ML20134B932
| ML20134B932 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 01/24/1997 |
| From: | Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jackie Cook ILLINOIS POWER CO. |
| References | |
| NUDOCS 9701310160 | |
| Download: ML20134B932 (9) | |
See also: IR 05000461/1996010
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January 24, 1997
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EA 96-412
Mr. John G. Cook
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Senior Vice President
Illinois Power Company
500 South 27th Street
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Decatur, IL 62525
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SUBJECT: NRC INSPECTION REPORT NO. 50-461/96010
Dear Mr. Cook:
On November 19, 1996, NRC completed i'.s review of activities associated with
the September 6, 1996, shutdown of Clinton Power Station. Specifically,
during the evening of September 5,-operators were attempting to place the unit
in single loop operation to allow continued unit operation by isolating a
reactor coolant leak in the "B" reactor recirculation pump shaft seal package.
The details of our review of activities associated with this event and
additional findings from the independently chartered Operational Safety Team
Inspection (OSTI) were provided.in Inspection Report No. 50-461/96010 and
50-461/96011.
Based on the results of this review, fifteen apparent violations, some with
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multiple examples, were identified and are being considered for escalated
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enforcement action in accordance with the " General Statement of Policy and
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Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.
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Accordingly, no Notice of Violation is presently being issue.d for these
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inspection findings. The number and characterization of the apparent
violations being considered for escalated enforcement are enclosed with this
letter.
In addition, please be advised that the number and characterization
of the apparent violations may change as a result of further NRC review.
A predecisional enforcement conference to discuss these apparent violations
has been scheduled for February 4,1997, at 10:00 a.m. in the NRC Region III
Office in Lisle, Illinois. The conference will be transcribed. The decision
to hold a predecisional enforcement conference does not mean that the NRC has
determined that a violation has occurred or that enforcement action will be
taken. This conference is being held to obtain information to enable the NRC
to make an enforcement decision, such as a common understanding of the facts,
root causes, missed opportunities to identify the apparent violations sooner,
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corrective actions, significance of the issues and the need for lasting and
effective corrective action. Along with discussions addressing the enclosed
violations, be prepared to discuss management actions and expectations
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regarding safety focus versus production and performance while in emergency
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operating procedures as it relates to the emergency actien levels. This
discussion should focus on actions and expectations before and after the
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September 5 event.
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9701310160 970124
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ADOCK 05000461
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J. G. Cook
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In addition, this is an opportunity for you to point out any errors in our
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inspection report and for you to provide any information concerning your
perspective on (1) the severity of the violations, (2) the application of the
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factors that the NRC considers when it determines the amount of a civil
penalty that may be assessed in accordance with Section VI.B.2 of the
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Enforcement Policy, and (3) any other application of the Enforcement Policy to
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this case, including the exercise of discretion in accordance with Section
VII.
You will be advised by separate correspondence of the results of our
deliberations on this matter. No response regarding these apparent violations
is required at this time.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter and its enclosure will be placed in the NRC Public Document Room.
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Sincerely,
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James L. Caldwell, Director
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Division of Reactor Projects
Enclosure: As Stated
Docket No.
50-461
cc:
Mr. Wilfred Connell, Vice President
P. Yocum, Plant Manager
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Clinton Power Station
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R. Phares, Manager-Nuclear Assessment
P. J. Telthorst, Director - Licensing
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Nathan Schloss, Economist
Office of the Attorney General
K. K. Berry, Licensing Services Manager
General Electric Company
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Chairman, DeWitt County Board
State Liaison Officer
Chairman, Illinois Commerce Commission
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(see continued attached distribution)
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J. G. Cook
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the amount of a civil penalty that may be assessed in accordance with
Section VI.B.2 of the Enforcement Policy, and (3) any other application of the
Enforcement Policy to this case, including the exercise of discretion in
accordance with Section VII.
You will be advised by separate correspondence of the results of our
deliberations on this matter. No response regarding these apparent violations
is required at this time.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter and its enclosure will be placed in the NRC Public Document Room.
Sincerely,
James L. Caldwell, Director
Division of Reactor Projects
Enclosure: As Stated
Docket No.
50-461
cc:
Mr. Wilfred Connell, Vice President
P. Yocum, Plant Manager
Clinton Power Station
R. Phares, Manager-Nuclear Assessment
P. J. Telthorst, Director - Licensing
Nathan Schloss, Economist
Office of the Attorney General
K. K. Berry, Licensing Services Manager
General Electric Company
Chairman, DeWitt County Board
State Liaison Officer
Chairman, Illinois Commerce Commission
J. Lieberman, OE
A. B. Beach
J. Goldberg, OGC
W. L. Axelson
R. Zimmerman, NRR
H. B. Clayton
Docket File
OC/LFDCB
PUBLIC IE-01
SRI Clinton, Dresden,
RIII PRR
LaSalle, Quad Cities
Project Manager, NRR
Document:
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Attachment 1: Annarent Viohtians
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1.
C?inton Power Station Technical Specification Section 5.4.1 requires that written
procedures shall be implemented covering the following activities: the applicable
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procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A,
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February 1978.
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Regulatory Guide 1.33, Revision 2, Appendix A, " Typical Procedures for Pressurized
Water Reactors and Boiling Water Reactors," (RG 1.33) states, in part, that the
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following are typical safety-related activities which should be covered by written
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procedures: procedure adherence; shift and relief turnover; log entries; authorities and
responsibilities for safe operation and shutdown; procedures for control of
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surveillance tests; and, emergency core cooling system tests.
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CPS 1005.14, Rev. 4, " Formatting of Procedures and Documents," states that a
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procedural step or section marked with an * are to be performed in sequence.
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CPS 3302.01, Rev.18, " Reactor Recirculation," a procedure required by RG 1.33,
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section 8.2.4 was required to be performed in sequence as indicated by the * next to
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the steps.
Contrary to the above, on September 5,1996, the licensee failed to perform all the
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steps in Procedure CPS 3302.01, " Reactor Recirculation," Section 8.2.4, in sequence.
Specifically steps 8.2.4.5 and 8.2.4.6 were performed prior to the requirements of
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step 8.2.4.3 being met.
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2.
Clinton Power Station Technical Specification section 5.4.1 requires that written
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procedures shall be implemented covering the following activities: the applicable
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procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A,
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February 1978.
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Regulatory Guide 1.33, Revision 2, Appendix A, " Typical Procedures for Pressurized
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Water Reactors and Boiling Water Reactors," (RG 1.33) states, in part, that the
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following are typical safety-related activities which should be covered by written
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procedures: procedure adherence; shift and relief turnover; log entries; authorities and
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responsibilities for safe operation and shutdown; procedures for control of
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surveillance tests; and, emergency core cooling system tests.
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Technical Specification 5.2.2e, " Unit Staff," requires that administrative procedures
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shall be developed and implemented to limit the working hours of unit staff who
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perform safety related functions. Controls shall be included in the procedures such
that individuals shall be reviewed monthly by the plant manager, or his designee, to
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ensure that excessive hours have not been assigned.
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10 CFR 50.54(m)(2)(iii), states, when a nuclear power unit is in an operational mode
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other than cold shutdown or refueling, as defined by the unit's technical
specifications, such licensee shall have a person holding a senior operator license of
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the nuclear power unit in the control room at all times. In addition to this senior
operator, for each fueled nuclear power unit, a licensed operator or senior operator
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shall be present at the controls at all times.
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s.
Procedure CPS 3317.01, Rev.16, " Fuel Pool Cooling Cleanup,", a procedure
required by RG 1.33, step 8.1.2.16 required that the inlet and outlet valves on
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the idle spent fuel pool cooling heat exchanger be closed .
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Contrary to the above, between September 18 and 25,1996, operators failed
to close the inlet and outlet valves of the idle 'A' train FC heat exchanger.
b.
Procedure CPS 3402.01, Rev.14, " Control Room HVAC," a procedure
required by RG 1.33, Step 8.1.1.1.1, requimd the final position of the
moisture separator drain valve OVC043B to be open and the loop seal fill
valve OVCOMB to be closed upon completion of filling the make-up (M/U)
air filter moisture separator loop seal.
Contrary to the above, on September 18,1996, the licensee failed to open the
moisture separator drain valve and close loop seal fill valve resulting in
draining of the control room ventilation loop seal.
c.
Procedure CPS 4001.01, Rev. 7, " Reactor Coolant System Leakage," a
procedure required by RG 1.33, Step 4.4 required radiation protection to be
notified, by the control rcom, if unidentified leakage exceeded 5 gpm such
that area samples and/or AR/PR trending information could be p' avided to
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assist in detecting the location / source of the leak.
Contrary to the above, on September 5,1996, the control room failed to notify
radiation protxtion of the need to assist in the identification of unidentified
leakage in excess of 5 gpm.
d.
Procedure CPS 3005.01, " Unit Power Changes," a procedure required by RG 1.33, Step 6.1.b required the control room notify the chemistry department
after a thermal power change of greater the 15% so they could take a gas
sample.
Contrary to the, on September 6,1996, the control room failed to notify the
chemistry department after a thermal power change of greater than 15%.
e.
Procedure CPS 1401.01. Rev. 24, " Conduct of Operations," is a procedure
required by RG 1.33.
1)
Section 8.4.3.13 required the Line Assistant Shift Supervisor (LASS) to
inform the relief operator of, as a minimum, current plant status,
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operations in progress and work to be performed in the immediate
future.
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Contrary to the above, on September 17,1996, the LASS failed to
inform the relief operator of activities in the plant which were going to
affect fuel building differential pressure.
2)
Section 8.3.3.1 requires the shift supervisor remain in a monitoring
role during off normal operation unless he determines that the LASS is
not able to deal with the situation.
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Contrary to the above, on September 6,1996, the shift supervisor
failed to remain in a monitoring role and directed activities to place the
unit in single loop operation.
3)
Section 8.4.4.10 required that significant plant operating data, such as
abnormal plant conditions and plant transients, be entered in the shift
supervisor and main control room journals.
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Contrary to the above, on September 6,1996, no entry was made in
the shift supervisor's journal when suppression pool level exceeded the
technical specification limit requiring entry into a limiting condition for
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operation action statement.
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4)
Section 8.1.6.2.1 requires the Shift Technical Assistant (STA) to assist
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the shift supervisor in evaluating conditions for possible entry into an
emergency classification condition; notifications to outside agencies are
not to interfere with his/her primary duties.
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Contrary to the above, on September 5,1996, the STA failed to assist
the shift supervisor in evaluating conditions, i.e., containment
unidentified leakage, for possible entry into an emergency
classification condition.
f.
Procedure CPS 1001.01, Rev. 6, " Control of Working Hours," Step 8.7,
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which implements the overtime control and review requirements of Technical Specification Section 5.2.2e, requires a group supervisor's review / approval of
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bi-monthly Time Control Reports as a means of satisfying this control and
review requirements.
Contrary to the above, during the period between April 1006 through August
1996, monthly reviews of overtime usage by the Operations Department
personnel have not been performed.
g.
Procedure CPS 1001.05, Rev. 8, " Authorities and Responsibilities of Reactor
Operators for Safe Operation and Shutdown," which implements the
requirements of 10 CFR 50.54(m)(2)(iii), defines the "A" reactor operator
(RO) as the individual designated to fulfill the requirements to have a licensed
RO or senior reactor operator (SRO) present at the controls of a fueled nuclear
power unit at all times.
Contrary to the above, on September 18,1996, with the reactor fueled, the
"A" RO left the at the controls area for approximately 3 minutes without
obtaining an appropriate relief.
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3.
10 CFR 50 Appendix B, Criterion V requires activitiss affecting quality shall be
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prescribed by documented instructions or procedures of a type appropriate to the
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circumstances.
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Contrary to the above:
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a.
As of September 1996 procedures CPS 9080.01, Rev. 40, " Diesel Generator
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1A (IB) Operability - Manual and Quick Start Operability" and CPS 9080.02,
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Rev 37, " Diesel Generator IC Operability - Manual and Quick Start
Operability," activities affecting quality, were not appropriate to the
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circumstances. Specifically, Step 5.11 in both procedures prescribed
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preconditioning of the emergency diesel generators, by priming the fuel oil
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system prior to diesel generator starting, thereby negating the test's validity in
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demonstrating the emergency diesel generators' ability to perform satisfactorily
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inservice.
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b.
As of September 1996 procedures CPS 9080.01, Rev. 40, " Diesel generator
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1A (IB) Operability - Manual and Quick Start Operability" and CPS 9080.02,
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Rev. 37, " Diesel Generator IC Operability - Manual and Quick Start
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Operability," activities affecting quality, were not appropriate to the
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circumstances. Specifically, Step 5.5.4 in both procedures prescribed
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preconditioning of the emergency diesel generators, by "barring over" the
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diesel prior to starting, thereby negating the test's validity in demonstrating the
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emergency diesel generators' ability to perform satisfactorily in service.
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c.
As of October 1996, procedure CPS 9080.02, Rev. 37, " Diesel Generator 1C
Operability - Manual and Quick Start Operability," an activity affecting quality
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was inappropriate to the circumstances in that it failed to require the high
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pressure core spray (HPCS) emergency diesel generator to be declared
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inoperable during testing.
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d.
On September 18,1996, procedare CPS 9861.02D019, Rev. 26, "LLRT for
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1M045" (LLRT for portions of the main steam system), an activity affecting
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quality, was not appropriate to the circumstances in that it failed to provide
necessary steps to bypass and restore a group I containment isolation signal.
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4.
10 CFR 50.59(a)(1)(iii), " Changes, Tests and Experiments," states, in part, the
holder of a license authorizing operation of a utilization facility may conduct tests or
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experiments not described in the safety analysis report, without prior Commission
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approval, unless the proposed change, test or experiment involves a change in the
technical specifications incorporated in the license or an unreviewed safety question.
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10 CFR 50.59(b)(1) requires, in part, that the licensee maintain records of tests
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carried out pursuant to paragraph (a) of this section. These records must include a
written safety evaluation which provides the bases for the determination that the test
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does not involve an unreviewed safety question.
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Contrary to the above:
On August 1,1996, the licensee performed a test, not described in the safety
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analysis report, to verify that there was no negative impact on emergency core
cooling systems (ECCS) when cycling condensate (CY) to the containment was
isolated. 'Ihe test was performed without performing a written safety
evaluation to determine that the test did not involve an unreviewed safety
question.
b.
On August 1,1996, the licensee performed a test on the water leg pump (
WLP) check valve, IE12F085A, not described in the safety analysis report, to
verify its functionality. The test was performed without performing a written
safety evaluation to determine that the test did not involve an unreviewed
safety question.
c.
Between August 2 and September 18,1996, the licensee performed a weekly
test, not described in the safety analysis report, to verify the operability of
check valve IE12F085A. The test was performed without performing a
written safety evaluation to determine that the test did not involve an
unreviewed safety question.
d.
On May 3,1995, with the reactor at power, the licensee performed a test, not
described in the safety analysis report, of the control rod drive (CRD) pumps
to determine whether a drop in CRD pressure was due to leaking valves or
CRD pump degradation. The test was performed without performing a written
safety evaluation to determine that the test did not involve an unreviewed
safety question.
5.
10 CFR 50.59(a)(1)(I), " Changes, Tests and Experiments," states, in part, the holder
of a license authorizing operation of a utilization facility may make changes in the
facility as described in the safety analysis report without prior Commission approval,
unless the proposed change involves a change in the technical specifications
incorporated in the license or an unreviewed safety question.
10 CFR 50.59(b)(1) requires, in part, that the licensee maintain records of changes in
the facility made pursuant to this section to the extent that these changes constitute
changes in the facility as described in the safety analysis report. These records must
include a written safety evaluation which provides the bases for the determination that
the change does not involve an unreviewed safety question.
Contrary to the above:
a.
Since 1989, the licensee has operated the fuel pool cooling and cleanup (FC)
system, as prescribed in CPS 3317.01, with a valve line up different from that
shown on USAR Figure 9.1-4. For example, the inlet and outlet valves on the
idle FC heat exchanger were left in the open position vice the closed position
as prescribed in CPS 3317.01. The change was made without performing a
written safety evaluation to determine that the change did not involve an
unreviewed safety question.
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b.
On September 17,1996, annunciator response books were observed on top of
the P-680 main control room panel. USAR section 3.1.2.2.1.0.1 states that
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the control room had been designed to meet seismic Category I requirements.
The change was made without performing a written safety evaluation to
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determine that the change did not involve an unreviewed safety question.
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6.
10 CFR 50.59 (a)(1)(I), " Changes, Tests and Experiments," states, in part, the holder
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of a license authorizing operations of a utilization facility may make changes in the
facility as described in the safety analysis report without prior Commission approval,
unless the proposed change involves a change in the technical specifications
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incorporated in the license or an unreviewed safety question.
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10 CFR 50.59(b)(1) requires, in part, that the licensee maintain records of changes in
the facility made pursuant to this section to the extent that these constitute changes in
the facility as described in the safety analysis report. These records must include a
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written safety evaluation which provides the bases for the determination that the
change does not involve an unreviewed safety question.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Actions," states, in part,
measures shall be established to assure conditions adverse to quality, such as failures,
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malfunctions, deficiencies, deviations, defective materials and equipment, and
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nonconformances are promptly identified and corrected.
Contrary to the above:
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a.
As of October 1996, the licensee had neither taken prompt corrective action
nor performed a written safety evaluation to determine if an unreviewed safety
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question existed for the degraded cathodic protection system. Specifically, in
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August 1995 the licensee had previously identified that the, cathodic protection
system was not adequate to protect buried piping as stated in the USAR section
9.4.5.2.
b.
As of October 1996, the licensee had neither taken prompt corrective action
nor performed a written safety evaluation to determine if an unreviewed safety
question exists for the auto-restart of the control room chillers after loss of
power. Specifically, in 1993 the licensee had previously identified that a
discrepancy existed between the as-built condition of the control room chillers
and the system as described in the USAR. The licensee had identified that the
, chillers may auto-start in 2 minutes after an event while the USAR
documented that they would start 20 minutes after an event.
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