ML20043D990

Responds to NRC 900413 Ltr Re Violations Noted in Insp Rept 50-461/90-02.Corrective Actions:Safety Evaluation Prepared & Reviewed for Level Instrumentation & Annunciators Identified in Updated SAR

ML20043D990
Person / Time
Site:	Clinton
Issue date:	05/14/1990
From:	Spangenberg F ILLINOIS POWER CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-601668, NUDOCS 9006110337
Download: ML20043D990 (5)

Text

r T Kp I 5-14)18'

'CLINTON POWER STATION. P,0, ItOX 678. CLINTON, ILLINOIS G17274678. TELEPHOh4 (217) 935 8881 1A.120

-l May 14, 1990 i

t f.

i .' Docket No. 50 461 t

Mr. A. B. Davis Regional Administrator .

L Region III U.S.. Nuclear Regulatory. Commission 799 Roosevelt Road '

Clen Ellyn, Illinois 60137

Subject:

- Response to Notice of Violation in NRC Inspection Report

-50 461/90002 dated Anril 13. 1990 ,

l

Dear Mr. Davis:

l L This latter provides the Illinois Power Company (IP) response to the L Notice of Violation in NRC Inspection Report 50 461/90002. The Notice of }

l Violation concerns revising a procedure to allow the use of administrative -

l methods for controlling radwaste sludte tank levels without performing an .

I evaluation to determine if the non utilization of the in place level '

l indicators and annunciators constituted an unreviewed safety question.

IP believes _the information contained herein adequately responds to the +

NRC Notice of Violation.

, Sincerely yours, ,

L

, F. A. Span .nberg Managel Lice sing and Safe J;.P/rgw Enclosure cc: NRC Resident Office NRC Region III, Regional Administrator INPO Recordc Center Illinois Department of Nuclear Safety NRC Clinton Licensing Project Manager E IO M

$$fkbbb7900514K0500$$I1 o

g()\

,n r

L . .!

Attachment Response to Ni; tee of Violation in Inspection Report 50 461/90002 The Notice of Violation states in part:

"10CFR50.59 (a)(1) allowed licensees to make changes to the facil'.ty as described in the Safety Analysis Reoort without prior NRC approval, provided that the change did not require a change to the Techni;al Specification, or involve an unreviewed safety question.

A proposed change shall be deemed to involve an unreviewed safety question if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased.

The Clinton Updated Safety Analysis Report, Sections 11.2.1.3.1 and 11.2.1.6 specified that all radwaste system tanks have both monitoring and hi6h level annunciation which are used to control tank levels.

CPS Procedure No. 3909.03, " Operating Waste Sludge System," Revision 11, dated Dec naber 19, 1988, describes methods for controlling the levels of radwaste sludge tanks.

Contrary to the above, on December 19, 1988, CPS Procedure No. 3909.03 was revised to allow the use of administrative methods for controlling liquid radwaste sludge tank levels, vice the installed level indicators and annunciators, without performing a review to determine if the non utilization of these level indicators and annunciators constituted an unreviewed safety question."

1. Background and Cause of Violation:

The level indication instrumentation and annunciation associated with the liquid radwaste (WX) system at Clinton Power Station (CPS) utilize ultrasonic devices to determine the liquid level and the liquid / sludge interface level in five radwaste system tanks. These instruments have operated erratically causing spurious alarms since there devices were tested during the startup phase. Administrative controls for five radwaste systems procedures were developed and placed into effect between June 18, 1986 and September 11, 1986, to deal with the instrumentation problems and assist in tank level determination. On July 18, 1986, administrative controls were established in CPS Procedure No. 3909.03, " Operating Waste Sludge System," utilizing tank level instrumentation in combination with inventory tracking (tracking tank inputs and discharges) to assist in tank level determination. The administrative controls were not intended to permanently replace the existing 1cvel indication and annunciation; they were intended to be used until the instrumentation was repaired or replaced.

In July 1986, at the time CPS Procedure No. 3909.03 was revised, the procedure which governed whether a safety evaluation was required, specified that non safety related procedures (including CPS Procedure Ne 3909.03) have bee' evaluated as not requiring a safety evaluation.

i 1

=

l l 1

In October 1988, the Safety Evaluation Manual was established. This-manual was prepared _in accordance with the draft guidance contained in NUMARC/NSAC 125 on safety evaluations. Department procedures were l

required to be revised within 90 days to incorpmate changes dictated by ,

the manual. On November 11, 1988, a Procedure Deviation for Revision to CP9 Procedure No. 3909.03 was prepared utilizing a soon to be superseded screening form. It was determined the individual who performed the screening had mistakenly not received the required training to perform safety evaluations.

During the period from startup testing through February 1990, high high level alarms on liquid radwaste tanks were removed from service or disabled as problems with individual alarms trose. CPS Procedure No.

1406.01, "Out of Service Annunciator Trackin,1," was used as the approved -

mechanism for doing so. CPS Procedure No. 1406.01 contains provisions i for an annunciator to be disabled if it meets the following criteria:

i (1) the annunciator is a distraction and masis other alarms, (2) the alarm is providing no meaningful information, and (?) disablin6 the kisrm has been approved by the Shift / Assistant Shift Supervisor. These ,

alarras were disabled to conform with the " blackboard" concept.

Procedure No.'1406.01 does not identify the need that a safety evaluation be performed when disablini, an annunciator, f The CPS Updated Safety Analysis Report (USAR) describes the liquid radwaste system tank level indication and annunciation in USAR Sections 11.2.1.5.1 and Table 11.2 4. 10CFR50.59(a)(1) allows changes to be made to the plant, as described in the SAR, without prior NRC approval -

provided the change does not require a change to the Technical Specifications or involve an unreviewed safety question. No safety evaluation was performed for the administrative controls for tracking tank levels or for disabling tank level alarms prior to the implementation.

I The cause of the violation can be attributed to inadequate procedures.

II. fr.Irective Action Taken and the Rerylts Achieved:

A safety evaluation haa now been prepared and reviewed for the level I instrumentation and annunciators identified in the USAR. 'The administrative controls which are being used will prevent tank overflows as required by U.S. Nuclear Rogulatory Ccmmission Regulatory Guide 1.143, " Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Lic,ht Wator cooled '1uclear Power Plants." The results of this safety evaluation have concluded that no Technical Specification changes are required and an unreviewed safety question does not exist.

A corrective action was taken to ensure that radwaste personnel, who are required to perform safety evaluations are properly trained. This action was completed by identifying those personnel who have completed the training and limiting future safety evaluation reviews to just those qualified staff members.

2

III. Correerivg_Aetion Taken to Avoid Further Violations:

The Nuclear Safety section of the Licensing and Safety Department has reviewed the Safety Evaluation Program at Clinton Power Station (CPS) to

, determine if any programmatic corrective actions are required. Several ,

improvements to the program have been implemented since the time frame when CPS Procedure No. 3909.03 was revised. In October 1988, a Safety Evaluation Manual was developed to provide a consistent format and content for performing safety evaluations. The manual includes a screening form which is used to determine whether a change to the facility or a procedure described in the SAR, or a test or experiment ,

not described in the SAR requires a safety evaluation. The screening form requires two signatures, including one from the director of the i originating department to provide a second review, to ensure the required review is completed prior to implementing a change. ,

Under the present Safety Evaluation Program, screening forms are transmitted to the Licensing and Safety Department where a discretionary ,

review is performed to determine if the screening was performed properly. Licensing and Safety Department Procedure L.7, " Safety Evaluation Programmatic Review and Preparation of 10CFR50.59 Input for the Annual Report to the NRC," does not explicitly describe what this discretionary review includes. However, the Licensing and Safety l Department will revise this procedure to include criteria for performing a discretionary review, including checking that the individuals performing the screening have received the required training. This action will be completed by July 31, 1990.

The Licensing and Safety Department performed a review of the Safety Evaluation Program to determine whether a change to plant procedures is required for situations whea equipment is tagged out of service for an extended period of time. The Safety Evaluation Manual identifies a list of items which are to be considered as potential changes to the facility as described in the SAR. Included in this list are tagouts (when the intent is to enange the operational configuration of the plant indefinitely). However, there is no specific guidance provided in the out of service annunciator tracking procedure, CPS Procedure No.

1406.01, to mako a determination on the need for a safety evaluation, when disabling annuncia* ora or taking an annunciator out of service.

This procedure will be revised to incorporate the necessary guidance for making long-term changes to the operational configuration as opposed to supporting on going plant activities such as inspections, surveillances, maintenance, etc. This action will be completed by September 30, 1990, A review of annunciators which are presently disabled or removed from service will be performed to determine whether safety evaluations are required. This cetion will be completed by July 31, 1990. Even though ali non safety related procedures presently require a safety evaluation screening determination to be made, a review of past radwaste procedure changes will be performed to determine any conflicts with USAR requirementa. Any conflicts will require e safety evaluation to be performed. This action will be completed by July 31, 1990.

3

I. g

.. e .;

Due to the difficulties experienced over the past four years with the tank level indications, a design change to upgrade or replace the existing WX system ultrasonic level instrumentation is under review.

IV. Date kh.n Full Compliance Will Be Achieved!

Illinois Power Cepany will be in full compliance by September 30, 1990.

4