U-600806, Responds to NRC Re Violations Noted in Insp Rept 50-461/86-65.Corrective Actions:Individual Responsible Counseled to Carefully Review Condition Rept.Procedure 1016.01 Will Be Revised

Responds to NRC Re Violations Noted in Insp Rept 50-461/86-65.Corrective Actions:Individual Responsible Counseled to Carefully Review Condition Rept.Procedure 1016.01 Will Be Revised

ML20234B588
Person / Time
Site:	Clinton
Issue date:	01/06/1987
From:	Spangenberg F ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-600806, NUDOCS 8707060114
Download: ML20234B588 (12)

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U-600806

'L42-87(01-06)-L 1A.170 s I ILLIN0/8 POWER 00MPANY .

CUNTON POWER STATION, P.O. BOX 678, CLINTON. ILLINOIS 61727 January 6, 1987 l

Docket 50-461 l

Mr. J. G. Keppler .j '

Regional Administrator Region III U.S. Nuclear Regulatory Commission ]

799 Roosevelt Road 1

-Glen Ellyn, Illinois 60137 j Response to the Notice of Violation' dated

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Subject:

November 26, 1986 in Inspection Report 50-461/86065 1

Dear Mr. Keppler:

This letter is in response to the Notice of' Violation in Inspection Report 50-461/86065. Please see Attachments A through E to this letter.

for Illinois Power's detailed responses to each apparent violation..

I trust that these responses will ensure compliance with regulatory requirements. j Sincerely yours, i

F. A. Spa genbe Manager - Licensing and Safety JAB /bsa Attachr.ents ,

cc: B. L. Siegel, NRC Clinton Licensing Project Manager h7C Resident Inspector Illinois Department of Nuclear Safety..

8707060114 870106 PDR ADOCK 05000461 G PDR

1 Attachment A j Illinois Power Company Clinton Power Station l The Notice of Violation states in pertinent parts:

"a. None of 18 condition reports reviewed had an approved plan of corrective action dncvmented in BLOCK 9. In each case, BLOCK 9 of the condition report provided a historical summary of actions taken and results achieved rather then an approved plan of corrective action based on the results of an investigation, i

b. BLOCK 2 was not filled out for several condition reports ']

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c. Subsequent required reviews by the Compliance Department, Quality Assurance Department and the Facility Review Group did not identify and correct the above procedural violations."

f I. Corrective'ActionsTckenandResultsAchiefed

a. CPS procedure 1016.01, CPS Condition Report, has been revised l to require that in BLOCK 4'the following be documented:

1) date and time that the condition was identified;

2) the time that the appropriate level of management was j notified;

3) the name of the management person notified;

4) the immediate actions directed by management.

b. The individual responsible for the review of block two has I been counseled to carefully review the condition report.

c. Subsequent paragraphs of CPS procedure 1016.01 were written I such that all departments including Compliance, Quality Assurance, and the Facility Review Group understood that it was acceptable-to complete the required corrective actions prior to the submittal of the investigation results/ corrective I action plan. 'The rev1sion to CPS procedure 1016.01 discussed above has corrected this misunderstanding.

II. Corrective Actions Taken to Prevent Recurrence

a. CPS Procedure 1016.01 will be revised to direct that the i corrective action plans in BLOCK 9, with the exception of the BLOCK 4 requirements stated above, be written and approved by-the appropriate department head prior to implementation of corrective actions. Upon completion of this revision to CPS procedure 1016.01, all other departmental procedures which interface with 1016.01 will be revised to incorporate these  ;

requirements.  ;

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Attachment A Illinois Power Company Clinton Power Station i

b. Counseling has been performed with the individual responsible for the review of BLOCK 2. No further corrective actions are necessary because the omission cf information in BLOCK 2 will l not change the final disposition of the condition report. )l

c. Training will be conducted for members of Compliance and Quality Assurance who routinely review condition reports. '

This training will be to ensure that instances where the procedure is not followed will be correctly identified and resolved.

1 III. Date When Full Compliance Will Be Achieved 1

a. Illinois Power is in full compliance. .Further revisions discussed above will enhance the program and will be completed by March 31, 1987.

b. Illinois Power is in full compliance.

c. Illinois Power will be in compliance by January 15, 1987, 1

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1 Attachment b Illinois Power Company Clinton Power Station The Notice of Violation states in pertinent parts:

"a. On October 3, 1986, while moving fuel bundles from the Fuel Building to Containment in accordance with CPS No. 1898.00, a fuel' bundle was moved from one item control area (the Fuel Building) to another (the Containment Building) without proper.

verification of the serial number.

b. On October 4, 1986, the technical department Nuclear group and a . licensed SRO made erroneous changes to an approved fuel transfer checklist which resulted in two fuel bundles of medium enrichment being placed into reactor locations requiring high enrichment fuel bundles,

c. On October 5, 1986, while operating in-specified conditfon CORE ALTERATIONS, a suberiticality check of the just-loaded control cell (20-29) was not performed, as required, prior to loading two fuel bundles into control cell 20-14.

d. On October 7, 1986, while operating in specified condition CORE ALTERATIONS, two fuel bundles were loaded into control  ;

cell (20-41) without prior performance of a suberiticality check as required.

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e. On October 8, 1986, while loading fuel into the reactor in accordance with an approved SNM transfer checklist, two fuel bundles of medium enrichment were designated for placement i

into core locations requiring high enrichment' fuel bundles due l to an inadequately prepared SNM transfer checklist. ,

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f. On October 11, 1986, while opera *.ing in specified condition CORE ALTERATIONS, two fuel bundles were loaded into the i

reactor without prior enrichmeit verification by the Shift j i

Test Director as required by STP-03-0 (memorandum DLH-86-312).

g. On October 14, 1986, while operating in specified condition CORE ALTERATIONS, two fuel bundles were loaded into the reactor without prior enrichment verification by the Shift Test Director as required by STP-03-0 (memorandum DLH-86-312),

h. On October 16, 1986, while moving fuel bundles from the Fuel Building to Containment in accordance with CPS No. 1898.00, a fuel bundle was moved from one item control area (the Fuel Building) without proper verification of the serial number."

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. Attachment B Illinois Power Company Clinton Power Station  ;

I. Corrective Action Taken and the Results Achieved I On October 22, 1986, IP management met with NRC management'at the Region III Office in Glen Ellyn, IL to discuss the number of procedural violations that had occurred during the fuel loading process. On October 23, 1986, IP management held a meeting with-site managers, directors, and selected supervisors which stressed reduction of overtime and the slowdown of work actions to prevent errors.

On November 4, 1986, a management review was conducted of the errors which occurred during the CPS fuel loading evolution. The review concluded that the errors are attributed to six root causes which required correction. For each, Illinois Power took corrective action to correct these causes to prevent similar' ,

operational events in future complex evolutions. The six root causes, and their resultant corrective actions, are as follows.

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1. No single person was in charge of the overall fuel load I evolution. As a consequence, the control to ensure the steps- 3 in the fuel load process were properly performed was I inadequate to prevent errors from occurring, j j

Action: Training on the relationship between the Test Director and Shift Supervisor was provided by management, and their responsibilities were re-emphasized through revisions to the program (Startup Manual, Standing Orders). Further, the shift training in the simulator, scheduled prior to initial criticality, will include test directors so that their responsibilities and relationships can be exercised.

2. Measures were not in place for managers to be kept thoroughly apprised of progress during the evolution or of problems which .

arose. This was noted in the Operations, Technical Staff and Startup Departments.

1 Actions: Plant Staff departments were instructed concerning the reporting of shift events, which included the reporting mechanism, how often to report, content of reporte and the reporting of special items. Also, the Condition Report system was revised to require one hour notifications to management concerning conditions that may require the' generation of a Condition Report. Mar.agement can then assess the condition significance and take corrective measures as appropriate.

3. Face-to-face and telephone communications were informal.

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Attachment B Illinois Power Company Clinton Power Station

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Action: Formal instructions have been promulgated on the conduct of communication, and all shift personnel are being trained on them, 4 Management did not adequately assess the fatigue of the {

personnel involved with the evclution.

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i Action: Overtime limits are being strictly enforced. A-maximum of ten hours per day, and no more than six consecutive work days, is presently in effect and will be continued.

Exceptions are granted only with senior management approval.

5. Quality Assurance Department was not sophisticated enough in  ;

identifying the trend of errors for Plant Management.

Action: Training was provided to over 90 Quality Assurance personnel, including supervisors, regarding the importance and ,

responsibility of recognizing significant problems and trends )

of incidents, such as the fuel handling incidents, clearly communicating these to plant management and ensuring that corrective actions taken are adequate to correct the problems j and that the corrective actions are documented. j

6. The fuel loading procedure did not provide the detail necessary to complete the evolution.

I i Action: Formal instructions have been issued by the Manager -

l Clinton Power Station for a review of each Startup Test Procedure (STP) and any associated Operating Procedures prior to their performance. The review will be conducted jointly by a Test Director and a licensed Senior Reactor Operator. The purpose of the review is to ensure that the Startup Test i Procedures and associated Operating Procedures contain

! sufficient detail and specificity for their initial performance in the Power Ascension Test Program, l

i In addition to the above, critiques were held with site managers, directors, shif t personnel, test directors and supervisors to discuss the fuel handling evolution and results of the management i review.

II. Corrective Action to be Taken to Avoid Further Violations it is recognized that prompt investigation of problems provides an j effective manegement trail to identify and take corrective actions.

An Administrc'.ive Practice document is being generated to aid ,

personnel in the conduct of investigations and critiques. This  !

Administrative Practice is presently scheduled to be completed in  ;

January 1987. j I

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i Attachment B Illinois Power Company  :

Clinton Power Station i

III. Date When Full Compliance Will.Be Achieved Illinois Power is in full compliance. ,

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I Attachment C 1 Illinois Power Company Clinton Power Station The Notice of Violation states in pertinent parts:

"a. On October 15, 1986, at approximately 6:00 p.m., while .

investigating abnormal indications on the Intermediate Range Neutron Monitors, licensed reactor operators performed a test of the Reactor Protection System under the verbal direction of the Manager, Clinton Power Station, without approved documented instructions or procedures.

b. On October 14, 1986, at approximately 11:30 p.m. while in mode 5, licensed operators restored the Reactor Vessel Water Level (Level 1 Analogue Trip Module (ATM) B21-N961A) to service after partial performance of CPS No. 9056.01 under the verbal i I

direction of the Shift Supervisor without approved documented instructions or procedures. This resulted in an unnecessary I automatic actuation of containment and drywell isolation l valves 11A005 and IIA 008."

I. Corrective Actions Taken and the Results Achieved

a. Illinois Power does not agree that the performance of a manual reactor trip with all control rods fully inserted in order to observe Intermediate Range Monitors (IRMs) signal noise constitutes a test which must be performed with an approved written procedure or troubleshooting plan. This reactor trip was preplanned and authorized by the Manage,r - Clinton Power Station prior to its performance and is not considered an i

activity requiring documented instruction or procedures l pursuant to 10CFR50, Appendix B, Criterion V.

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This was simply one action taken by itself in order to verify that the IRM noise spike was in fact attributable to the scram signal.

b. Illinois Power does not agree that the removal of the transmitter simulator in order.to achieve compliance with the Technical Specifications constitutes an activity which should have been directed by an approved instruction or procedure.

Although a Temporary Procedure Deviation (TPD) would have documented this activity and precluded the ESF actuation, a TPD is not considered necessary because the ESF actuation was

. preplanned by the Shift Supervisor and anticipated.

II. Corrective Action to be Taken to Avoid Further Violations-Yurther corrective action is not considered necessary since no violation of 10CFR50, Appendix B, Criterion V took place in these two instances.

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Illinois Power Company Clinton Power Station i III. Date When Full Compliance W111'Be Achieved Illinois Power is in full compliance, i

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i Attachment D Illinois Power Company Clinton Power Station The Notice of Violation states in pertinent parts: l "10 CFR 50, Appendix B, Criterion V and the IP Operational Quality Assurance Manual, Chapter 5 states in part: Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings....

Contrary to the above, the following examples of inadequate i surveillance test procedures were identified:

a. On October 9, 1986, during surveillance testing per procedure CPS No. 9015.01, " Standby Liquid Control Pump Operability,"

revision 22, performance of step 8.2.6 resulted in an unexpected isolation of the reactor water cleanup pump suction due to a logic interlock function. The surveillance procedure was missing necessary steps to prevent actuation of the interlock.

b. On October 14, 1986, during surveillance testing per procedure CPS No. 9056.01, " Automatic Actuation of ADS (DIV 1),"

revision 20, performance of step 8.1.15 did not prevent actuation of valves 11A005 and IIA 008, as was intended,

c. On October 16, 1986, during surveillance testing per procedure CPS No. 9463.02, " Suppression Pool Water Level Channel Calibration," revision 21, performance of Appendix A, for instrument LT-CM013 resulted in an unexpected automatic start of the Division 1 Shutdown Service Water Pump."

I. Corrective Actions Taken and Results Achieved

a. CPS Procedure 9015.01, " Standby Liquid Control System Operability" will be revised by January 9, 1987, to ensure the ]

Reactor Water Cleanup (RWCU) suction isolation valve will not isolate during performance of this surveillance test,

b. CPS Procedure 9056.01, " Automatic Actuation of the Automatic Depressurization System (ADS) (DIV 1)" has been revised to ensure that containment isolation valves IIA 005 and IIA 008 do not isolate during performance of this surveillance test.

c. CPS Procedure 9463.02, " Suppression Pool Water Level LT-CM030 i (31), LT-CM013(06) Channel Calibration" has been revised to I ensure that the Division 1 Shutdown Service Water pump will not automatically start during performance of thin' surveillance test.  !

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Attachment D Illinois Power Company Clinton Power Station II. Corrective Actions Taken to Prevent Recurrence Plant Manager's Standing Order #PMS0-30 was amended to require an evaluation of Mode 1, 2 and 3 surveillance procedures which require leads to be lif ted- or jumpers or test equipment to be installed, prior to the initial performance of the surveillance tests. These evaluations will determine the effect of the surveillance on plant equipment utilizing the latest design. documents.

III. Date When Full Compliance Will Be Achieved Illinois Power will be in full compliance by January 9, 1987.

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Attachment E Illinois Power Company i Clinton Power Station The Notice of Violation states in pertinent parts:

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" Technical Specification 3.3.2 states in part: "The containment and l reactor vessel isolation control system (CRVICS) channels shown in Table 3.3.2-1 shall be OPERABLE."

Table 3.3.2-1, Instrument 1.j. , " Reactor Vessel Water Level - Level 1" requires a minimum of 1 operable channels per trip system while i operating in specified condition CORE ALTERATIONS. There are 2 Reactor Vessel Water Level - Level 1 (Division 1) channels, designated 1B21-691A sud 1B21-691E. Table 3.3.2-1, Note "k" requires that a channel may be placed in an inoperable status for j up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for required surveillance.

Technical Specification 3.0.4 specifies, in part, that entry into an OPERATIONAL CONDITION or other specified condition shall not be made unlese the conditions for the Limiting Condition for Operation

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are met without reliance on provisions contained in the Action requirements.

I Contrary to the above:

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a. At 1:30 a.m. on October 14, 1986, while operating in specified condition CORE ALTERATIONS, technicians performing ]

surveillance procedure CPS 9056.01, " Automatic Actuation of ADS (DIV 1)," revision 20, dated May 3, 1986, placed both channels (1B21-691A and 1B21-691E) of the division 1 Reactor Vessel Water Level Low, Low, Low - Level 1 trip function in an inoperable condition. This violated Technical Specification Table 3.3.2-1, Instrument 1.j. which required a minimum of 2 operable channels per trip system,

b. On October 14, 1986, between 1:30 a.m. and 5:15 a.m., while operating in specified condition CORE ALTERATIONS, one or more channels of Reactor Vessel Water Level Low, Low, Low - Level 1 (DIV 1) were authorized and placed in an inoperable status for i a period in excess of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> while performing surveillance l testing; the applicable action statement was not carried out.

c. On October 14, 1986 at 11:55 a.m., the licensee entered a specified condition (CORE ALTERATIONS) while not meeting the 1 requirements of Technical Specification Table 3.3.2-1 for the 1 minimum number of operable channels of Reactor Vessel Water Level Low, Low, Low - Level 1 (Division 1) in the containment and reactor vessel isolation control system.

d. On October 21, 1986, the licensee entered a specified condition (CORE ALTERATIONS) while relying on provisions -)

contained in the action requirements of TS 3.6.6.3.a.2 for the Standby Gas Treatment system."

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! l Attachment E Illinois Power Company Clinton Power Station l l

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1. Corrective Actions Taken and Results Achieved a) Compliance with this Technical Speci!.ication was achieved at 8:11 a.m. on October 14, 1986, when CORE ALTERATIONS were suspended, b) Compliance with this Technical Specification was-achieved at 8:11 a.m. on October 14, 1986, when CORE ALTERATIONS were suspended.

c) Compliance with this Technical Specification was achieved at 10:00 p.m. on October 14, 1986, when CORE ALTERATIONS were suspended, d) Compliance with this Technical Specification was achieved at I 8:00 p.m. on October 21, 1986, when the B train of the Standby Cas Treatment System was declared operable.

II. Corrective Actions Taken to Prevent Recurrence a, b, and c) A critique of these events, along with lessons learned, was held by each operating shift. The critique l

reviewed the time requirements associated with these technical specifications and the need to review and identify all applicable technical specifications when planning activities.

Requirements for removing an instrument from service were discussed. It was stressed that any inoperability, due to failure or removal from service for surveillance, will be treated as inoperable and properly logged in the Control Room Operator's Log. Additionally, Table 3.3.2-1 of the Technical Specifications will be revised with issuance of the Full Power Operating License to improve formatting of the information contained in this table. This will significantly improve readability and minimize misinterpretation of the information provided in this table.

d) The Shift Supervisor on duty at the time was counseled on the need to review the LCOs and the technical specifications prior to making a mode change or change in a "specified condition" as described in the applicability section of the limiting condition for operation. Each operating shift was also briefed on this incident and lessons learned.

III. Date When Full Compliance Will Be Achieved Full compliance will be achieved upcn issuance of the full power license.