. The inspectors noted that the MCR operators were distracted from their tasks to respond to the perceived emergency phone call. The operators corrected this problem.
The inspectors noted that radio transmissions from personnel in the plant would frequently break up in the MCR. The licensee informed inspectors that poor radio communications was a recognized problem. The inspectors verified that the licensee tracked poor radio communications in the operator workaround program.
c.
Conclusions The inspectors concluded that MCR personnel correctly and consistently used three-part communication techniques with very few exceptions. When communications errors occurred, MCR personnel promptly corrected them to ensure that communications standards were met. Formal and consistent pre-job briefings contained pertinent information necessary for the safe operation of the plant. However, the inspectors noted that one of the eight pre-job briefings observed did not include specific actions for malfunctions and unexpected conditions, and licensee personnel did not clearly state termination criteria during the briefing.
01.8 Control Room Record Keepina a.
Inspection Scope (93802)
The inspectors reviewed the MCR narrative log and non-narrative records for annunciators and temporary modifications. The inspectors referenced the following documents:
CPS No.1014.03, " Temporary Modifications," Revision 18;
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Conduct of Operations Manual, CPS No.1401 procedure series, various
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revisions; and CPS No.1406.01, " Annunciator Tracking Program," Revision 11.
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b.
~ Observations and Findinas
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Narrative Loas The inspectors observed that the MCR log contained appropriate entries for operator activities conducted during the inspection. The inspectors noted that sufficient procedural guidance existed to clearly identify the required log entries and the individuals required to make and review those entries. The inspectors observed that times and sequences of events were accurate. The operators made late entries into the logs whenever discrepancies or updates were necessary. The inspectors determined that all of the shift operators observed were knowledgeable of previous log entries and familiar with symbols called out in the procedure and utilized to highlight significant items in the logs.
The inspectors observed that making manual log entries was very time consuming for the operators. Due to the large number of limiting conditions for operation (LCOs) and
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't the amount of equipment unavailable, the licensee dedicated one RO to this task for
. most of each shift. The inspectors noted that entries for midnight and special evolutions, such as rod testing, took several hours to document. As a consequence, operators recorded emergent activities, such as annunciator alarms and responses, on blank lined
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paper tablets or memo pads until the appropriate log entries could be made. The inspectors observed that the "B" RO spent a majority of the shift managing log entries versus performing other duties. Operations supervision acknowledged to the inspectors that operators could not mentally keep track of all the present LCOs and mode restraints.
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Non-Narrative Ooerations Records
~ The inspectors identified record keeping errors with both non-narrative operations records reviewed. Those records included the annunciator audit log and temporary modification audit documentation.
On March 31,1999, the inspectors identified that the quarterly out-of-service annunciator audit for the first quarter of 1999 had not been scheduled prior to the end of March 1999.
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After questioning by inspectors, the licensee immediately commenced and completed
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the audit. The licensee addressed this issue in the corrective action program as Condition Report No. 1-99-04-016, dated March 31,1999.
On April 1,1999, the inspectors requested a copy of the quarterly review of temporary
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modifications for the calendar quarter that ended March 1999. The licensee informed the inspectors that the requested quarterly audit was in progress. Licensee procedure I
CPS No.1014.03, " Temporary Modifications," Revision 18, provided direction for the control of temporary modifications. Step 8.6.2.1 stated, in part, that during the last month of each calendar quarter, operations personnel shall assure that a review of accessible
temporary modifications is performed. Technical Specification 5.4.1.a specified, in part, that wntten procedures shall be implemented covering the applicable procedures recommended in Appendix A'of Regulatory Guide 1.33. Revision 2, February 1978.
Appendix A listed equipment control as one of these procedures. The failure to perform the temporary modification audit within the last month of the first calendar quarter was
- considered a violation of the TS. This Severity Level IV violation is being treated as a non-cited violation consistent with Appendix C of the NRC Enforcement Policy.
(NCV 50-461/99004-02(DRS)). The licensee addressed this issbe in the corrective action program as Condition Repo:t No. 1-99-03-236, dated March 17,1999.
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Conclusions The MCR operators' narrative logs were complete and accurate. However, the inspectors also concluded that the log taking process was cumbersome and required the
"B" RO to spend the majority of the shift making log entries.
The inspectors identified two instances in which the licensee did not maintain non-
. narrative operations records rigorously. An NCV was identified involving a failure to perform a quarterly temporary modification audit and the licensee would have been untimely in performing a quarterly out-of-service annunciator audit had the inspectors not intervened.
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01.9 Operations Work Controi Activities a.
Insoection Scope (938021 The inspectors observed the interface between the work control center, MCR, and work groups performing the plant outage work activities. The inspectors reviewed and assessed the effectiveness of operations shift personnel in controlling work in the plant.
The inspectors referenced the following document:
Conduct of Operations Manual, CPS No.1401 procedure series, various
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revisions.
b.
Observations and Findinos The inspectors observed the WCS perform initial reviews of work packages and the MCR personnel perform a subsequent review before authorizing the work. During the first inspection week, the inspectors were concemed that WCS screening of work packages lacked rigor. The inspectors based this concem on the MCR personnel's frequent questioning of the work group leader and review of work packages that sometimes required more research to obtain answers. In addition, there were some examples where plant personnel initiated expected alarms without first notifying the MCR personnel. _In these instances, the inspectors observed that MCR operators determined the cause of the alarm, stopped the activity that initiated the alarm by using plant radios or Gaitronics, and discussed operations' expectation of MCR notification of potential alarms with the responsible plant personnel before allowing the work to resume. The inspectors concluded that operators frequently and unnecessarily served as the "last line of defense" against unexpected and adverse plant response to work activities.
The inspectors identified one instance where operators did not determine the cause of an alarm and take the expected actions. During the first inspection week, MCR operators received an unexpected "W Trouble" alarm. The RO had a plant operator verify the local alarm was for the division 2 main steam isolation valve leakage control blower. The CRS confirmed that electricians were working on the system. The RO called the electricians who verified they had " pulled a bucket" (electrical breaker). The RO suggested the electricians coordinate a meeting with their supervisor and the WCS, review the work package, and add a note or step to call the MCR whenever a step was performed that would cause an MCR alarm. The RO informed the inspectors that the same MCR annunciator had alarmed the previous night when the electricians were working on division 1; however, the expected actions to address this issue were not taken. The inspectors informed operations management of this issue during a debriefing at the end of the first week of the inspection.
During the second inspection week, the inspectors observed an increased rigor in the WCS review of work packages for impact on the plant and MCR and the questioning of work groups about their packages. The inspectors also observed an improvement in the notification of MCR personnel regarding expected MCR alarms as the result of a maintenance or testing activity. The WCS screened work packages to verify work group awareness of potential alarms and to ensure that the work group understood the expectation for MCR notification prior to the initiation of an alarm. The WCS also asked
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probing questions of the work group to verify their understanding of the work or test that they were to perform. The inspectors observed the WCS turn back several work
packages because the package was incomplete, or becuse the work group personnel
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demonstrated inadequate knowledge of the work package. For example, the inspectors l
observed an electrical maintenance worker request permission to perform a post-maintenance test (PMT) on a relay associated with a feedwater pre-lube pump. The worker was not sure which pump the relay was associated with and appeared
unprepared to perform the work. Because the pump was tagged out, the WCS sent the L
- worker away without permission to perform the testing and notified the supervisor.
c.
Conclusions.
l During the first onsite inspection week, a lack of rigor in the work centrol supervisors'
review of work packages and questioning of work group personnel resulted in the
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approval of poor work packages and the failure to communicate ongoing work activities to the operators and subsequently, frequent challenges to the operators. As a result, the main control room operators were not always aware of expected alarms and research was necessary to answer their questions regarding plant activities. After the inspectors identified this concem to licensee management, the screening of work packages and the j.
questioning of work group personnelimproved and was appropriate during the second j
l week of the inspection.
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. 02.
Operational Status of Facilities and Equipment l-L l
O2.1 Imoact of Plant Condition on Ooerations a.
Insoection Scooe (93802)
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The inspectom assessed the overall plant equipment status. This included a review of l
safety tagging records, equipment deficiency logs, and equipment out-of-service logs.
The licensee developed processes to identify and resolve operator workarounds and l
MCR deficiencies. The inspectors observed plant evolutions, discussed plant configuration with operations and maintenance personnel, and referenced the following l
documents:
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CPS No.1000.11, " Work Priority Assignment and implementation," Revision 4;
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l CPS No.1029.01, " Action Request and Maintenance Wvision 36;
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CPS No.1029.03, " Implementation of Fix It Now (FIN) Process'," Revision 3;
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l CPS No.1401.09," Control'of System and Equipment Status," Revision 1;
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Main Control Room Deficiencies Index, provided on April 2,1999;
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L Operator Workaround index, provided on April 1,1999; and
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L Operator Challenge Index, provided on April 1,1999.
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b.-
Observations and Findinos The inspectors observed that a large number of plant systems, subsystems, or i
components were out-of-service or impaired. The inspectors determined through observations and discussions with work control personnel that several hundred plant components remained out-of-service due to deficiencies or tagouts. The inspectors
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through review of the annunciator log noted that 84 annunciators were either out-of-service or impaired. As of April 1,1999, the licensee had identified 6 open
' operator workarounds, 3 open operator challenges, and 62 open MCR deficiencies.
Significant observations are detailed below:
Eauioment Problems The inspectors observed numerous instances where equipment did not function properly when operated. In these instances, the inspectors noted that the operators responded
. properly to the malfunctioning equipment by stopping the evolution in progress and verifying plant safety. However, the inspectors were concemed that the number of.
equipment malfunctions in conjunction with the increasing plant work activity level presented challenges to the operators. Some of the more challenging equipment problems included:
The high bus voltage during the RAT to ERAT transfer;
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The degraded Latham offsite power line;
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i The abnormal residual heat removal discharge line pressure after shutdown from
SDC; A momentary high secondary containment differential pressure while changing
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fuel building ventilation system alignment which resulted in an Emergency Operating Procedure entry; The MCR panel P630 ground fault;
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Two channels of source range monitoring (SRM B and SRM C) instrumentation -
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spiking above the period alarm setpoints; The local power range monitor instrumentation had locked-in upscale alarms;
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The standby liquid control (SLC) pump B breaker which failed to open when the I
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pump was tumed off; and
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The reactor feed pump B which could not be placed on its tuming gear.
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Ooerator Workarounds and Ooerator Challenoes The licensee classified deficiencies impacting plant operations as either operator workarounds or operator challenges. Licensee procedure CPS No.1401.09, Section 2.2.3, defined an operator workaround as an equipment ~ deficiency and its required compensatory actions that impair the operator's ability to operate or control the plant during transient conditions. Sechon 2.2.3a defined an operator challenge as a degraded or nonconforming condition that complicates normal operation of plant equipment and is compensated for by operator action.
The process for identifying, documenting, resolving, prioritizing, tracking, and auditing operator workarounds and operator challenges was documented in Section 8.12 and 8.12a, respectively, of procedure CPS No.1401.09. The prioritization for operator workarounds was limited to a Prionty 3 or higher (1 was emergency,2 was urgent,3 was priority,4 was routine, and 5 was outage), but prioritization of operator challenges was determined on a case-by-case basis. The procedure include <l the situation that while individualitems may not be considered a workaround, the aggregate effect of the cumulative items should be considered for identification of an operator workaround.
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l The licensee's combined definition of operator workaround and operator challenge was adequate to identify deficiencies that impacted operations during both normal and transient conditions. The goveming procedure provided a process and adequate I
guidance for documenting, resolving, prioritizing, tracking, and auditing operator
. workarounds and operator challenges.
~ As of April 1,1999, the licensee had ' ix open operator workarounds and three open s
operator challenges. Work on the following operator workarounds and operator challenges was in progress and scheduled to be completed prior to unit startup:
. Workaround 97-33, " Degraded grid voltage modifications";
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' Workaround 97-37, "No communications system available in SX pump rooms";
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Workaround 98-61, " Acoustic monitor channels 7 and 8 for SRVs 1821F047D
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and F051D alarm without SRVs open"; and Challenge 97-44, "1WS079A (WO-A chiller head pressure regulating valve) will
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not control WS flow."
The licensee expected the five following operator workarounds and operator challenges to remain open past unit startup:
i Workaround 99-85, " Poor radio reception in some areas of the plant."
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Compensatory actions included using phones and the Gaitronics system instead
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of radios. For planned evolutions with work in affected areas, the pre-job briefing would include a discussion on the use of communications systems.
Workaround 98-68, "EDG venti'ation fan room doors were difficult to open when
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. the EDG ventilation system was in operation." Actions to resolve the issue
included evaluating the use of door actuators. Compensatory actions included a procedural requirement to check that the room is empty prior to an EDG start.
Workaround 98-82, " Station Air (SA) compressor lube oil systems cannot control
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in automatic." Of the three SA compressors, the licensee planned to install and evaluate a modification on one of the air compressors prior to unit startup. When the unit is on-line, and if the modification is successful, the licensee planned to perform the same modification on the remaining SA compressors.
Compensatory actions included taking manual control of the SA compressors when the component cooling water temperatures fluctuate. Annunciator 5041.06,
" Trouble Service Air Compressor O," was expected to alarm if abnormal oil temperatures occurred.
Challenge 98-58, " Excessive MCR noise due to high ventilation flows." Current
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~ actions included evaluation of improve j @moers. Compensatory actions included speaking louder in the MCR.
Challenge 97-34, " Reactor Recirculation (RR) loop discharge valves leak past the
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seats." Current actions included valve repairs, possibly during outage RF-7.
Compensatory actions included clarification through training and procedures of operator misconceptions that the recirculation loop discharge valves are leak tight.
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The inspectors evaluated these five items and determined that they did not significantly complicate operations of the plant and satisfactory compensatory measures were in place.
On March 31,1999, annunciator "RHR B Discharge Pressure Abnormal" alarmed when MCR operators removed the B RHR train from the SDC mode. When questioned by the inspectors, the operations task manager stated that the unexpected alarm was not tracked as an operator workaround or operator challenge, but that the problem would be reviewed. The licensee initiated Condition Report No.1-99-04-001 to track the issue.
Main Control Room Deficiencies The licensee defined MCR deficiencies in procedure CPS No. 1401.09, Section 2.2.4, as an equipment-related problem either in the MCR itself or in the plant, that has an Action Request (AR) written against it and is an equipment failure which satisfies one of the following criteria:
located physically within the MCR;
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regardless of location, renders a MCR instrument / indication inaccurate or
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unreliable; regardless of location, prevents a MCR annunciator frorn alarming when the
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alarm condition exists; regardless of location, causes a MCR annunciator to alarm when an alarm
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condition does not exist.
The inspectors reviewed the Main Control Room Deficiencies Index computer printout and noted that as of April 2,1999, the licensee was tracking 62 open MCR deficiencies.
Of these,20 MCR deficiencies were open pending the completion of PMT or closeout paperwork, but the licensee had completed the physical work to correct the deficiencies.
During the period of this inspection, the number of open MCR deficiencies requiring work remained nearly constant at about 40 items. The licensee identified approximately 10 of the deficiencies as mode restraint items (deficiencies that would affect operational moles). In these instances, operations personnel also logged the MCR deficiency in the computerized " operability restraint database." The mode restraint items could complicate operations of the unit more than the other identified deficiencies. The mode restraint items had been entered in the " operability restraint database" and CPS No.1401.09, Step 8.14.11, stated that personnel should review the tracking system prior to mode changes. Some of the more significant mode restraint items included:
Upscale lights for local power range monitors (LPRMs) on the full core display
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are lit when LPRMs are not upscale; Valve position indication for two safety service water valves do not match actual
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valve position;
"C" SRM spikes intermittently;
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Degraded control switch for a safety relief valv9; and
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Position indication problem for an attemate rod insertion valve.
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Of the remaining 30 items that were not identified as mode restraint items, approximately 10 were related to balance-of-plant annunciator problems (annunciators that would alarm
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too early or did not come in when expected). The licensee had scheduled these items to be worked the week of April 6,1999. Some of the more significant non-mode restraint items included:
Fire protection spurious alarms and trouble alarms that didn't reset;
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" Auto trip" annunciator did not come in when a 4160 volt bus main breaker was
tripped; Channel 2 of the loose parts monitor had a loud hum;
SLC tank temperature alarm annunciated at point outside of the set band; and
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Recorder failed to show shaft eccentricity when main turbine was placed on the
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tuming gear.
The inspectors evaluated the current MCR deficiencies and determined that if left uncorrected, the number and character of the deficiencies could present significant
- challenges to the operators. With only one minor exception, the licensee planned to correct the current MCR deficiencies before plant startup. However, the licensee expected additional MCR deficiencies to be identified due to placing systems in service as the licensee approached unit startup. The licensee planned to evaluate these additional MCR deficiencies with respect to safety significance and operational impact.
The inspectors observed the process for identifying a MCR deficiency. The inspectors observed a CRS perform a review of a new action request (AR) in accordance with CPS No.1029.01. The procedure required operations personnel to evaluate all new ARs for classification as a MCR deficiency and as a mode restraint item. The CRS properly classified the item as a MCR deficiency; however, operators did not replace the AR sticker with a MCR deficiency sticker until the inspectors questioned this oversight.
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The inspectors discussed with operators and malntenance workers the process used by the licensee to route, prioritize, and schedule work on MCR deficiencies. The inspectors also reviewed associated administrative procedures. The licensee stated that all ARs, including MCR deficiencies, were first sent to the Fix lt Now (FIN) team. The licensee then sent all ARs which were outside the ability of the FIN team to accomplish to the scope review committee to determine when the AR should be worked. The licensee assigned a priority based upon definitions in administrative procedures. However, the licensee provided additional focus on MCR deficiencies. The lic6nsee stated that all MCR deficiencies identified during the current outage were treated as priority work, we promptly assigned to an individual, and were the highest priority item which an indivic would work unless the MCR defk:iency required a component or system outage to rept The FIN team tracked MCR d' ficiencies as specified in CPS No. 1029.03. However. ths e
inspectors noted that the process used by the licensee to place additional focus r
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deficiencies was not proceduralized.'
c.
Conclusions The inspectors observed that the operators responded appropriately to equipment which did not appear to be functioning properly. The licensee properly identified and classified ARs as MCR deficiencies when appropriate.
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The inspectors concluded that the operator workarounds, operator challenges, and the main control room deficiencies that would not be resolved prior to unit startup would not significantly complicate plant operations.
'03 Operations Procedures and Documentation
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03.1 Procedure Adeauacv a.
Insoection Scooe (93802)
The inspectors observed operators use procedures and reviewed those procedures for adequacy. The procedures referenced are listed in Section 01.1 and the various Inspection Scope sections of this report.
1 b.
Observations and Findinas The inspectors determined that the operations procedures reviewed, with only a few exceptions, were adequate to perform the intended task. However, the inspectors determined that two surveillance test procedures described below were inadequate, in addition, the inspectors noted opportunities existed for enhancements to the licensee's safety tagging procedure as described in Section O3.2.
Control Rod Scram Time Testina On March 2,1999, the inspectors observed the preparations for scram time testing of four control rods. The inspectors noted that step 8.2.3 of CPS No. 9813.01," Control Rod Scram Time Testing," Revision 30, contained directions to withdraw all of the control rods identified for testing to position 48. The operators were aware that they were limited by TS to withdrawing only one control rod at a time under the current plant conditions.
Section 8.4 contained directions to conduct the scram time testing of the rods and ended with step 8.4.16. That step stated, " Repeat steps 8.4.2 through 8.4.15 for the remaining CRDs [ control rod drives) to be tested." However, there was no direction in steps 8.4.2 through 8.4.15 to withdraw the next control rod to be tested.
The RO and SM informed the inspectors that form 2202.01F002' " Control Rod Maneuver
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Review," Revision 9, dated February 23,1999, contained directions telling the operators to start at step 8.2 of CPS No. 9813.01 for each rod. The inspectors later questioned whether or not form 2202.01 F002 met the requirements for a " procedure" with regard to the review and approval requirements noted in the TS Operational Requirements Manual (ORM). The Senior Engineer - Nuclear approved the form, but not the Manager - Clinton Power Station as required by the ORM. The SM acknowledged that he did not have adequate approved procedural guidance for rod testing and instituted a temporary change to CPS No. 9813.01 to allow a return to the proper step after testing each rod so that the next rod could be withdrawn. The inspectors were concemed that the RO and SM had decided that the instructions contained in form 2202.01F002, a document which did not meet the ORM requirements for an approved procedure, were sufficient to allow performance of steps in approved procedure CPS No. 9813.01 in a different order than written.
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Criterion V of Appendix B to 10 CFR Part 50 required, in part, that procedures affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances. Licensee procedure CPS No. 9813.01," Control Rod Scram Time Testing," Revision 30, a procedure affecting quality because it directed reactivity changes, was not appropriate to the circumstances in that the sequence of steps, as written, did not provide proper U!rection for the withdrawal of subsequent control rods under the existing plant configuration. This procedure deficiency is
- considered a violation of Criterion V of Appendix B to 10 CFR Part 50. This Severity
' Level IV violation is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. (NCV 50-461/99004-03(DRS)). The licensee addressed
- the issue in the corrective action program as Condition Report No.1-99-03-236, dated March 17,1999.
Division 2 Diesel Generator Testina On March 3,1999, the inspectors observed operators conduct a surveillance test on the division 2 EDG in accordance with CPS No. 9080.01, " Diesel Generator 1 A(B)
Operability - Manual and Quick Start Operability," Revision 44. Revision 44 of the procedure contained narrower acceptance bands for voltage and frequency than had been acceptable in the past. The procedure also contained revised steps for EDG shutdown so that operators would shut down the EDG at rated conditions of voltage and frequency "to ensure that [the EDG] will start and achieve the narrower acceptance criteria required by the above changes." In addition, Revision 43 of the procedure had changed the instrument to be used to measure the generator output voltage from the control board meter to a computer point to improve the accuracy of the reading.
The licensee declared the EDG inoperable because it did not meet the new surveillance test acceptance criteria for frequency which had been narrowed to 59.8 to 60.2 hertz.
During the first test, the EDG initially stabilized at 60.3 hertz. Operators adjusted the frequency to be within f.he required range, and also adjusted the EDG output voltage to
. be closter to the center of the specified range of 4140 to 4160 volts. A second surveillance test performed later in the day resulted in the EDG again stabilizing at 60.3 hertz. The licensee considered the EDG inoperable until the situation was evaluated in operability determination 1-99-03-053-OD1 as discussed in Section 01.2 of this report. The operability determination found 60.3 hertz to be' acceptable. The inspectors noted the following inadequacies in the surveillance test procedure:
The operators were initially unable to adjust the voltage successfully because the
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computer display changed in large increments. The operators asked the shift engineer to check the data compression setting for the computer point for
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generator output voltage. The shift engineer discovered that the setting was 26 volts, meaning that the computer display would not change until the measured voltage changed by at least that much. That made it very difficult to set the
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i voltage within a 20 voit band. The CRS completed the surveillance test as written after the shift engineer reset the data compression setting to zero.
On March 4,1999, in anticipation of running a similar test on the division 3 EDG,
' the SM mviewed the operational design of EDG govemor circuits with the system engineer. These individuals determined that, although the division 3 EDG would j
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s maintain the last frequency setting when shut down, the division 1 and 2 EDGs were designed to automatically retum to a preset null frequency setting after each run. Therefore, the revised steps in CPS No. 9080.01 to ensure that the EDG would start within the narrower acceptance criteria were inadequate in that instructions were not provided to change the frequency settings to a proper as left value after the EDG is shut down.
Criterion V of Appendix B to 10 CFR Part 50 required, in part, that procedures affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances. Procedure CPS No. 9060.01," Diesel Generator 1 A(B)
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Operability - Manual and Quick Start Operability," Revision 44, a procedure affecting quality because it verified the operability of the EDGs, was not appropriate to the circumstances in that the procedure provided erroneous information for adjusting the
. generator frequency when the EDG was shut down.- In addition, the procedure did not -
verify the proper computer point compression settings to ensure that accurate generator output voltage measurements could be taken. This was considered a violation of Criterion V of Appendix B to 10 CFR Part 50. This Severity Level IV violation is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. (NCV 50-461/99004-04(DRS)). The licensee addressed this issue in the corrective action program as Condition Report No. 1-99-03-426, dated March 31,1999.
c.
Conclusions The inspectors determined that the operations procedures reviewed, with only a few exceptiens, were adequate to perform the intended tasks. These exceptions included a control rod scram time surveillance test procedure which failed to direct the withdrawal of subsequent control rods under the existing plant configuration and an EDG surveillance test procedure which failed to ensure that acceptable frequency and voltage requirements could be met. The inspectors considered these inadequate procedures to constitute non-cited violations.
O3.2 Safety System Tao-out Process a.
Inspection Scooe (93802)
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The inspectors reviewed CPS No. 1014.01, " Safety Tagging," Revision 26, verified one active tagout in place, and observed the removal of one tagout. The inspectors also verified the performance of monthly reviews, and reviewed safety evaluations for specific tagouts as well as reviewed annual tagout verifications conducted by the licensee.
- b.
Observations and Findinos Safety Tacout Procedure The inspectors referenced CPS No.1014.01 " Safety Tagging" and determined that the procedure was adequate, however the inspectors identified the following four procedure enhancement opportunities:
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Secticn 1.0 of Appendix C," Disabling Air-operated Valves," contained
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instructions for disabling vane-type, air-operated valves (AOVs) that were used as isolation points during the tagout process. The vane-type AOV has a self-contained air accumulator that is independent of the main air supply line, in this instance, the procedure referenced the vane-type AOV whose accumulator does not have an air bleed valve. The instructions directed the user to place the valve
in the desired position from its remote hand switch and then verify locally that the
.. valve was in the desired position. Finally, the instructions noted that "if the valve fails in the same position as the desired position, place a " Danger" or " Caution" tag on the air isolation valve." The inspectors were concemed that with the accumulator still pressurized and connected, the AOV was not positively disabled contrary to the situation implied by the procedure section title.
Section 8.5," Tag Placement," provided guidance on placing safety tags on
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electrical breakers that did not reflect the actual placement of tags in the field observed by the inspectors during their plant walkdowns. Section 8.5 stated, in part, that when placing a tag on breakers it "should" be placed on the locking device (handle), unless the breaker is being removed from the cubicle. The inspectors found some safety tags for electrical breakers hanging on the panel door versus the operating device for the breaker. The majority of those tags were on the cubicle door's latching bolt. Although some of the brcaker handles or breakers had been removed, most of the tags were hung for other than breaker work, such as long-term isolation of the RHR steam condensing mode.
Operations personnel acknowledged that typical tagging of a breaker required the placement of the tag on the operating device. However, shift supervision acknowledged that there were interpretation problems with the procedure and that operator performance during the hanging of tags on breakers was not consistent with management expectations. The inspectors identified that the use of the term "shall" instead of "should" could have led to more consistent compliance with the procedure and eliminated interpretation probierr,s for tag placement on the electrical breaker energy isolating device (handle).
Another issue involved the lack of procedural guidance regarding the isolation of
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on/off type breakers with no or non-functioning mechanical interlocks when those breakers were being used as an isolation point for work other than breaker work.
Use of the temporary lift process to remove the breaker from the cubicle would prevent inadvertent actuation of the breaker and add an another layer of
. protection for the worker and equipment during performance of maintenance activities, Section 8.14 required that approximately 10 percent of all active tagouts greater
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than one month old be field verified, but did not contain procedural guidance and documentation for this verification process. The licensee allowed a clerk to select 10 percent of the active tagouts and submit them to operations personnel for field verification. However, the licensee did not keep a list of the selected tagouts or record the total number of active tagouts at the time of the selection. Therefore, sufficient documentation did not exist to easily determine if the licensee properly and adequately performed the annual verification requirement.
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Safety Tacout lmolementation And Reviews The inspectors checked the installation of Tagout 990356 on RHR SDC suction valves 1E12-F008 and 1E12-F009. The tagout documentation listed the proper switches and components to properly isolate the valve. The control switch for 1E12-F009 contained a caution tag to caution operators about ensuring the operability of the SDC function. The inspectors determined that all tags were hung properly.
The inspectors observed removal of safety tags for Tagout 990363 associated with fuel pool cooling pump B. The FS conducted a pre-job briefing. During the briefing, the FS discussed the tagout scope and job scope. He also discussed the proper tagout verification method because some tags had been individually removed and some had been temporarily lifted. The FS discussed the proper order for restoring the tagout and what to expect at the pump. After the briefing, the inspectors observed the operator rack in the electrical breaker. The operator verified that he was racking in the correct breaker by counting the breakers on the bus and by verifying that the compartment labels matched the tagout documentation. During restoration of both the valves and the breaker, the operator stayed clear of the area until notified to perform the verification activity.
The inspectors reviewed the documentation associated with monthly tagout reviews, safety evaluations for specific tagouts, and annual tagout verifications. The licenseo maintained the tagout index in accordance with procedure. In addition, the weekly tagout report tracked the age of tagouts and identified the tagouts that required safety evaluations. Procedure CPS No. 1014.01, Section 8.13, required that safety evaluations be performed for tagouts greater than six months old. The inspectors reviewed a random sample of tagouts and found that all tagouts greater than six months old had safety evaluations.
c.
Conclusions Operators properly implemented safety system tagout activities as observed by the inspectors. However, the inspectors identified some problems with the procedural guidance contained in procedure CPS No. 1014.01, " Safety Tagging," and with operator understanding of the procedural guidance. These included a lack of guidance for disabling vane-type AOVs without accumulator air bleed valves; a lack of procedural understanding by operators for safety tag placement on electrical breakers; a lack of procedural guidance for on/off electrical breakers with non-functioning mechanical interlocks; and a lack of administrative guidance for documenting an annual field verification of active safety tagouts.
Operator Knowledge and Performance 04.1 Operations Command And Control a.
Insoection Scope (93802)
The inspectors observed the activities directed by three MCR operating crews during the first week and four crews the second week of the inspection. The inspectors compared
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and assessed the first and second inspection week's observations pertaining to operator command and control based on the level of plant work activity.
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Observations and Findinas During the first week of the inspection, the majority of plant work activities were primarily performed by only one of three crews. The inspectors observed that the CRS on that I
one specific crew demonstrated the following command and contrel deficiencies:
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- The inspectors observed a failure to follow-up on questionable work activities by
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the CRS during a division i shutdown service water flow balance surveillance
- test. This surveillance test required the crew to raise RHR header pressure by
--adjusting valve E12-F024, "RHR Suppression Pool Test Retum" to throttle down RHR "A" flow to 4500 gpm. One of the MCR ROs questioned if manually opening E12-F024 would make the valve inoperable; however, the CRS directed the evolution to be performed anyway. Prior to commencing actions to adjust RHR flow and thereby raise system pressure, the RO pursued the issue and identified that CPS No.1401.09," Control Of System And Equipment Status," Revision 1, Section 8.11.1.2, identified that the valve would be considered inoperable.
l The inspectors observed one instance in which verbal directions given by the
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CRS did not reflect knowledge of the plant configuration. The CRS provided instructions that in the event of inadvertent rod motion or criticality during control rod scram time testing, the reactor was to be scrammed by placing the reactor mode switch in shutdown. However, a MCR RO subsequently pointed out to the CRS that the reactor mode switch would be locked in the refuel position during the testing and could not be placed in the shutdown position as the CRS had instructed. The CRS provided new instructions to the RO to scram the reactor if
- required by using the manual pushbuttons.
The inspectors observed a lack of supervision of control rod movements contrary
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to procedures (non-cited violation, Section 01.3).
The inspectors also observed several failures of the CRSs to control the number of personnel in the MCR horseshoe area during control rod venting and scram time testing during the first week of the inspection. The inspectors identified these concems to
' licensee management.
During the second weok of the inspection, the inspectors observed that cll four crew CRSs demonstrated an appropriate level of command and control. The amount of plant work activity exceeded that of the first week and was distributed among the four crews.
The inspectors observed that CRSs were conscientious in reinforcing the use of three-way communications in the MCR and in identifying cleared alarms. The inspectors also observed that, in general, the CRSs maintained a position of authority and oversight; performed correct diagnosis of events due to equipment problems; and directed appropriate operator actions in accordance with procedures. However, although the licensee posted signs to direct traffic and minimize the level of talking, the inspectors continued to identify instances of too many people in the horseshoe area.
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_Qs.nclusions
- A CRS on one of the three crews observed by the inspectors during the first week of the inspection exhibited several instances of command and control deficiencies. These
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Quality Assurance in Operations 07.1 Ooerational Testina and Review Process a.
Inspection Scope (93802)
The inspectors assessed the management and quality control checks associated with six recently completed surveillance test packages. The inspectors completed a comparative review of test packages and requirements contained in CPS No.1011.02,
" Implementation and Control of Surveillance Testing," Revision 19, and Change No. PAC 0126-99, dated January 19,1999.
b.
Observations and Findinas The inspectors verified that the surveillance test packages had been reviewed, assembled, and approved in accordance with the most recent revisions of the program procedures. The operators properly marked each completed step of the surveillance test procedures as required by the procedure instructions. The completed surveillance test procedures either met all acceptance criteria or had corrective actions implemented.
The inspectors reviewed the calibration records for the measuring and test equipment used in the testing and noted that they were in calibration with the proper range and accuracy as required by the procedures. The inspectors verified that the immediate supervisors and operations shift management reviewed and app'oved the test results r
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packages as required by the surveillance test control program procedure.
c.
Conclusions The CRSs and operations shift management reviewed, approved, and controlled the
- surveillance test result packages in accordance with the surveillance test control program procedures, p
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Miscellaneous Operations issues O8.1 (Closed) Case Specific Checklist item IV.1. " Establish Proaram to Reduce and Maintain Main Control Room Deficiencies:"
The inspectors concluded that the licensee had established an adequate program to identify, track, and resolve operator workarounds and main control room deficiencies as described in Section O2.1. The inspectors considered this item closed.
V. Manaaement Meetinas X1 Exit Meeting Summary The preliminary results of the team inspection were presented to the licensee management at an onsite exit meeting on April 7,1999. The licensee acknowledged the findings presented and did not identify any material provided during the inspection as proprietary.
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PARTIAL LIST OF PERSONS CONTACTED Licensee G. Baker, Manager - Quality Assurance V. Cwietniewicz, Manager - Maintenance R. Frantz, Licensing J. Goldman, Manager - Work Management
. J. Hanson, Director of Nuclear Training P. Hinnenkamp, Assistant Plant Manager G. Hunger, Plant Manager K. ~ Johnson, Manager - Nuclear Support
. W. Maguire, Director - Operations J. McElwain, Chief Nuclear Officer W. Romberg - Manager - Degraded Voltage J. Sipek, Director-Licensing P. Telthorst, Operations Support Manager
' M. Tacelosky, Operations Services Manager D. Warfel, Manger - Nuclear Station Engineering Department
.NRC T. Kozak, DRP Branch Chief
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T. Pruett, Senior Resident inspector K. Stoedter, Resident inspector
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C. Brown, Resident inspector D. Hills, DRS Branch Chief M. Bielby, inspection Team Leader
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l1 INSPECTION PROCEDURES USED
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l IP 98302:
Operational Safety Team inspection (OSTI)
- IP 71707
Operational Safety Verification p
IP 71715:
Sustained Control Room and Plant Observations
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IP 40500:-
Evaluation of Licensee Self-Assessment Capability ITEMS OPENED, CLOSED, AND DISCUSSED
Opened-50-461/99004-01
~NCV
- Control room supervisor did not directly supervise reactivity.
changes during control rod scram time testing contrary to procedure 50-461/99004-02-NCV Failure to perform temporary modification quarterly audit contrary to procedure 50-461/99004-03 NCV Control rod scram time surveillance test procedure inadequate in that it did not direct the withdrawal of
' subsequent rods under the plant configuration
' 50-461/99004-04 NCV.
Emergency diesel generator surveillance test procedure -
inadequate in that it did not ensure that acceptable frequency. requirements could be met Closed 50-461/99004-01.
NCV Control room supervisor did not directly supervise reactivity -
changes during control rod scram time testing contrary to procedure :
.50-461/99004-02 NCV.
Failure to perform temporary modification quarterly audit contrary to procedure
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50 461/99004-03 NCV
' Control rod scram time surveillance test procedure inadequate in that it did not direct the withdrawal of subsequent rods under the plant configuration 50-461/99004-04 NCV Emergency diesel generator surveillance test procedure inadequate in that it did not ensure that acceptable frequency requirements could be met
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~ Alternating Current AOV Air Operated Valves AR Action Request CFR Code of Federal Regulations CNP Corporate Nuclear Procedure CPS Clinton Power Station.
CR:
Condition Report.
CRS Control Room Supervisor
'CRD Control Rod Drive DRP Division of Reactor Projects l
DRS Division of Reactor Safety ECCS Emergency Core Cooling System EOP Emergency Operating Procedure ERAT Emergency Reserve Auxiliary Transformer FIN Fix-it-Now
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FPC&A:
Fuel Pool Cooling and Assist FRG Facility Review Group FS Field Supervisor IFl Inspection Followup Item IP'
inspection Procedure LER Licensee Event Report LPCS Low Pressure Core Spray LPRM Local Power Range Monitor MCR.
Main Control Room NCV Non-Cited Violation NOV Notice of Violation-
NRC'
Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NWR'
Nuclear Work Request-ORM Operational Requirements Manual
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~ PMT Post-Modification Testing
' QA Quality Assurance RHR Residual Heat Removal
~ RO
- Reactor Operator RP Radiation Protection-i SDC Shutdown Cooling SLC Standby Liquid Control SM-Shift Manager SRM Source Range Monitor
- SVC Static VAR Compensators TS Technical Specification USAR-Updated Safety Analysis Report URI Unresolved item USQ Unreviewed Safety Question
- VAR:
Volt Ampere Reactive
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Work Control Supervisor I
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PARTIAL LIST OF DOCUMENTS REVIEWED The following is a list of licensee documents reviewed during the inspection, including documents prepared by others for the licensee. Inclusion on this list does not imply that NRC inspectors reviewed the documents in their entirety, but rather that portions or selected portions of the documents were evaluated as part of the overallinspection effort. NRC acceptance of the documents or any portion thereof is not implied.
Procedures CPS No.1000.11
" Work Priority Assignment and Implementation," Revision 4 CPS No.1014.01
" Safety Tagging," Revision 26 CPS No.1014.03
"" Temporary Modifications," Revision 18 CPS No.1014.06
" Operability Determinations," Revision 3 and 4 CPS No.1016.01
" Condition Reports," Revision 32 CPS No.1029.01
" Action Request and Maintenance Work Orders," Revision 36 CPS No.1029.03
" Implementation of Fix It Now (FIN) Process," Revision 3 CPS No.1312.03
"RHR - Shutdown Cooling & Fuel Pool Cooling and Assist,"
Revision 2 CPS No.1401.01
" Operating Philosophy," Revision 30 CPS No.1401.02
" Operations Department Organization, Duties, and Responsibilities," Revision 6 CPS No.1401.03
" Control Room Professionalism," Revision 7 CPS No.- 1401.04
" Shift Tumover and Relief," Revision 3
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CPS No.1401.05
" Operator Logs and Records," Revision 0 CPS No.1401.06
" Procedures and Operator Aids," Revision 5 CPS No.1401.07
" Communicating Information," Revision 0 CPS No.1401.09
" Control of System and Equipment Status," Revision 1 CPS No.1401.11
" Planning and Control of Evolutions," Revision 0 CPS No.1401.12 '
" Shift Manapement Oversight," Revision 0 CPS No.1401.13
" Operations Department Training and Qualifications," Revision 0 35-
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CPS No.1401.15
" Alarm and Transient Response," Revision 0 CPS No.1406.01
" Annunciator Tracking Program," Revision 11 CPS No. 2825.37
' " ERAT Static VAR Compensator Integrated Test," Revision 0 CPS No. 3312.03
" Shutdown Cooling & Fuel Pool Cooling and Assist, Revision 2 CPS No.' 3506.01
" Diesel Generator and Support Systems," Revision 25 CPS No. 4406.01 -
" Secondary Containment Control," Revision 24 (EOP 8)
CPS No. 9053.05.
"RHR/LPCS Valve Operability (Shutdown)," Revision 36~
CPS No. 9061.04.
" Containment / Drywell isolation Automatic Actuation," Revision 37 CPS No. 9080.01 :
" Diesel Generator 1 A(B) Operability - Manual and Quick Start Operability," Revision 44
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Condition Reoorts 1-98-02-059-
"480V Molded Case Circuit Breaker - Failure to Function as Expected," February 4,1998 1-98-02-228
" Design Setpoint Outside Vendor Stated Setpoint Range,"
February 19,1998 1-98-02-518
" Failure of Molded Case Circuit Breaker To Open," February 27, 1998 1-98-03-530 ECN 29249 - Problems in the Safety Evaluation, the Calculation,
"
- and the Update of Affected Documents," March 26,1998 1-98-04-047:
" Service Water Has No Surveillance to Simulate Overall Flow-Capabilities of Components for Loss of Offsite Power or Loss of Coolant Accidents," April 3,1998 1-98-10-002
" Annunciators Out-of-Service For More Than Six Months Without i
Safety Evaluations Being Completed," October 1,1998 j
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1-99-01-053
" Operability Determination Not Approved Prior to Reliance on OD Basis for Equipment Operation," January 10,1999 l
"S' fety Screening Not Performed on Aging Tagout Greater Than 1-99-01-097 a
Six Months Old," January 13,1999 1-99-02-158
" Fuses Not Tested For Use in DC Applications," February 12, 1999 1-99-02-283
"No Handwheel Tag on 1SX014A," February 16,1999
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Operability Determinations / Evaluations L
1-98-09-201-OD
" Evaluate Division 2 Service Water Operability Based on Division 1 Flow Balance Results, Revisions 0 & 1, September 12,1998 1-98-09-201-OE-1
" Evaluate Division 2 Service Water Operability Based on Division 1 Flow Balance Results, Revision 0. September 18,1998 l
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1-98-09-201-OE-2
" Evaluate Division 2 Service Water Operability Based on Division 1 Flow Balance Results, Revision 0, October 7,1998 1-98-09-390-OD
" Service Water Division 2 Pump Had Amperage Outside " Green"
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Band," Revision 0, September 25,1998 1-98-10-234-OD Residual Heat Removal Heat Exchanger Demineralized Water..
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Inlet Valve Failed to Stroke Shut During Surveillance," Revision 0, October 17,1998 1-98-11-299-0-OD
" Electrical Protection Assembly Circuit Board Does Not Provide Trip Function in Time as Intended in General Electric Specification," Revision 1, January 10,1999; Revision 2, January 18,1999; Revision 3, March 1,1999 1-98-11-299-0-OE1
" Electrical Protection Assembly Circuit Board Does Not Provide Trip Function in Time as intended in General Electric Specification," Revision 1 January 10,1999 Revision 2, January 17,1999; Revision 3, February 28,1999
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1-98-12-272-OD
" Determine Room Cooler and Low Pressure Cooling System Operability with Air-Operated Valve 1SXO33 Failed Open,"
Revision 0, December 28,1998 1-98-12-274-OD
" Evaluate Residual Heat Removal Heat Exchanger Shell Side Temperatures Below 40 Degrees," Revision 0. December 31, 1998 1-98-12-275-OD
" Maintain Minimum Flow for Service Water Pump Using Flow Through Residual Heat Removal Heat Exchangers Due to Bypass Valve Being inoperable" Revision 0, January 21,1999 1-98-12-275-OE
" Maintain Minimum Flow for Service Water Pump Using Flow Through Residual Heat Removal Heat Exchangers Due to Bypass Valve Being inoperable" Revision 0, February 13,1999 i
l 1-99-01-318-OD
" Heavy Fouling of Post Accident Sampling System Room Cooler j
and Low Service Water Flow to the Post Accident Sampling System," Revision 0, February 3,1999
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1-99-01-318-OE-1
" Heavy Fouling of Post Accident Sampling System Room Cooler and Low Service Water Flow to the Post Accident Sampling System," Revision 0, February 2,1999 j
i 1-99-02-077-OD-1
" Insufficient Voltage to Selected 120V Circuits," Revision 0,
{
February 6,1999 1-99-02-077-OE-1
" Insufficient Voltage to Selected 120V Circuits," Revision 0, February 19,1999
1-99-02-085-OD-1
" Breaker for ORA 01CB Failed to Shunt Trip During Performance of 9061,04," Revision 0, February 6,1999
'1 -99-02-085-OE-1
" Breaker for ORA 01CB Failed to Shunt Trip During Performance ~of i
9061.04," Revision 0, February 19,1999
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1-99-02-158-OD-1
" Fuses Not Rated for Their DC Interrupting Capability," Revision 0,
February 13,1999
1-99-02-158-OE-1 -
" Fuses Not Rated for Their DC Interrupting Capability," Revision 0, February 17,1999 1-99-03-053-OD1
" Division 2 EDG Failed to Maintain Steady State Frequency Band of 59.8 to 60.2 Hz as Required by Technical Specification Surveillance Procedure CPS 9080.01," Revision 0, March 03, 1999 Enaineerina Evaluations EE 1-97-11-368*
" Division ll1 Diesel Generator Jacket Water Cooler Performance Test Evaluation," Revision 0, January 17,1999 EE 1-97-11-368*
" Service Water Test Results Evaluation and Resolution of Restraint Actions," February 2,1999 EE 1-9843-530
" Significance of Condition Report 1-98-03-530," Revision 0, March 27,1998 -
EE 1-98-09-201
" Engineering Evaluation of Division 2 Service Water Mode 4 i
Operational Status," Revision 0, September 17,1998
Number not unique Enaineerina Chance Notices 31437
" Revise Flow Rates and Temperatures to the Post Accident Sampling System Heat Exchanger (1PSO4S) and the Post Accident Sampling System Room Cooler (1VA20S)," February 12, 1999
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- 'o Surveillance Test Packaaes l
CPS No. 9030.01C006
"RCIC Reactor Vessel Level 2 B21-N692A (B,E,F) Channel Functional Checklist," Revision 24, November 15,1995
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CPS No. 9030.01C041/D041 RCIC Turbine Exhaust Diagram Pressure E51-N655A (B,E,F) Channel Functional Checklist," Revision 22, Dated February 8,' 1996 CPS No. 9030.01C042/D042 "
RCIC Suppression Pool Level E51-N636A(E) Channel Functional Checklist," Revision 24, February 8,1996 CPS No. 9433.16
"RCIC Storage Tank Level E51-N035A(E) Channel Calibration," Revision 31, March 4,1996
l CPS No. 9433.16D001
"RCIC Storage Tank Level E51-N035A Channel Calibration Data Sheet," Revision 33, August 2,1997
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l CPS No. 9382.01
"125 VDC Battery Pilot Cell Check," Revision 29,
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February 10,1999
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