U-601087, Responds to NRC Re Violations Noted in Insp Rept 50-461/87-32.Corrective Actions:Util Procedure 3002.01, Heatup & Pressurization, Revised to Include Channel Functional Test Requirements
| ML20236T041 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/19/1987 |
| From: | Spangenberg F ILLINOIS POWER CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| U-601087, NUDOCS 8711300251 | |
| Download: ML20236T041 (5) | |
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~ ILLINDIS POWER 00MPANY IP CLINTON POWER STATION, P.O. BOX 678 CLINTON, ILLINolS 61727
' November' 19, 1987 y
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Docket No. 50-461 Mr.
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B. Davis Regional Administrator Region III-U.S. Nuclear Regulatory Commission
-799 Roosevelt Road Glen Ellyn, Illinois 60137 Subj ect: Response to the Notice of Violation in
. Inspection Report'50-461/87032, dated October 21, 1987
Dear.Mr. Davis:
This is in response to the NRC letter dated October' 21, 1987, which contained Inspection Report 50-461/87032. The cover letter requested'a written response regarding the actions implemented to correct the violation of Clinton Power Station's-Technical Specifications.
Attachment A to this letter provides Illinois Power Company's response to this request.
l I trust that this response is adequate to demonstrate compliance with NRC requirements. Should you have any questions, please contact j
me.
I Sincerely yours, j
F. A. Spangenberg, III Manager - Licensing and Safety CAC/cke i
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.4 Attachment cc:
B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Inspector j
Illinois Department of Nuclear Safety
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8711300251 871119 PDR ADOCK 05000461 i[
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IIOV 2 01987 ii
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Attachment A
- j Illinois Power Company Clinton Power Station ja
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s The NRC letter dated October 21, 1987, states in parte
" Technical Specification 3.0.1 requires compliance witij the Limiting Conditions for Operation - except that upon failure to meet the Limiting. Conditions for Operation, in uasoci/ edd ACTION requirements shall be met.
Technical Specification. 4.Q.3 states, in part, that failure to perform a surveillance requirement,within the specified time interval shall constitute c failure to meet the OPERABILITY requirements for a Limiting Condition for Opcution.
Contrary to the above:
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[1.] On August'17, August 28 and possibly July 18, 1987, control rods were withdrawn in OPERATING CONDITION 1 without a channel
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functional test of_the Rod Pattern Control System Rod Withdrawal
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Limiter High Power Setpoint being conducted within one hour prior to control rod movement unless performed wirdnin the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required by Technical Specification Table.4.3.6-1 Item 1.b. Note (c).
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[2.] On September 11 and 12, 1987, thermal overicad protection for Valve--
IFP079 was not bypassed continuously for a period in exc'ess of y > i.
eight hours and the affected valve was not declared inoperable in accordance with Technical Specification 3.3.4.2.
[3.] Between September 3 and 16, 1987, theweeklysample-aAlysisof
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Process Radiation Monitor ORIX-PR001 requireOSy Technica.!
3' Specification Table 4.11.2-1 Item C was not per/omed and the t,
,I channel was not declared inoperable.
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[4.] On September 23, 1987, both trains of main condenser offgas V
treatment system hydrogen monitors were inoperable far a period of more than four hours without a grab sample being taken in accordance with Technical Specification Table 3.3.7.12-1 Ite& 3.a
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ACTION 124.
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[5.] on September 29, 1987, the AC offsite power sources were not D demonstrated OPERABLE for a period of greater thari eight hours vitiv the IB diesel generator inoperable as required by Technical Specification 3.8.1.1 ACTION b.
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[6.] Between September 25 and 30, 1987, a period of greater r.han 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> elapsed without verifying the seal leakage rate on primary containment Elevation 737' air lock doors as retuired by Technical
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Specification 4.6.1.3.a.1."
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Corrective Actions Taken And Results Achieved 2
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This event was ' rep'okred M.n / den (ee Event Report (LER) 87-051-00
'A dated Septembe-17h687. ' On Atwust 28, 1987, at 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />, the RodPattern'EentroO?rw9sdecillcdinoperableandcontrolrod motion was sto;ged.,At 0219 hburg >0 Pattern Controller was
- he Ciannel Functional Test was satisfactorily completed, auJ Ehe 70
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declared operaole. (j
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Clinton ' Power Station (APS) PIocedure 3002,01, "Heatup and Pressy 9.ze, tion," b s been revised to include the Channel Functional Testre'irt:emental Af ter reviewing r(c$rdt, and logs, it was determined that on August test being performed within the preiou/e 1 w$thobt the required 17, 1987, controfrodsweremovedinMo s; 24 liaurs. On July 18, 1987, the control roda may bjav'e b,een vfv4,4 in'Xode 1 without the required test being performeu-within 'tne l previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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not certain though, because the exact time of rod motion is not required to be logged.
It is possible that the operators comf.ied.
t A Technical Specification change was sabmitted to the NRC on October 30, 1987, to make the applicable Technical Specification less confusing.f 2.
This event was reported in LER 87-053-00 dated October 1, 1987.
The cause kf (his event is attribd:ed to utility licensed operator error as a result of failure,to complete the surveillance test The procedure being u's$1s cause was a confusing Contributing trv p m edure steps.
ea by the opeator to perform the procedum.
surveil /ance, Procedure 9061.03,5" Containment /Dryws31 Isolation Valve [three Month Operability},"{had been revised by a temporary change nethod which in'rerrupted the continuity of the procedure.
Four p' ages of the pro hdure steh for other systems were inserted E['
out of sequence, separating thefcompleting steps for testing the Fire Protection Evstem valves.
7,he operator performing the surveillance test' believed that all the steps were completed.
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J The operator whegerformed the inadquate, hvi,ew of annunciator I
status has been counselled on payids att'Jation to detail. The procedure drafters who use the temporary change methcd for y.
procedure revisions have been advised to consider human factors
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F when revising procedures. CPS Procedure 9061.03,
" Containment /Drywell Isolation Valve Three Month Operability,9 has i
- j been revised, and this revision corrects the discontinuity problem I
of the ;sw.edure.,
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This event was reported in LER 87-054-00 dated October 6, 1987.,
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The cause,of this evet. is attributed to utility personnel em o.
The Chist--Nuclear filled to doquately track the need to perform E;
Surveillance 9954.07j for PRM ORIX-PR001 by September 10, 1987.
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I The Chemist-Nuclear has been counselled on the failure to adequately track the surveillance. requirement. The tracking system for performing surveillance has been reviewed and found to be adequatu.. All Chemistry technicians have been trained on the requirements as to when Surveillance 9954.02 is to be performed and
'the requirements of completing an accurate shift turnover for the oncoming shift.
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ThLa event war, reported.in LER 87-056-00 dated October 8, 1987, The cause of the > vent is attributeejto utility licensed operator e
The'LirofAssistant Shift Supervisor (LASS) identified the error.
status of the hydvogan monitors but failed to recognize the
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requirenmt to ented the l Technical Specification Action Statement.
The LASS' involved in 1;he event. was counselled on the failure to recognize the.1:equirdent to enter the Technical Specification Action Statement.
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This event was reported in LER 87-057-00 dated October 19, 1987.
The cause of this event is attributed to utility licensed operator error. The LASS became preoccupied with supervising the Pressure Regulator testing and overlooked the Action Statement requirement.
On September 29, 1987, the Technical Specifit. nfon Action Statement was satisfactorily completed at 21A0 hours. The LASS has been counselled on the failure to implement the Action Statemenn and all apprppriatti Operations supervisors have ben raade aware of this event.. I
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This mdnt wss reported in LER 87-058-00 dated October 19, 1987.
The cause'of this event is attributed to utility licensed cperator
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The LASS misinterpreted the Technical Specification j
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requirements for maintaining operability of the containment air k
lock doors and containment integrity.,!The Lt.SS was convinced that the inner air lock deor leak test was not required until the outer
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door was repaired and restored to' operability. Operations has been
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provided with a forn i. interpretation of.the Technical l
Specifications ist leak test requirements and associated actions to i
be taken for nn inoperable air lock door.
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l Corrective Actions faken To Prevent Recurrence Each of the above LERs identifies a failure'to meet the OPERABILITY requirements for short-term Limiting Condic1Ns for Operation.
To remedy this problem, the Assistant Manager - Plant Operations has initiated a trucking board which is being maintained on shift to track abort-term Limiting Conditions for Operation (LCOs) and to prevent missing deadlines.
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Additionally, to address the problem of increasing LERs, an LER i
Reduction Plan has been initiated. The Assistant Manager - Plant j
Operations has reviewed all CPS LERs and has outlined a corrective i
l action training program for Nuclear ' raining Department (NTD) l implementation. The Assistant Manager - Plant Operations also developed 1
articles addressing the LIF. generation rate, which were published in the daily newsletter.
O The Supervisor - Plant Support Services has initiated an LER status board'st the entrance to the Service Building to draw attention to current LERs.
There are also several ongoing programs to address LER reduction. The Manager - CPS is presenting a speech on commitment to excellence to all Plant Staff employees, including discussion of the importance of personnel performance in day-to-day activities. The Manager - CPS is also-interviewing employees involved in LER personnel errors prior to the employee returning to normal duties to determine the individual's frame of mind and. suitability for duty.
The Assistant Manager - Plant Operations identifies responsible managers to clear equipment deficiencies impacting LCOs. The Assistant Manager - Plant Operations also initiates procedure changes as required to prevent LERs.
Plant Modifications are initiated as required to correct design problems.
Date When Full Compliance Will Be Achieved Illinois Power is now in full compliance.
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