ML20210B047

Provides Info Re Preparedness of Facility to Exceed 5% Power.Progress Toward Initial Criticality Proceeding Slower than Expected.Activities Required to Be Completed Prior to Exceeding 5% Power Will Be Completed During Mar 1987

ML20210B047
Person / Time
Site:	Clinton
Issue date:	02/02/1987
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Bernero R Office of Nuclear Reactor Regulation
References
NUDOCS 8702090063
Download: ML20210B047 (12)

Text

4 d

$we n

4 FEB 2 1987

'M'EMORANDUM FOR: ,R.-Bernero, Director, Division of Boiling Water Reactor

. Licensing, NRR FROM: Charles E. Norelius, Director, Division of Reactor Projects Region III

SUBJECT:

ILLIN0IS POWER COMPANY (IP), CLINTON POWER STATION

. STATUS OF PREPAREDNESS TO EXCEED 5% POWER

.This memorandum is forwarded to provide you information on the preparedness of the-Clinton facility ~to exceed 5% power. This includes a summary of all pertinent activities .since issuance of the low power license dated September 29, 1986.-

Enclosures 1 and 2 include a description of the current plant status, operational summary, and a summary of significant inspection activities since license issuance.- Enclosure 3 provides a status of IP's progress in completing license conditions. Enclosure 4 is a-brief summary of significant

event reports that resulted in issuance of LERs by the licensee. Enclosure 5

. .is'a status of-Clinton allegations being tracked as open by Region III.

Licensee. progress towards initial criticality has proceeded at a slower pace than expected. Delays can be attributed to several factors including problems F . encountered durin'g surveillance testing, maintenance work request (MWR)

activities, and design change activities. At present, initial criticality j'

is expected to be achieved in February 1987. IP currently estimates that they will have completed all activities req'uired by the NRC to exceed 5% power

~during March 1987.

( . Region III has been closely monitoring licensee activities. After IP received its low' power license, the plant staff committed several fuel loading errors and-had a significant number of personnel errors, procedural deficiencies, and reportable events during the first month of the license. These problems were discussed with licensee management on'0ctober 22 and December 1, 1986. During L November IP reduced the level of plant activities and the amount of overtime L' being worked.by the plant staff. Since then, the number and significer.ce of

! reportable events has decreased noticeably. However, a recent team inspection

.to assess operational readiness identified procedural and administrative problems'similar to those identified earlier and highlighted in our recent L .SALP report. 'These will have to be resolved before the Region is ready to l recommend a license for full power operation.

$ 2 0 g j f5 1 A- @g ulI l

L.

R. Bernero 2 ((g g jgg7 A followup inspection in the area of maintenance and modifications was conducted to assess whether or not previously identified problems had been corrected. No additional problems were identified in the area of maintenance and modifications. Corrective Action is being further reviewed this month.

A meeting to discuss the elimination of the Project Control Center and concerns arising from the events surrounding the January 21, 1987 recirculation pump start is scheduled in the Region III office on January 30, 1987. These concerns are discussed in Enclosure 2.

If you have any questions concerning this matter, please contact me or Mr. R. C. Knop of my staff.

CRIGINAL 5 GNED BY E. G. CREENMAN Charles E. Norelius, Director Division of Reactor Projects

Enclosures:

1. Plant Status & Operational Summary

2. Significant Inspection Activities

3. Status of License Conditions

4. Significant Event Reports

5. Allegation Status cc w/ enclosures:

J. Taylor, IE J. Partlow, IE W. Butler, NRR B. Siegel, NRR A. B. Davis, RIII SRI, Clinton J. Hind, RIII C. Paperiello, RIII E. Greenman, RIII F. Jablonski, RIII J. Harrison, RIII C. Hehl, RIII R. Warnick, RIII M. Phillips, RIII R. Knop, RIII D. Danielson, RIII J. Creed, RIli R. Greger, RIII M. Schumacher, RIII M. Ring, RIII W. Snell, RIII R. Gardner, RIII RIII RIII RI~II RIIIh

$W Gardner/j p Knop Y R'FID Warnick No N" $ ,g @

ENCLOSURE 1 Plant Status and Operational Summary The licensee received its license (restricted to 5% power) on September 29, 1986, and began loading fuel on that day. Fuel loading was completed on October 21, 1986. Initial criticality is expected to occur in February 1987.

The licensee is currently seeking to complete surveillance testing and maintenance work activities required for initial criticality. The licensee currently expects to be in a position to exceed 5% power sometime in March 1987.

Prior to exceeding 5% power, the licensee must complete or resolve license conditions described in Enclosure 3 of this report. In addition, the following activities must be completed:*

1. 146 Maintenance Work Requests must be completed.

2. 353 Master Deficiency items must be resolved.

3. 18 Surveillance Instructions must be completed.

4. 8 Systems must be made operable (Technical Specification Systems).

• Status from licensee as of January 23, 1987.

Licensee operating performance during fuel load activities revealed weaknesses in management controls resulting in a high number of fuel handling errors and a high number of personnel errors and reportable events. These weaknesses were subsequently discussed during management meetings with IP on October 22, and December 1, 1986.

Approximately 50 NRC notifications per 10 CFR 50.72 have been initiated by the licensee due to events at the plant since license issuance. A large number of these events were due to personnel error which has caused some concern but which in itself is not considered abnormal for a plant at this stage in operation. Concerns arising from these events were discussed in the management meetings on October 22 and December 1, 1986.

~ ,

M ENCLOSURE 2 Significant I'nspection Activities

' Initially, 24-hour coverage of fuel' load activities _was provided by Region III to meet.IE: Inspection Modules 72302 and 72524 requirements and verify that plant operations followed their approved program. During the conduct of'

initial fuel load, the licensee violated the plant Technical Specifications.

.for conducting core alterations.(fuel loading).on two occasions and made-

.several procedural errors. This poor initial performance was attributed to the licensee's inexperience in working with plant systems and the technical specifications coupled with a lack of strong-supervision and excessive use of overtime. :The licensee has demonstrated improvements in performance particularly in the areas of shift briefings and shift' supervisor control of plant operations. In addition, the licensee has prepared a corrective action plan to provide organizational improvements and improved communications.

Recent' inspections by the NRC have identified improper post maintenance and post modification testing of systems following Pre-Operational testing.

The licensee has reviewed all modification packages and has retested as appropriate. Region III has reviewed a sample of the maintenance and modification testing packages and found them to be acceptabl_e. Enforcement actions are still under review.

The Clinton SALP 6 Board was held on November 10, 1986, and the SALP licensee meeting was held on December 17, 1986 at Region III. Clinton received one Category 'l rating in the Pre-Operational Testing functional area. All other functional areas were rated Category 2 except for the Quality Assurance and Administrative Controls functional area and the Maintenance functional area which were rated Category 3.

Phase 1 of the Region III Operational. Readiness Inspection was performed at

, Clinton during the period of December 1-5, 1986. Five Region III inspectors participated in the inspection. Areas reviewed included: surveillance i . testing as required by Technical Specifications; operations and maintenance training; control'of out of service equipment and equipment tagging; control

! of lifted leads, jumpers, and temporary mechanical alterations; annunciator status and control; and control room observations. One violation was identified in the area of lifted leads and jumpers. Phase 2 involved followup on previous inspection findings concerning implementation of the licensee's maintenance, design change, and modification program. Phase 1 of~the Operational Readiness Inspection identified no significant safety concerns; however, several examples were identified in which licensee

. personnel were not following administrative procedures or procedures did not exist to control activities that may impact plant operations. Plase 2 identified no new safety concerns.

l l

On January 23, 1987, Illinois Power Company informed RIII that they were no longer using the Project Control Center (PCC) in controlling activities deferred past fuel load as described in a letter from IP to the NRC dated June 3, 1986.

On January 21, 1987, there were a number of inappropriate actions taken during attempts to start a recirculation pump during a primary loop hydro. These actions eventually led to a spurious signal causing group isolations of a number'of systems. The inappropriate actions include failure to properly unitize procedures, inadequate attention to detail, inadequate training, failure to do adequate reviews, and failure to keep upper management informed.

The deactivation of the PCC and the January 21, 1987, event will be discussed with the licensee in a management meeting in RIII on January 30, 1987.

2

ENCLOSURE 3 Status of Licensee Conditions The following is a brief description and status of license conditions that must be completed by the licensee prior to the staff concluding that the Clinton facility is ready to exceed 5% power.

Initial Criticality A. Licensee to provide administrative throttling controls to preclude further degradation of the anchor darling globe valve stem to disc tack welds until resolution of 10 CFR 50.55(e) item.

License Condition Attachment 1, Item 2.d.

Status The licensee's resolution of this construction deficiency report was reviewed by the resident inspector (see Inspection Report 50-461/86072).

That review found that the licensee had not provided sufficient basis to justify plant operation during the first fuel cycle. Additional evaluation is required by the licensee prior to initial reactor criticality.

B. Initial criticality preoperational test and testing exceptions identified by the licensee in a March 12, 1986, letter to Region III must be completed.

License Condition Attachment 1 Item 1.

Status On January 23, 1987, there were two deferred preoperational tests.

remaining to be completed by the licensee to meet this license condition.

The licensee estimates completion of these tests by January 26, 1987.

Nuclear Heatup A. Licensee to provide a program for resolving the adequacy of Ray Chem splices.

License Condition Attachment 1, Item 2.c.

States This matter is under review by a Region III Specialist. Licensee corrective actions are complete.

Prior to nuclear heatup, preoperational test and testing exceptions B.

identified by the licensee in a March 12, 1986, letter to Region III must be completed.

License Condition Attachment 1, Item 1.

Status On January 23, 1987, there were portions of five precperational tests remaining to be completed by the licensee to meet this license condition. The licensee estimates completion of these tests by January 30, 1987.

Prior to Exceeding 5% Power A. Licensee to resolve audibility problems encountered on evacuation of personnel in high noise areas in accordance with IP letter dated July 8, 1986.

License Condition Attachment 1, Item 2.a.

Status This license condition is pending initial plant operation for action.

Noise levels must be present in the plant prior to action being taken on this item.

B. Licensee to complete installation and testing of the high range radiation monitors per NUREG-0737, Item 2.F.1, Attachment 3.

License Condition Attachment 1, Item 2.b.

Status The licensee completed action on this item and provided information to Region III for review on December 18, 1986. Region III review will be completed to support this milestone.

C. Prior to exceeding 5% power, preoperational test and testing exceptions

identified by the licensee in a March 12, 1986, letter to Region III must l

1 be completed.

License Condition Attachment 1, Item 1.

Status l The licensee deferred portions of this testing to beyond 5% power and l portions of this deferred testing have already been completed. Region

! III is monitoring the status of this testing through the resident j' inspector.

f l

L

~* -

' ENCLOSURE 4 Significant Event Reports

Since the license. issuance .there have been 24 LER's submitted. The LER descriptions provided below were taken from the LER abstracts provided by the licensee.

LER 86-001-00 On September 30, 1986, a Reactor. Water Cleanup (RWCU) outboard containment isolation occurred due to a tripped RWCU pump room temperature module. This trip was attributed to the presence of grounds in the temperature module coincident with thermocouple grounds.

LER 86-002-00 On September 30, 1986, negative pressure was lost in Secondary Containment during initial fuel loading. During removal of scaffolding by contractor craft personnel from the Residual Heat Removal (RHR) "B" pump room, the interlock-switches for the room doors were defeated by craft personnel and the room doors were propped open. This violated the airlock system and' caused the loss of vacuum.

LER 86-003-00 On September 30 and October 2, 1986, the Control Room Ventilation System (VS) shifted to the high chlorine mode of operation. The cause of both events was the breakage of the CHEMCASETTE tapes in two of the four chlorine detectors. Investigation revealed that there were excessive factory set tensions on the chlorine detector heads which precipitated the tape breakages.

LER 86-004-00 On October 1, 1986, an automatic initiation of the Standby Gas Treatment System (SGTS) occurred as a result of a Containment Fuel Transfer Vent Plenum

! High Radiation signal. This signal was the result of the wrong leads being lifted and not being insulated while channel functional testing was being performed.

LER 86-005-00 On two occasions, on October 8,1986, it was discovered that the Firewatch Rounds for impaired barriers were not completed in the required time frame.

i These occurrences were the result of personnel negligence.

i LER 86-006-01 On October 8 and October 15, 1986, automatic initiations of the Division I Essential Service Water System (SX) occurred. The suspected root cause of these events was that the Nonessential Service Water System (WS) received l

F v

~

a-low pressure transient (due to increased flows) for each occurrence, which resulted in a low pressure switch actuating the SX system and starting each respective pump.

LER 86-007-00 On October 9, 1986, two RWCU outboard containment isolations occurred. The first occurrence was attributed to a deficient Standby Liquid Control (SLC) surveillance procedure which did not prevent the RWCU from isolating during the test. The second occurrence was attributed to the lack of venting'and filling of the RWCU system prior to system restoration.

LER 86-008-00 Superseded by LER 86-009-01.

LER 86-009-01 On October 14, 1986, the secondary containment was degraded by rendering the isolation instrumentation for instrument air and component cooling water containment isolation valves inoperable.for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 28 minutes. The cause of this event was attributed to surveillance procedure deficiencies. Subsequently, the licensee also determined that Technical Specification requirements for fuel loading were not met during two intervals of core alterations. The cause of these events was attributed to personnel error.

LER 86-010-00 On October 15, 1986, with initial fuel loading in progress and all rods fully .

inserted, two auto actuations of the Reactor Protection System (RPS) trip I function occurred. Both occurrences were due to a previously failed Main Steam Line (MSL) Radiation detector channel accompanied by a second divisional spurious (electrical circuit noise) MSL High-High Radiation or Inop trip.

LER 86-011-00 On October 16, 1986, an automatic initiation of the Division I Shutdown Service Water System (SX) pump occurred due to a deficient surveillance procedure.

LER 86-012-00 On October 17, 1986, a RWCU inboard containment isolation occurred when RWCU differential flow transmitters were returned to service after a calibration surveillance. The cause of the occurrence was attributed to personnel error in that the transmitters were not vented sufficiently prior to their return to service.

l 2

LER 86-013-00 On October'19, 1986, a Control Room Operator inadvertently placed a Source Range Monitoring (SRM) channel out of OPERATE causing a Reactor Protection System (RPS) trip.

LER 86-014-00 On October 21, 1986, a Standby Gas Treatment System Initiation occurred due to-the incorrect installation of a jumper required for Division II testing.

LER 86-015-00 On October 21, 1986, electrical circuit breakers for the Containment Equipment Drain Valve, Containment Floor Drain Valve, and the Emergency Notification System were tripped when a maintenance electrician dropped the cover panel to an Auxiliary Building MCC.

LER 86-016-00 On October 20, 1986, a violation of when core alterations (fuel loading) were plantauthorized Technical to Specifications occurred begin while the Standby Gas Treatment System was inoperable.

LER 86-017-02 On October 24, 1987, an automatic initiation of the Reactor Protection System (RPS) trip function occurred due to an upscale reading on Intermediate Range Monitor Channel A (IRM-A). The cause of this event is being investigated by the licensee.

LER 86-018-00 On October 26, 1986, a Reactor Water Cleanup (RWCU) outboard isolation valve isolation occurred when a Control and Instrumentation (C&I) technician loosened two terminal screws, without proper authorization.

LER 86-019-00 On November 10 and November 24, 1986, spurious High Radiation signals from the Main Control Room Air Intake Process Radiation Monitor shifted the B Control Room Ventilation System train into the High Radiation mode of operation. The cause of these events was attributed to dust and moisture in an electrical connector.

LER 86-020-00 On November 10, 1986, an automatic switching of the High Pressure Core Spray Pump Suction Valve Alignment occurred due to a tripped level transmitter.

The cause of the event was attributed to rust particulate found within the level transmitter.

3

4 LER 86-021-00 On November 14, 1986, an automatic isolation of the Reactor Water Cleanup System (RWCU) occurred due to a RWCU Pump Room A High Temperature trip signal. The- cause of this event was attributed to personnel error.

LER 86-022-00 Not yet available.

LER 86-023 On December 7, 1986, an automatic actuation of the Reactor Protection System scram trip function occurred due to the receipt of a Shutdown Discharge Volume (SDV) high level alarm signal. The cause of this event was attributed to personnel _ error.

LER 86-024-00 On December 10, 1986, a Group I containment isolation signal was generated from the Condenser Low Vacuum Bypass Logic. The cause of this event was attributed to personnel error.

4

ENCLOSURE 5 Allegation Status There are 10 allegation files that remain open and assigned to the staff.

Most of the allegations have been reviewed in some detail, but additional inspections are required. These are expected to be' resolved to the point of determination of safety significance prior to exceeding 5% power.

h 5

9 i