ML19325C571

Responds to NRC 890905 Ltr Re Violations Noted in Insp Rept 50-461/89-26.Corrective Actions:Procedure 3001.01 Revised to Include Step in Prerequisite Section of Procedure to Place RHR in Standby Mode

ML19325C571
Person / Time
Site:	Clinton
Issue date:	10/03/1989
From:	Holtzscher D ILLINOIS POWER CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-601538, NUDOCS 8910170076
Download: ML19325C571 (6)

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1A.120 q llLLIN0/8 POWER COMPANY

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- CLINTON POWIR STAtlON, P.O. Box 678, CLINTON, ILLIN0ls ein? - .

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,R October 3, 1989

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..i j k -- Docket No,' 50-461:

J .i m'  ; Mr.- . A'.L B.' Davis

Regional? Administrator

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Region III - , .

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- .U.S. Nuclear Re5ulatory Commission 799: Roosevalt' Road -~

Glen' El'.yn, ; Illinois- l 60137 'I r ,

Subject:

Response'to Notice of Violation.in NRC Inspection j Reoort 50-461/89026 dated Sectember S.1989 f

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Dear'Mr.:

Davisi ,

i This 1stter provides the Illinois Power Company (IP) response to the-Notice of Violation in NRC Inspection Report 50 461/89026', The. '

Notice of Violation concerned two examples.of entering an OPERATIONAL  ;

LCONDITION.without meeting the requirements of Technical Specification. j L Limiting Conditions for Operation, l

'IP. believes that the1information contained in this letter l adequately; responds to the NRC Notice--of-Violation, Sincerely yours,.  !

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5 D. L. Holtzscher j Acting Manager -

Licensing and Safety <

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v >cc: NRC Clinton Licensing Project- Manager NRC Resident Office Illinois Department of Nuclear Safety t

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.' Response to Notice of Violation in.

/ Inspection Report 50 461/89026 y

The Notice of Violation states in part:

'. . . a . on July 24,'1989, the-licensee entered OPERATIONAL CONDITION 2 (Startup).without meeting the conditions of Limiting Condition for Operation 3.5.1 which required that Emergency Core Coolinc, Systems Divisions I, II and III be OPERABLE. ECCS Division II was not OPERABLE due to Residual Hect Removal System "B" being "

lined up in the Shutdown Cooling Mode.

b. On July 24, 1989, the licensee entered OPERATIONAL '

CONDITION 2-(Startup) without meeting the conditions '

of. Limiting Condition for Operation 3.3.7.5 which.

required that the Safety / Relief Valve Acoustic Monitor channels be OPERABLE. The Acoustic Monitor for t Safety / Relief Valve F051G was not OPERABLE and the .;

backup Discharge Line Thermocouple Recorder was not energized."

< .I. Background and Cause of This Violation On July 24, 1989, the' plant was in Mode 4'(COLD SHUTDOWN). The reactor temperature was approximately 125 degrees Fahrenheit and pressure was approximately eighty pounds per square inch gauge ,

(psig)- Loop B of the Residual Heat Removal System (RHR) was operating in the shutdown cooling mode. Loops A and C of RHR were o in the standby mode. (When a loop of RHR is in the standby mode,

'_ Low Pressure Coolant Injection (LPCI) can automatically initiate.)

f Preparations for entering Mode 2 (STARTUP) and withdrawing control rods were in progress. These preparations included performance of procedure. 3001.01, " Approach to critical". In conjunction with performance of procedure 3001.01, Operations personnel were 1 completing the Mode 2-Checklist, 3001.01C002.

When preparations for entering Mode 2, including completion and review of the Mode 2 Checklist, were believed to be complete, the l L :Line Assistent Shift Supervisor (LASS) informed the Shift lT Supervisor (SS) that preparations for entering Mode 2 were

.. complete. The SS than directed the senior reactor operator to place the reactor mode switch in the startup/ standby position.

.At 1147 hours0.0133 days <br />0.319 hours <br />0.0019 weeks <br />4.364335e-4 months <br />, the reactor mode switch was placed in the startup/ standby posicion and the plant entered Mode 2.

At 1203 hours0.0139 days <br />0.334 hours <br />0.00199 weeks <br />4.577415e-4 months <br />, operators commenced control rod withdrawal.

At 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br />, loop B of RHR was secured from the shutdown cooling mode and placed in standby, The plant was then in compliance with the requirements of Technical Specification 3.5.1.

Shortly after the plant entered Mode 2, the Shift Supervisor realized that Technical Specifications may have been violated because loop B of the RHR was operating in the shutdown cooling 1 (1)

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' Response;to Notice of Violation in Inspection Report-50-461/89026 mode when the plant' entered Mode 2. The SS, after discussing the possible Technical Specification violation with the IASS, consulted the Technical Specifications to determine if the.

u requirements of the Technical Specifications had been met. The L LCO for Technical Specification 3.5.1 requires that the Low 1: Pressure Coolant Injection (LPCI) mode of all three loops of RHR be operable, each with a flow path capable of taking suction from the suppression pool and transferring the water to the reactor f vessel. This Technical Specification is applicable to Modes 1 (POWER OPERATION), 2, and 3 (HOT SHUTDOWN). This Technical Specification has a Note which allows one loop of RHR to be L aligned-in the shutdown cooling mode when reactor pressure is less than the LPCI cut-in permissive setpoint (135 psig). The 1 ASS incorrectly believed that this Note permitted entering Mode 2 with l one loop of RHR operating in the shutdown cooling mode. However, this Note is only applicable to Mode 3.

-When RHR-is operating in the shutdown cooling mode, LPCI will not L automatically initiate and'is therefore inoperable. Since loop B of RHR was operating in the shutdown cooling mode when the plant entered Mode 2, and since the Note is only applicable to Mode 3,

,. the LCO of Technical Specification 3.5.1 was not met prior to l entering Mode 2. This was a violation of Technical Specification 3.0.4.

At approximately 1645 hours0.019 days <br />0.457 hours <br />0.00272 weeks <br />6.259225e-4 months <br />, the Shift Technical Advisor noted that reactor temperature and pressure were high enough to obtain data on safety relief valve (SRV) leakage. Corrective maintenance had been performed on the acoustic monitor for SRV 1B21-F051G l while the plant was shut down. The acoustic monitor for SRV 1B21-L 'F0510 could not be considered operable until post maintenance -!

! testing, required to be performed at normal operating pressure, could be satisfactorily completed. Since the acoustic monitor for

-SRV IB21-F051G was inoperable the tail pipe temperature was required to be monitored. The STA therefore attempted to obtain

l. leakage data for SRV IB21-F051G from the tail pipe temperature I

recorder however, no readings were being recorded. The l

temperature recorder for SRV 1B21-F0510 was immediately placed in  !

service.

i Investigation revealed that, although-the power supply switches on the external surfaen of the temperature recorder for SRV i 1B21-F051G indicated thr.t power was available to the recorder, an internal switch was turned off so no indication of temperature was being supplied to the recorder. The tail pipe temperature recorder for SRV 1B21-F051G was therefore inoperable.

Prior to entering Mode 2, the B-area control room operator performed a walkdown of main control room panels to ensure that the recorders required to be operable in Mode 2 were in service.

During this walkdown, the operator checked the external switch position of the temperature recorder for SRV 1B21-F051G but failed l

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Response to Notice of Violation in Inspection Report 50 461/89026 to ensure that a temperature was being recorded. The operator-incorrectly believed that all' required recorders were operable.

'The LCO for Technical Specification 3.3.7.5 requires that the acoustic-tail pipe monitor _for each SRV be operable in Modes 1, 2 and 3. If the acoustic monitor is inoperable, the Technical SpecL** cation can be met by monitoring tail pipe temperature. The acoustL monitor for SRV IB21 F0510 was inoperable and therefore tail pipe temperature was required to be monitored. Since the temperature recorder was not in service, the requirements of the LCO for Technical Specification 3.3.7.5 were not met prior to entering Mode 2. This was a violation of Technical Specification 3.0.4. .!

.The cause of the failure to meet the requirements of the LCO for Technical Specification 3.5.1 prior to entering Mode 2 is attributed to personnel error by a utility licensed operator. The j Line Assistant Shift Supervisor incorrectly believed that the Note of Technical Specification 3.5.1 was applicable to Modes 1, 2 and

3. He believed that the requirements of Technical Specification 3.5.1 would be met if the LPCI mode of RHR was operable prior to the reactor pressure reaching 135 psig. This error is attributed i to a lack of understanding of this Technical Specification 3.5.1 and how it is implemented in procedures.

Procedure 3001.01 does contain a step which requires securing any loops of RHR operating in the shutdown cooling mode and placing them in standby. However, the procedure does not indicate that the loops must be placed in standby prior to entering Mode 2. If this step had been noted in procedure 3001.01 as a prerequisite to entering Mode 2, the Technical Specification violation would not have occurred. l The cause of the failure to meet the LCO for Technical f l Specification 3.3.7.5 prior to entering Mode 2 is attributed to j l- personnel error by a utility licensed operator. The B area (j control room operator failed to verify that the temperature L recorder for SRV 1B21-F051G was recording tail pipe temperature. i I: Although power supply switches on the external surface of the l1 temperature recorder indicated that power was available, no i

[- temperature was being recorded on the recorder chart because an  ;

internal switch was turned off. The operator failed to check the '

internal switch position and failed to verify whether temperature l was being recorded.

The operacor who secured the recorder while the plant was shut down failed to mark on the chart paper in an obvious manner that the recorder was secured. The mark that was made on the chart l paper was not obvious and was not visible with the cover plate of

!- the recorder shut. Additionally, this operator failed to add this temperature recorder to the Mode Change Restraint List.

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Response to Notice of Violation in Inspection Report _50 461/89026 II. Corrective Actions Taken and Results Achievad At 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br />, loop B of RHR was secured from the shutdown cooling mode and placed in standby. The plant was then in compliance with 1 the requirements of Technical Specification 3.5.1.

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When the temperature recorder for SRV 1B21 F051G was found shut down it was immediately placed in service. The plant was then in j compliance with the requirements'of Technical Specification j 3.3.7.5. A walkdown was performed to verify that all other l required recorders were in service. l i

Post maintenance testing of the acoustic monitor for SRV 1B21- J F0510 was completed .with satisfactory results on July 26, 1989, at I 0452 hours0.00523 days <br />0.126 hours <br />7.473545e-4 weeks <br />1.71986e-4 months <br />. 1 Licensee Event Report (LER) 89 031-00 was issued to document this '

event.

i III, Corrective-Actions to Prevent Recurrence i Procedure 3001.01 has been revised to include a step in the 1 prerequisite section of the procedure to place RHR in the standby mode. This step has been identified as a Technical Specification requirement.

The 1 ASS and the control room operators involved in this event

l. have been counselled.

1 L A Night Order was issued reminding Operations shift crews that l_ whenever an-action is taken which affects a Technical Specification requirement, the effect of the action must be identified'and added'to the Mode Change Restraint List. ,

Operations personnel are aware that when a recorder is secured a j mark is to be made on the chart paper noting that the recorder is '

i: secured. In order to ensure that the chart paper is marked in an obvious manner, a Night Order was issued. directing personnel to mark.the chart in a manner visible with the cover plate of the L recorder shut.

l Training on mode changes, how to recognize "other specified i conditions" and Technical Specifications 3.0.X, Limiting condition for Operation, and 4.0.X, Surveillance Requirements has been ,

provided to Operations personnel during requalification training. V ,

L This training was more extensive than training previously provided N _;

l' to Operations personnel.

Additional Technical Specification training, consisting of simulator scenarios to demonstrate comprehension of, and compliance with, Technical Specifications involving mode changes, is scheduled to be complete by November 30, 1989.

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,1 ' Attachment Response 'to Notice of Violation in -

L Inspection Report 50 461/89026 1

The NRC Inspection Report, 50 461/89026, citing these violations -i states'that the' corrective actions for previously identified violations, including those documented in NRC. Inspection Report 50-461/89018, dated July 25, 1989, were apparently not effective.-

As documented in the IP response to NRC Inspection Report 50-5041/89018, IP letter U 601517, dated August 22, 1989, IP management has recognized errors made lLn handling recent events  ;

l and has initiated appropriate corrective action.- In addition to-those actions noted above and in LER 89 031, IP has retained a qualified consulting firm to assist IP in reviewing appropriate procedures which implement Technical Specifications, in ordor to provide further assurance that Technical Specification -

requirements.are fully met. The procedure review is expected to be complete by April 30, 1990 Recommendations resulting from the ,

review will be evaluated and ..ien appropriate incorporated into j procedures. -l IV. Date Full Como11ance Will Be Achieved Illinois Power will be in full compliance by November 30, 1989.

h The procedure review to provide further assurance that Technical Specification requirements are fully met will be completed by April 30, 1990.

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